Case3:14-cv-01012-SI Document1 Filed03/05/14 Page1 of 23
`
`
`
`WILLIAM H. MANNING (pro hac vice pending)
`E-mail: WHManning@rkmc.com
`RICHARD M. MARTINEZ (pro hac vice pending)
`
`E-mail: RMMartinez@rkmc.com
`AARON R. FAHRENKROG (pro hac vice pending)
`E-mail: ARFahrenkrog@rkmc.com
`LOGAN J. DREW (pro hac vice pending)
`E-mail: LJDrew@rkmc.com
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`2800 LaSalle Plaza
`800 LaSalle Avenue
`Minneapolis, MN 55402–2015
`Telephone: 612–349–8500
`Facsimile:
`612–339–4181
`
`J. SCOTT CULPEPPER (pro hac vice pending)
`E-mail: JSCulpepper@rkmc.com
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`One Atlantic Center
`1201 West Peachtree St., Suite 2200
`Atlanta, GA 30309–3453
`Telephone: 404–760–4300
`Facsimile:
`404–233–1267
`
`DAVID MARTINEZ, Bar No. 193183
`DMartinez@rkmc.com
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`2049 Century Park East, Suite 3400
`Los Angeles, CA 90067–3208
`Telephone: 310-552–0130
`Facsimile: 310-229–5800
`Attorneys for Plaintiffs
`ADVANCED MICRO DEVICES, INC.
`and ATI TECHNOLOGIES ULC
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`
`Case No. 5:14-cv-1012
`
`
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`DEMAND FOR JURY TRIAL
`
`
`(1) ADVANCED MICRO DEVICES, INC.,
`a Delaware Corporation,
`(2) ATI TECHNOLOGIES ULC,
`a Canadian unlimited liability
`company,
`
`Plaintiffs,
`
`v.
`
`Case No. 5:14-cv-1012
`
`
`
`
`
`COMPLAINT
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`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`
`ATTORNEYS AT LAW
`
`MINNEAPOLIS
`
`LG Ex. 1003, pg 1
`
`

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`Case3:14-cv-01012-SI Document1 Filed03/05/14 Page2 of 23
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`1) LG ELECTRONICS, INC., a Korean
`entity,
`(2) LG ELECTRONICS U.S.A., Inc., a
`Delaware entity,
`(3) LG ELECTRONICS MOBILECOMM
`U.S.A., INC., a California entity,
`Defendants.
`
`
`
`Plaintiffs Advanced Micro Devices, Inc. and ATI Technologies ULC (collectively
`“Plaintiff” or “AMD”) for their complaint allege as follows:
`INTRODUCTION
`This is an action against LG Electronics, Inc. and its U.S. subsidiaries and related
`entities LG Electronics U.S.A., Inc., and LG Electronics MobileComm U.S.A., Inc.,
`(individually or collectively “Defendants” or “LG Electronics”), for patent infringement
`under the Patent Laws of the United States, 35 U.S.C. § 1 et seq., for infringing the
`following AMD patents:
`U.S. Patent No. 6,889,332 (“Helms ’332 patent”), entitled “Variable
`(a)
`Maximum Die Temperature Based on Performance State,” owned by Advanced
`Micro Devices, Inc.;
`(b) U.S. Patent No. 6,895,520 (“Altmejd ’520 patent”), entitled “Performance and
`Power Optimization via Block Oriented Performance Measurement and Control,”
`owned by Advanced Micro Devices, Inc.;
`U.S. Patent No. 6,897,871 (“Morein ’871 patent”), entitled “Graphics
`Processing Architecture Employing a Unified Shader,” owned by Advanced
`Micro Devices, Inc.’s subsidiary, ATI Technologies ULC;
`(d) U.S. Patent No. 7,327,369 (“Morein ’369 patent”), entitled “Graphics
`Processing Architecture Employing a Unified Shader,” owned by Advanced
`Micro Devices, Inc.’s subsidiary, ATI Technologies ULC;
`
`(c)
`
`Case No. 5:14-cv-1012
`
`
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`- 2 -
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`COMPLAINT
`
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`
`ATTORNEYS AT LAW
`
`MINNEAPOLIS
`
`LG Ex. 1003, pg 2
`
`

`
`Case3:14-cv-01012-SI Document1 Filed03/05/14 Page3 of 23
`
`
`
`(e)
`
`(f)
`
`U.S. Patent No. 7,742,053 (“Lefebvre ’053 patent”), entitled “Multi-Thread
`Graphics Processing System,” owned by Advanced Micro Devices, Inc.’s
`subsidiary, ATI Technologies ULC;
`U.S. Patent No. 5,898,849 (“Tran ’849 patent”), entitled “Microprocessor
`Employing Local Caches for Functional Units to Store Memory Operands Used by
`the Functional Units,” owned by Advanced Micro Devices, Inc.;
`(g) U.S. Patent No. 6,266,715 (“Loyer ’715 patent”), entitled “Universal Serial
`Bus Controller with a Direct Memory Access Mode,” owned by Advanced
`Micro Devices, Inc.;
`(h) U.S. Patent No. 6,784,879 (“Orr ’879 patent”), entitled “Method and
`Apparatus for Providing Control of Background Video,” owned by Advanced
`Micro Devices, Inc.’s subsidiary, ATI Technologies ULC; and
`U.S. Patent No. 7,095,945 (“Kovacevic ’945 patent”), entitled “System for
`Digital Time Shifting and Method Thereof,” owned by Advanced Micro
`Devices, Inc.’s subsidiary, ATI Technologies ULC.
`
`Collectively, the AMD patents generally cover technologies that provide critical
`functionalities in consumer electronic devices, meet and exceed myriad performance
`requirements while enabling attractive form factors demanded by users in mobile
`devices, and deliver an improved user experience in a wide variety of consumer
`products. Among other things, the AMD patents disclose technologies relating to
`semiconductors with innovative logic or design, improved graphics and video
`processing, ways to more effectively communicate across communications networks,
`improved user interface functionalities and capabilities, and consumer products
`incorporating or embodying the disclosed inventions.
`THE PARTIES
`1.
`Advanced Micro Devices, Inc. is a Delaware corporation with its principal
`executive offices at One AMD Place, Sunnyvale, California 94085. Advanced Micro
`Devices, Inc. is an innovative and pioneering technology company that designs
`
`(i)
`
`Case No. 5:14-cv-1012
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`- 3 -
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`COMPLAINT
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`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`
`ATTORNEYS AT LAW
`
`MINNEAPOLIS
`
`LG Ex. 1003, pg 3
`
`

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`Case3:14-cv-01012-SI Document1 Filed03/05/14 Page4 of 23
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`computer processors and related technologies for commercial and consumer markets.
`Advanced Micro Devices, Inc. designs and integrates cutting-edge technology that
`enables immersive graphics, high-definition video, and innovative features that power
`millions of electronic devices.
`2.
`ATI Technologies ULC is a subsidiary of Advanced Micro Devices, Inc.
`and is incorporated in Alberta, Canada with its principal offices at 1 Commerce Valley
`Drive E, Markham, Ontario, L3T 7X6, Canada. ATI Technologies ULC supports
`Advanced Micro Devices Inc.’s design and development of cutting-edge technology that
`enables immersive graphics, high-definition video, and innovative features that power
`millions of electronic devices.
`3.
`LG Electronics, Inc. (“LGI”) is a Korean business entity with its principal
`offices at LG Twin Towers 20, Yeouido-dong, Yeongdeungpo-gu, Seoul, South Korea
`150–721. On information and belief, LGI is a $50 billion global leader in consumer
`electronics, home appliances, and mobile communications, and is one of Asia’s largest
`electronics companies. On information and belief, LGI designs, manufactures, has
`manufactured, uses, offers for sale, sells and/or imports into the United States a wide
`variety of consumer electronics products, including numerous televisions, smartphones,
`tablets, Blu-ray players, projectors, and smart appliances.
`4.
`LG Electronics U.S.A., Inc. (“LGE”) is a Delaware corporation with its
`principal place of business located at 1000 Sylvan Avenue, Englewood Cliffs, New Jersey
`07632. On information and belief, LGE is a wholly-owned subsidiary of LGI. On
`information and belief, LGE is the U.S. sales arm for LGI and manufactures, has
`manufactured, uses, offers for sale, sells and/or imports into the United States a wide
`range of consumer electronics products, including numerous televisions, smartphones,
`tablets, Blu-ray players, projectors, and smart appliances, conducts primary market and
`product research for LGI, and enables regional customers to influence the direction of
`LGI’s future technologies and products.
`
`Case No. 5:14-cv-1012
`
`
`
`- 4 -
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`COMPLAINT
`
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`
`ATTORNEYS AT LAW
`
`MINNEAPOLIS
`
`LG Ex. 1003, pg 4
`
`

`
`Case3:14-cv-01012-SI Document1 Filed03/05/14 Page5 of 23
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`5.
`LG Electronics MobileComm U.S.A., Inc. (“LGM”) is a California
`corporation with its principal place of business at 10225 Willow Creek Road, San Diego,
`California 92131, and at least one other place of business in the State of California at 2570
`North 1st Street, #360, San Jose, California 95131. On information and belief, LGM is a
`wholly-owned subsidiary of LGE. On information and belief, LGM manufactures, has
`manufactured, uses, offers for sale, sells and/or imports into the United States various
`consumer electronics products, including smartphones and tablets, conducts primary
`market and product research for LGI and LGE, and enables regional customers to
`influence the direction of LGI and LGE’s future technologies and products.
`JURISDICTION
`6.
`This is an action for patent infringement, over which this Court has subject
`matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`7.
`This Court has personal jurisdiction over each of the Defendants consistent
`with the requirements of California Code of Civil Procedure § 410.10 and the Due
`Process Clause of the United States Constitution. Each Defendant transacts substantial
`business in California (and in this District), or has committed and continues to commit
`acts of patent infringement in California (and in this District) as alleged in this
`complaint. In addition, on information and belief, LGM maintains places of business in
`the State of California at 10225 Willow Creek Road, San Diego, California 92131, and
`2570 North 1st Street, #360, San Jose, California 95131.
`VENUE
`8.
`Venue is proper in this district pursuant to 28 U.S.C. §§ 1391 (b)-(d) and
`1400(b) because Defendants are subject to personal jurisdiction in this District, have
`committed acts of patent infringement in this District, and/or have regular and
`established places of business in this District.
`INTRADISTRICT ASSIGNMENT
`9.
`This is a patent infringement action and is therefore exempt from
`Intradistrict Assignment under Civil L.R. 3–2(c).
`
`Case No. 5:14-cv-1012
`
`
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`- 5 -
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`COMPLAINT
`
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`
`ATTORNEYS AT LAW
`
`MINNEAPOLIS
`
`LG Ex. 1003, pg 5
`
`

`
`Case3:14-cv-01012-SI Document1 Filed03/05/14 Page6 of 23
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`FACTUAL BACKGROUND
`10.
`Plaintiffs solely own all rights, titles, and interests in and to the following
`United States patents (collectively, the “AMD Patents”), including the exclusive rights to
`bring suit with respect to any past, present, and future infringement thereof:
`(a)
`U.S. Patent No. 6,889,332 (“Helms ’332 patent”), entitled “Variable
`Maximum Die Temperature Based on Performance State,” which was duly and
`legally issued on May 3, 2005, from a patent application filed December 11,
`2001, with Frank P. Helms and Jeffrey A. Brinkley as the named inventors.
`Among other things, the Helms ’332 patent discloses a system for adjusting
`available processor performance states as a function of thermal
`characteristics. The Helms ’332 patent’s scaling of maximum available
`frequencies based on thermal data increases device reliability by
`preventing overheating while also allowing for high levels of
`performance. The thermal mitigation techniques taught by the Helms ’332
`patent also enable the attractive form factors that consumers have come to
`expect from their mobile devices—thin, light smartphones and tablets
`made of inexpensive materials such as plastic or aluminum.
`(b) U.S. Patent No. 6,895,520 (“Altmejd ’520 patent”), entitled “Performance and
`Power Optimization via Block Oriented Performance Measurement and Control,”
`which was duly and legally issued on May 17, 2005, from a patent
`application filed March 2, 2001, with Morrie Altmejd as the first-named
`inventor. Among other things, the Altmejd ’520 patent discloses a system
`for independently adjusting power to functional blocks in an integrated
`circuit based on utilization information. The Altmejd ’520 patent allows,
`for example, a processor to distribute its workload across various
`functional blocks based on how busy the various functional blocks are in
`relation to one another. This, in turn, allows for an optimal balance
`between required processor performance and power consumption. The
`
`Case No. 5:14-cv-1012
`
`
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`- 6 -
`
`COMPLAINT
`
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`
`ATTORNEYS AT LAW
`
`MINNEAPOLIS
`
`LG Ex. 1003, pg 6
`
`

`
`Case3:14-cv-01012-SI Document1 Filed03/05/14 Page7 of 23
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`(c)
`
`Altmejd ’520 patent allows for more aggressive performance in devices
`such as smartphones while improving battery life. The decreased need for
`battery power allows for smaller batteries in mobile devices, thereby
`allowing the thinner, lighter devices that consumers demand.
`U.S. Patent No. 6,897,871 (“Morein ’871 patent”), entitled “Graphics
`Processing Architecture Employing a Unified Shader,” which was duly and
`legally issued on May 24, 2005, from a patent application filed November
`20, 2003, with Steven Morein as the first-named inventor. Among other
`things, the Morein ’871 patent discloses a unified shader architecture in a
`graphics processor. The Morein ’871 patent’s use of a unified shader
`architecture allows for smaller chip size, increases three-dimensional
`graphics performance and video performance, and provides for more
`efficient use of processor resources. These improvements result in better
`graphics performance and improved battery life in numerous consumer
`electronics devices that require high-quality graphics.
`(d) U.S. Patent No. 7,327,369 (“Morein ’369 patent”), entitled “Graphics
`Processing Architecture Employing a Unified Shader,” which was duly and
`legally issued on February 5, 2008, from a patent application filed April 29,
`2005, with Steven Morein as the first-named inventor. Among other things,
`the Morein ’369 patent discloses a unified shader architecture in a graphics
`processor that includes a parameter cache operative to maintain
`appearance attribute data for a corresponding vertex and a position cache
`operative to maintain position data for a corresponding vertex. The Morein
`’369 patent’s unified shader architecture with parameter and position
`caches provides for more efficient use of processor resources, allows for
`increased bandwidth, and delivers reduced power consumption in three-
`dimensional graphics and video. These improvements result in better
`graphics performance, improved user experience, and improved battery
`
`Case No. 5:14-cv-1012
`
`
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`- 7 -
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`COMPLAINT
`
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`
`ATTORNEYS AT LAW
`
`MINNEAPOLIS
`
`LG Ex. 1003, pg 7
`
`

`
`Case3:14-cv-01012-SI Document1 Filed03/05/14 Page8 of 23
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`(e)
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`(f)
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`life in numerous consumer electronics devices that require high-quality
`graphics.
`U.S. Patent No. 7,742,053 (“Lefebvre ’053 patent”), entitled “Multi-Thread
`Graphics Processing System,” which was duly and legally issued on June 22,
`2010, from a patent application filed May 9, 2007, with Laurent Lefebvre as
`the first-named inventor. Among other things, the Lefebvre ’053 patent
`discloses a unified shader architecture in a graphics processor capable of
`processing pixel and vertex command threads based on relative priorities
`or through multiple flexible processing engines. The Lefebvre ’053 patent’s
`use of a unified shader architecture with prioritized processing of
`commands allows for flexible allocation of finite processor resources to
`handle variable graphics workloads. This allows for more flexible graphics
`performance and improved user experience in consumer electronics
`devices that require high-quality graphics, including graphics processing
`from multiple input sources, as well as improved battery life and reduced
`cost.
`U.S. Patent No. 5,898,849 (“Tran ’849 patent”), entitled “Microprocessor
`Employing Local Caches for Functional Units to Store Memory Operands Used
`By the Functional Units,” which was duly and legally issued on April 27,
`1999, from a patent application filed April 4, 1997, with Thang M. Tran as
`the sole named inventor. Among other things, the Tran ’849 patent
`discloses a processor architecture having dedicated local caches for
`functional units of the processor. The Tran ’849 patent provides for
`dramatic improvement in graphics processing unit performance by
`overcoming limits imposed by texture memory bandwidth. The use of
`dedicated local caches in the architecture taught in the Tran ’849 patent
`allows for the superior utilization of numerous shaders by avoiding idle
`time in those shaders. The use of dedicated local caches also reduces the
`
`Case No. 5:14-cv-1012
`
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`- 8 -
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`COMPLAINT
`
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`
`ATTORNEYS AT LAW
`
`MINNEAPOLIS
`
`LG Ex. 1003, pg 8
`
`

`
`Case3:14-cv-01012-SI Document1 Filed03/05/14 Page9 of 23
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`power consumption typically experienced when functional units must
`access data stored in shared memory that may be located off the chip.
`These technical improvements, in turn, result in faster graphics, increased
`power efficiency, and an improved audio/video experience for users.
`(g) U.S. Patent No. 6,266,715 (“Loyer ’715 patent”), entitled “Universal Serial
`Bus Controller with a Direct Memory Access Mode,” which was duly and
`legally issued on July 24, 2001, from a patent application filed June 1, 1998,
`with Bruce A. Loyer as the first-named inventor. Among other things, the
`Loyer ’715 patent discloses a USB controller having a direct memory access
`(“DMA”) mode, comprising a plurality of USB endpoints, each selectively
`programmed for one of a plurality of DMA channels during the DMA
`mode of the USB controller. Among other things, the Loyer ’715 patent
`provides improved overall device performance through increased data
`transfer speeds, better power efficiency, and freeing the device’s CPU to
`perform other tasks.
`(h) U.S. Patent No. 6,784,879 (“Orr ’879 patent”), entitled “Method and
`Apparatus for Providing Control of Background Video,” which was duly and
`legally issued on August 31, 2004, from a patent application filed July 14,
`1997, with Stephen J. Orr as the first-named inventor. Among other things,
`the Orr ’879 patent discloses a method and apparatus for control of
`background video on a display, which allows the user to control attributes
`of the video while the video continues to play in the background and
`another application remains in focus on the display. In modern devices, the
`Orr ’879 patent allows users to multitask seamlessly, running applications
`on their televisions, smartphones, and other devices while simultaneously
`displaying and adjusting video content. The easier, friendlier user
`interface enabled by the Orr ’879 patent provides a more efficient, user-
`friendly interface where users are able to adjust live video attributes
`
`Case No. 5:14-cv-1012
`
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`- 9 -
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`COMPLAINT
`
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`
`ATTORNEYS AT LAW
`
`MINNEAPOLIS
`
`LG Ex. 1003, pg 9
`
`

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`Case3:14-cv-01012-SI Document1 Filed03/05/14 Page10 of 23
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`(i)
`
`without requiring them to close out of or lose access to applications of
`interest that are in focus.
`U.S. Patent No. 7,095,945 (“Kovacevic ’945 patent”) entitled “System for
`Digital Time Shifting and Method Thereof,” which was duly and legally
`issued on August 22, 2006, from a patent application filed November 6,
`2000, with Branko Kovacevic as the sole named inventor. Among other
`things, the Kovacevic ’945 patent discloses a system and method for
`demultiplexing a received packetized, multiplexed data stream carrying
`multimedia programs. More specifically, the Kovacevic ’945 patent enables
`the pausing of streaming video transmitted to an internet-enabled device.
`Further, the Kovacevic ’945 patent enables the buffering of video data of
`streaming video transmitted to an internet-enabled device. The Kovacevic
`’945 patent provides a more user-friendly experience by allowing end
`users to time shift programs of interest by pausing playback and
`continuing to watch streaming internet content at the user’s convenience.
`11.
`Each of the AMD Patents is valid and enforceable.
`12.
`The Defendants have actual notice of all of the AMD Patents and the
`infringement alleged herein at least upon filing of this complaint (if not earlier),
`pursuant to 35 U.S.C. § 287(a). On information and belief, Defendants had prior actual
`notice of at least the Helms ’332, Altmejd ’520, Morein ’871, Morein ’369, Lefebvre ’053,
`Tran ’849, Loyer ’715, Orr ’879, and Kovacevic ’945 patents no later than July 2012.
`13.
`Each of the Defendants has directly infringed, and continues to infringe,
`literally or under the doctrine of equivalents, one or more claims of the AMD Patents by
`acting without authority to make, have made, use, offer to sell, sell within the United
`States, or import into the United States consumer electronics products, including at least
`LG televisions, smartphones, tablets, Blu-ray players, projectors, and smart appliances,
`that embody or practice the patented inventions.
`
`Case No. 5:14-cv-1012
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`- 10 -
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`COMPLAINT
`
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`
`ATTORNEYS AT LAW
`
`MINNEAPOLIS
`
`LG Ex. 1003, pg 10
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`

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`Case3:14-cv-01012-SI Document1 Filed03/05/14 Page11 of 23
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`14.
`The above-described acts of infringement committed by Defendants have
`caused injury and damage to AMD, and will cause additional severe and irreparable
`injury and damages in the future.
`FIRST CLAIM FOR RELIEF
`Infringement of U.S. Patent No. 6,889,332
`15. AMD incorporates by reference the allegations set forth in paragraphs 1
`through 14 above as if specifically set forth herein.
`16. Defendants have directly infringed one or more claims of the Helms ’332
`patent, literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. § 271.
`The infringing products include, but are not limited to, for example, LG’s products that
`incorporate features for adjusting available performance states as a function of thermal
`characteristics, including but not limited to smartphones such as the LG G2 (including
`model nos. VS980, LS980, D800, and D801), the LG G Flex (including model nos. LS995,
`D950, and D959), the LG Optimus F7 (including model nos. LG870 and US780), the LG
`Lucid 2 (VS870), the LG Mach (LS860), the LG Optimus F6 (including model nos. D500
`and MS500), the LG Enact (VS890), the LG Optimus F3 (including model nos. P659,
`MS659, VM720, and LS720), the LG Optimus F3Q (D520), the LG Optimus G Pro (E980),
`the LG Optimus G (including model nos. LS970 and E970), the LG Spectrum 2 (VS930),
`the LG Intuition (VS950), the LG Spirit 4G (MS870), the LG Escape (P870), the LG Motion
`4G (MS770), the LG Optimus Regard (LW770), the LG Viper (LS840), the LG Lucid
`(VS840), the LG Connect 4G (MS840), the LG Optimus Exceed (VS840PP), the LG Nitro
`HD (P930), and the LG Spectrum (VS920), as well as the LG G Pad 8.3 (V500) tablet and
`any and all other LG products that incorporate features for adjusting available
`performance states as a function of thermal characteristics, including LG products that
`incorporate these features that LG has indicated will be forthcoming. The infringement
`remains ongoing.
`
`Case No. 5:14-cv-1012
`
`
`
`- 11 -
`
`COMPLAINT
`
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`
`ATTORNEYS AT LAW
`
`MINNEAPOLIS
`
`LG Ex. 1003, pg 11
`
`

`
`Case3:14-cv-01012-SI Document1 Filed03/05/14 Page12 of 23
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`17. As a consequence of Defendants’ infringement, AMD is entitled to recover
`damages adequate to compensate it for the injuries complained of herein, but in no
`event less than a reasonable royalty.
`SECOND CLAIM FOR RELIEF
`Infringement of U.S. Patent No. 6,895,520
`18. AMD incorporates by reference the allegations set forth in paragraphs 1
`through 14 above as if specifically set forth herein.
`19. Defendants have directly infringed one or more claims of the Altmejd ’520
`patent, literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. § 271.
`The infringing products include, but are not limited to, for example, LG’s products that
`incorporate features for independently adjusting power to functional blocks based on
`utilization information, including but not limited to smartphones such as the LG G2
`(including model nos. VS980, LS980, D800, and D801), the LG G Flex (including model
`nos. LS995, D950, and D959), the LG Optimus F7 (including model nos. LG870 and
`US780), the LG Lucid 2 (VS870), the LG Mach (LS860), the LG Optimus F6 (including
`model nos. D500 and MS500), the LG Enact (VS890), the LG Optimus F3 (including
`model nos. P659, MS659, VM720, and LS720), the LG Optimus F3Q (D520), the LG
`Optimus G Pro (E980), the LG Optimus G (including model nos. LS970 and E970), the
`LG Spectrum 2 (VS930), the LG Intuition (VS950), the LG Spirit 4G (MS870), the LG
`Escape (P870), the LG Motion 4G (MS770), the LG Optimus Regard (LW770), the LG
`Viper (LS840), the LG Lucid (VS840), the LG Connect 4G (MS840), the LG Optimus
`Exceed (VS840PP), the LG Nitro HD (P930), the LG Spectrum (VS920), and the LG
`Optimus L9 (including model nos. P769 and MS769), as well as the LG G Pad 8.3 (V500)
`tablet and any and all other LG products that incorporate features for independently
`adjusting power to functional blocks based on utilization information, including LG
`products that incorporate these features that LG has indicated will be forthcoming. The
`infringement remains ongoing.
`
`Case No. 5:14-cv-1012
`
`
`
`- 12 -
`
`COMPLAINT
`
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`
`ATTORNEYS AT LAW
`
`MINNEAPOLIS
`
`LG Ex. 1003, pg 12
`
`

`
`Case3:14-cv-01012-SI Document1 Filed03/05/14 Page13 of 23
`
`
`
`20. As a consequence of Defendants’ infringement, AMD is entitled to recover
`damages adequate to compensate it for the injuries complained of herein, but in no
`event less than a reasonable royalty.
`THIRD CLAIM FOR RELIEF
`Infringement of U.S. Patent No. 6,897,871
`21. AMD incorporates by reference the allegations set forth in paragraphs 1
`through 14 above as if specifically set forth herein.
`22. Defendants have directly infringed one or more claims of the Morein ’871
`patent, literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. § 271.
`The infringing products include, but are not limited to, for example, LG’s television
`products that incorporate a unified shader architecture in for example an LG H13 system
`on chip (“SoC”), including but not limited to televisions such as the LG 55LA8600 Smart
`TV, the LG 55LA9700 Smart TV, the LG 55EA9800 Smart TV, the LG 60LA8600 Smart
`TV, and the LG 65LA9700 Smart TV, LG’s products that incorporate the PowerVR Series
`5 and PowerVR Series 6 graphics engines, including but not limited to smart appliances
`such as the WT6001HV Smart ThinQ washing machine, the WT6001HVA Smart ThinQ
`washing machine, the DLEX6001V Smart ThinQ dryer, and the DLGX6002V Smart
`ThinQ dryer, as well as any and all other LG television and smart appliance products
`that incorporate a unified shader architecture in a graphics processor, the LG Optimus
`L9 (including model nos. P769 and MS769) smartphone, and including LG products that
`incorporate these features that LG has indicated will be forthcoming. The infringement
`remains ongoing.
`23. As a consequence of Defendants’ infringement, AMD is entitled to recover
`damages adequate to compensate it for the injuries complained of herein, but in no
`event less than a reasonable royalty.
`
`- 13 -
`
`COMPLAINT
`
`
`
`Case No. 5:14-cv-1012
`
`
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`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`
`ATTORNEYS AT LAW
`
`MINNEAPOLIS
`
`LG Ex. 1003, pg 13
`
`

`
`Case3:14-cv-01012-SI Document1 Filed03/05/14 Page14 of 23
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`FOURTH CLAIM FOR RELIEF
`Infringement of U.S. Patent No. 7,327,369
`24. AMD incorporates by reference the allegations set forth in paragraphs 1
`through 14 above as if specifically set forth herein.
`25. Defendants have directly infringed one or more claims of the Morein ’369
`patent, literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. § 271.
`The infringing products include, but are not limited to, for example, LG’s television
`products that incorporate a unified shader architecture in a graphics processor that
`includes a parameter cache operative to maintain appearance attribute data for a
`corresponding vertex and a position cache operative to maintain position data for a
`corresponding vertex in for example an LG H13 system on chip (“SoC”), including but
`not limited to televisions such as the LG 55LA8600 Smart TV, the LG 55LA9700 Smart
`TV, the LG 55EA9800 Smart TV, the LG 60LA8600 Smart TV, and the LG 65LA9700
`Smart TV, LG’s products that incorporate the PowerVR Series 5 and PowerVR Series 6
`graphics engines, including but not limited to smart appliances such as the WT6001HV
`Smart ThinQ washing machine, the WT6001HVA Smart ThinQ washing machine, the
`DLEX6001V Smart ThinQ dryer, and the DLGX6002V Smart ThinQ dryer, as well as any
`and all other LG television and smart appliance products that incorporate a unified
`shader architecture in a graphics processor that includes a parameter cache operative to
`maintain appearance attribute data for a corresponding vertex and a position cache
`operative to maintain position data for a corresponding vertex, the LG Optimus L9
`(including model nos. P769 and MS769) smartphone, and including LG products that
`incorporate these features that LG has indicated will be forthcoming. The infringement
`remains ongoing.
`26. As a consequence of Defendants’ infringement, AMD is entitled to recover
`damages adequate to compensate it for the injuries complained of herein, but in no
`event less than a reasonable royalty.
`
`
`Case No. 5:14-cv-1012
`
`
`
`- 14 -
`
`COMPLAINT
`
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`
`ATTORNEYS AT LAW
`
`MINNEAPOLIS
`
`LG Ex. 1003, pg 14
`
`

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`Case3:14-cv-01012-SI Document1 Filed03/05/14 Page15 of 23
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`FIFTH CLAIM FOR RELIEF
`Infringement of U.S. Patent No. 7,742,053
`27. AMD incorporates by reference the allegations set forth in paragraphs 1
`through 14 above as if specifically set forth herein.
`28. Defendants have directly infringed one or more claims of the Lefebvre ’053
`patent, literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. § 271.
`The infringing products include, but are not limited to, for example, LG’s television
`products that incorporate a unified shader architecture capable of processing pixel and
`vertex command threads based on relative priorities or through multiple flexible
`processing engines in for example an LG H13 system on chip (“SoC”), including but not
`limited to televisions such as the LG 55LA8600 Smart TV, the LG 55LA9700 Smart TV,
`the LG 55EA9800 Smart TV, the LG 60LA8600 Smart TV, and the LG 65LA9700 Smart
`TV, LG’s products that incorporate the PowerVR Series 5 and PowerVR Series 6 graphics
`engines, including but not limited to smart appliances such as the WT6001HV Smart
`ThinQ washing machine, the WT6001HVA Smart ThinQ washing machine, the
`DLEX6001V Smart ThinQ dryer, and the DLGX6002V Smart ThinQ dryer, as well as any
`and all other LG television and smart appliance products that incorporate a unified
`shader architecture in a graphics processor capable of processing pixel and vertex
`command threads based on relative priorities or through multiple flexible processing
`engines, the