IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`POWER INTEGRATIONS, INC., a
`Delaware corporation,
`
`Plaintiff,
`
`V.
`
`FAIRCHILD SEMICONDUCTOR
`INTERNATIONAL, INC., a Delaware
`corporation, FAIRCHILD SEMICONDUCTOR
`CORPORATION, a Delaware corporation, and
`SYSTEM GENERAL CORPORATION, a
`Taiwanese corporation,
`
`Defendants.
`
`C.A. No.
`
`JURY TRIAL REQUESTED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Power Integrations, Inc. hereby alleges as follows:
`
`THE PARTIES
`
`1.
`
`Power Integrations, Inc. ("Power Integrations") is incorporated under the laws of
`
`the state of Delaware, and has a regular and established place of business at 5245 Hellyer
`
`Avenue, San Jose, California, 95138.
`
`2.
`
`Upon information and belief, defendant Fairchild Semiconductor International,
`
`Inc. is incorporated under the laws of the state of Delaware, with its headquarters located at 82
`
`Running Hill Road, South Portland, Maine, 04106.
`
`3.
`
`Upon information and belief, defendant Fairchild Semiconductor Corporation is
`
`incorporated under the laws of the state of Delaware, with its headquarters located at 82 Running
`
`Hill Road, South Portland, Maine, 04106.
`
`4.
`
`Upon information and belief, defendant System General Corporation (hereinafter
`
`"SG") is incorporated under the laws of Taiwan, with its headquarters located at 517, No. 9, Alley
`
`1
`
`ON SEMICONDUCTOR EXHIBIT 1006
`Page 1 of 6
`
`

`
`6, Lane 45 Bao Shing Road, Shin Dian, Taipei, Taiwan. Upon information and belief, SG is a
`
`wholly owned subsidiary of Fairchild Semiconductor International, Inc.
`
`5.
`
`Defendant Fairchild Semiconductor International, Inc., defendant Fairchild
`
`Semiconductor Corporation, and defendant SG will hereinafter be collectively referred to as
`
`"Defendants."
`
`JURISDICTION AND VENUE
`
`6.
`
`This action arises under the patent laws of the United States, Title 35 U.S.C. § 1 et
`
`seq. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
`
`7.
`
`Upon information and belief, this Court has personal jurisdiction over Defendants
`
`because Defendants have purposely availed themselves of the privilege of conducting activities
`
`within this State and District.
`
`8.
`
`Upon information and belief, venue is proper in this Court pursuant to 28 U.S.C.
`
`§§ 1391(b), 1391(c), and 1400 because Defendants are subject to personal jurisdiction in this
`
`judicial District.
`
`GENERAL ALLEGATIONS
`
`9.
`
`Power Integrations' products include its TOPSwitch®, TinySwitch®,
`
`LinkSwitch®, and DPA-Switch® families of power conversion integrated circuit devices, which
`
`are used in power supplies for electronic devices such as cellular telephones, LCD monitors, and
`
`computers. These products are sold throughout the United States, including Delaware.
`
`10.
`
`Defendants manufacture pulse width modulation ("PWM") controller integrated
`
`circuit devices (e.g., devices intended for use in power conversion applications such as LCD
`
`monitor power supplies, off-line power supplies or battery chargers for portable electronics), and
`
`directly, and through their affiliates, make, use, import, sell, and offer to sell the same throughout
`
`the United States, including Delaware. Defendants also support and encourage others to import,
`
`use, offer for sale, and sell throughout the United States, including Delaware, products
`
`incorporating Defendants' integrated circuit devices.
`
`2
`
`ON SEMICONDUCTOR EXHIBIT 1006
`Page 2 of 6
`
`

`
`FIRST CAUSE OF ACTION
`
`INFRINGEMENT OF U.S. PATENT NO . 6,107,851
`
`The allegations of paragraphs 1-10 are incorporated as though fully set forth
`
`Power Integrations is now, and has been since its issuance, the assignee and sole
`
`herein.
`
`11.
`
`12.
`
`owner of all right, title, and interest in United States Patent No. 6,107,851, entitled "Offline
`
`Converter with Integrated Softstart and Frequency Jitter" ("the '851 patent"), which was duly
`
`and legally issued on August 22, 2000. A true and correct copy of the '851 patent is attached
`
`hereto as Exhibit A.
`
`13.
`
`Defendants have been and are now infringing, inducing infringement, and
`
`contributing to the infringement of the '851 patent in this District and elsewhere by making,
`
`using, selling, offering to sell, and/or importing devices, including PWM integrated circuit
`
`devices, covered by one or more claims of the '851 patent, and/or contributing to or inducing the
`
`same by third-parties, all to the injury of Power Integrations.
`
`14.
`
`15.
`
`Defendants' acts of infringement have injured and damaged Power Integrations.
`
`Defendants' acts of infringement have been, and continue to be, willful so as to
`
`warrant the enhancement of damages awarded as a result of their infringement.
`
`16.
`
`Defendants' infringement has caused irreparable injury to Power Integrations and
`
`will continue to cause irreparable injury until Defendants are enjoined from further infringement
`
`by this Court.
`
`herein.
`
`17.
`
`18.
`
`SECOND CAUSE OF ACTION
`
`INFRINGEMENT OF U.S. PATENT NO. 6,249,876
`
`The allegations of paragraphs 1-10 are incorporated as though fully set forth
`
`Power Integrations is now, and has been since its issuance, the assignee and sole
`
`owner of all right, title, and interest in United States Patent No. 6,249,876, entitled "Frequency
`
`Jittering Control for Varying the Switching Frequency of a Power Supply" ("the '876 patent"),
`
`3
`
`ON SEMICONDUCTOR EXHIBIT 1006
`Page 3 of 6
`
`

`
`which was duly and legally issued on June 19, 2001. A true and correct copy of the '876 patent
`
`is attached hereto as Exhibit B.
`
`19.
`
`Defendants have been and are now infringing, inducing infringement, and
`
`contributing to the infringement of the '876 patent in this District and elsewhere by making,
`
`using, selling, offering to sell, and/or importing devices, including PWM integrated circuit
`
`devices, covered by one or more claims of the '876 patent, and/or contributing to or inducing the
`
`same by third-parties, all to the injury of Power Integrations.
`
`20.
`
`21.
`
`Defendants' acts of infringement have injured and damaged Power Integrations.
`
`Defendants' acts of infringement have been, and continue to be, willful so as to
`
`warrant the enhancement of damages awarded as a result of their infringement.
`
`22.
`
`Defendants' infringement has caused irreparable injury to Power Integrations and
`
`will continue to cause irreparable injury until Defendants are enjoined from further infringement
`
`by this Court.
`
`THIRD CAUSE OF ACTION
`
`INFRINGEMENT OF U.S. PATENT NO. 7,110,270
`
`23.
`
`The allegations of paragraphs 1-10 are incorporated as though fully set forth
`
`herein.
`
`24.
`
`Power Integrations is now, and has been since its issuance, the assignee and sole
`
`owner of all right, title, and interest in United States Patent No. 7,110,270, entitled "Method and
`
`Apparatus for Maintaining a Constant Load Current with Line Voltage in a Switch Mode Power
`
`Supply" ("the '270 patent"), which was duly and legally issued on September 19, 2006. A true
`
`and correct copy of the '270 patent is attached hereto as Exhibit C.
`
`25.
`
`Upon information and belief, Defendants have been and are now infringing,
`
`inducing infringement, and contributing to the infringement of the '270 patent in this District and
`
`elsewhere by making, using, selling, offering to sell, and/or importing devices, including PWM
`
`integrated circuit devices, covered by one or more claims of the '270 patent, and/or contributing
`
`to or inducing the same by third-parties, all to the injury of Power Integrations.
`
`4
`
`ON SEMICONDUCTOR EXHIBIT 1006
`Page 4 of 6
`
`

`
`26.
`
`27.
`
`Defendants' acts of infringement have injured and damaged Power Integrations.
`
`Defendants' infringement has caused irreparable injury to Power Integrations and
`
`will continue to cause irreparable injury until Defendants are enjoined from further infringement
`
`by this Court.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiff requests the following relief:
`
`(a)
`
`(b)
`
`(c)
`
`(d)
`
`judgment that Defendants infringe of the '851 patent;
`
`judgment that Defendants infringe of the '876 patent;
`
`judgment that Defendants infringe of the '270 patent;
`
`a permanent injunction preventing Defendants and their officers, directors, agents,
`
`servants, employees, attorneys, licensees, successors, assigns, and customers, and those in active
`
`concert or participation with any of them, from making, using, offering to sell, or selling in the
`
`United States or importing into the United States any devices that infringe any claim of the '851,
`
`'876, or '270 patents, or contributing to or inducing the same by others;
`
`(e)
`
`judgment against Defendants for money damages sufficient to compensate Power
`
`Integrations for Defendants' infringement of the '851, '876, and '270 patents in an amount to be
`
`determined at trial;
`
`(f)
`
`that any such money judgment be trebled as a result of the willful nature of
`
`Defendants' infringement;
`
`(g)
`
`an accounting for infringing sales not presented at trial and an award by the court
`
`of additional damages for any such infringing sales;
`
`(h)
`
`costs and reasonable attorneys' fees incurred in connection with this action
`
`pursuant to 35 U.S.C § 285; and
`
`(i)
`
`such other and further relief as this Court finds just and proper.
`
`5
`
`ON SEMICONDUCTOR EXHIBIT 1006
`Page 5 of 6
`
`

`
`Plaintiff Power Integrations requests trial by jury.
`
`JURY DEMAND
`
`Dated: May 23, 2008
`
`FISH & RICHARDSON P.C.
`
`By.,
`
`William J. Marsden,\Jr. (#2247)
`Kyle Wagner-Compton (#4693)
`919 N. Market St`r`eet;-Suite 1100
`P.O. Box 1114
`Wilmington, DE 19801
`Telephone: (302) 652-5070
`Facsimile: (302) 652-0607
`Email: marsden a,fr.com
`kcompton ,fr.com
`
`Frank E. Scherkenbach
`225 Franklin Street
`Boston, MA 02110-2804
`Telephone: (617) 542-5070
`Facsimile: (617) 542-8906
`
`Howard G. Pollack
`Michael R. Headley
`Scott Penner
`500 Arguello Street, Suite 500
`Redwood City, CA 94063
`Telephone: (650) 839-5070
`Facsimile: (650) 839-5071
`
`80061065.doc
`
`Attorneys for Plaintiff
`POWER INTEGRATIONS, INC.
`
`6
`
`ON SEMICONDUCTOR EXHIBIT 1006
`Page 6 of 6