UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`Godo Kaisha IP Bridge 1
`
`Plaintiff,
`
`Civil Action No. 6:20-cv-00178
`
`JURY TRIAL DEMANDED
`
`
`v.
`
`Micron Technology, Inc.;
`Micron Semiconductor Products, Inc.; and
`Micron Technology Texas, LLC
`
`
`Defendants.
`
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Godo Kaisha IP Bridge 1 (“IP Bridge”) asserts the following claims for patent
`
`infringement against Defendants Micron Technology, Inc.; Micron Semiconductor Products,
`
`Inc.; and Micron Technology Texas, LLC (collectively “Micron” or “Defendants”), and alleges
`
`as follows.
`
`NATURE OF THE ACTION
`
`1.
`
`This is a civil action for infringement under the patent laws of the United States of
`
`America, 35 U.S.C. § 1 et seq.
`
`2.
`
`IP Bridge is the owner of all rights, title, and interest in U.S. Patent Nos.
`
`7,189,616; 6,747,320; 6,445,047; and 6,424,041 (collectively, the “Asserted Patents”).
`
`3.
`
`Defendants have infringed and continue to infringe one or more claims of IP
`
`Bridge’s Asserted Patents by making, using, offering to sell, and selling within the United States,
`
`and importing into the United States, including in this District, certain memory chips and
`
`graphics memory. IP Bridge seeks injunctive relief and monetary damages.
`
`
`
`1
`
`Micron Ex. 1001, p. 1
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
`
`

`

`THE PARTIES
`
`4.
`
`Plaintiff IP Bridge is a Japanese entity with its principal place of business located
`
`at c/o Sakura Sogo Jimusho, 1-11 Kanda Jimbocho, Chiyoda-ku, Tokyo, 101-0051 Japan.
`
`5.
`
`Defendant Micron Technology, Inc. (“Micron Technology”) is a Delaware
`
`corporation with a principal place of business at 8000 South Federal Way, Boise, Idaho 83716.
`
`Micron Technology also has a place of business at 101 West Louis Henna Boulevard, Suite 210,
`
`Austin, Texas 78728. Micron Technology is registered with the Texas Secretary of State to do
`
`business in Texas.
`
`6.
`
`Defendant Micron Semiconductor Products, Inc. (“Micron Semiconductor”) is an
`
`Idaho corporation with a principal place of business at 8000 South Federal Way, Boise, Idaho
`
`83716. Micron Semiconductor also has a place of business at 101 West Louis Henna Boulevard,
`
`Suite 210, Austin, Texas 78728. Micron Semiconductor is registered with the Texas Secretary of
`
`State to do business in Texas. Micron Semiconductor can be served through its registered agent,
`
`The Corporation Service Company, 211 E. 7th Street, Suite 620, Austin, TX 78701-3218.
`
`7.
`
`Defendant Micron Technology Texas, LLC (“Micron Texas”) is an Idaho limited
`
`liability company with a principal place of business at 8000 South Federal Way, Boise, Idaho
`
`83716. Micron Texas also has places of business at 101 West Louis Henna Boulevard, Suite
`
`210, Austin, Texas 78728; and 805 Central Expressway South #100, Allen, Texas 75013.
`
`Micron Texas can be served through its registered agent, The Corporation Service Company, 211
`
`E. 7th Street, Suite 620, Austin, TX 78701-3218.
`
`8.
`
`Micron is one of the largest memory chip makers in the world. It makes dynamic
`
`random access memory (DRAM), NAND Flash, and NOR Flash memory, and other memory
`
`products. Micron’s products are offered under the Micron, Crucial, and Ballistix brands, as well
`
`as private labels. Micron makes its own products in semiconductor fabrication plants in the
`
`
`
`2
`
`Micron Ex. 1001, p. 2
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
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`

`

`United States and other countries throughout the world. Micron sells its products to customers,
`
`including customers in this District, in the computer, networking and storage, consumer
`
`electronics, sold-state drives, and mobile telecommunications markets.
`
`9.
`
`Micron maintains offices in Austin and Allen, Texas. Within the United States,
`
`Micron also has offices in Folsom, Irvine, Longmont, Milpitas, San Diego, and San Jose,
`
`California; Boise and Meridian, Idaho; Minneapolis, Minnesota; Lehi, Utah; Manassas, Virginia;
`
`and Seattle, Washington.1 Outside the United States, Micron also has offices in China, India,
`
`Japan, Korea, Malaysia, Singapore, Taiwan, Belgium, Germany, Israel, Italy, and the United
`
`Kingdom.2
`
`10. Micron operates semiconductor fabrication plants in Boise, Idaho; Lehi, Utah; and
`
`Manassas, Virginia, and fabricates and manufactures DRAM products in at least Lehi, Utah and
`
`Manassas, Virginia.3 Outside the United States, Micron operates semiconductor fabrication
`
`plants in at least China, Japan, Singapore, and Taiwan.4
`
`11. Micron operates and owns the micron.com website, and markets, offers,
`
`distributes, and provides technical support for its DRAM products throughout the United States
`
`including in this District.
`
`12.
`
`Each of the Defendants develops, designs, manufactures, distributes, markets,
`
`offers to sell, or sells infringing products or services within the United States, including in this
`
`District, and otherwise purposefully directs infringing activities to this District in connection
`
`
`1 Ex. E, https://www.micron.com/about/locations (last visited Feb. 11, 2020).
`2 Id.
`3 Ex. F, https://en.wikipedia.org/wiki/List_of_semiconductor_fabrication_plants (last visited
`Feb. 11, 2020).
`4 Id.
`
`
`
`3
`
`Micron Ex. 1001, p. 3
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
`
`

`

`with its Austin, Texas office; its micron.com website; and its other places of business in Texas
`
`and the rest of the United States.
`
`13.
`
`Defendants have been and are acting in concert, and are otherwise liable jointly,
`
`severally, or otherwise for relief related to or arising out of the same transaction, occurrence, or
`
`series of transactions or occurrences related to the making, using, selling, offering for sale, or
`
`otherwise distributing the DRAM products in this District.
`
`14.
`
`In addition, this action involves questions of law and fact that are common to all
`
`Defendants. For example, Defendants are making, using, offering for sale, selling, or otherwise
`
`distributing at least some of the same DRAM products in this District.
`
`JURISDICTION AND VENUE
`
`15.
`
`This is a civil action for patent infringement arising under the patent laws of the
`
`United States, 35 U.S.C. § 1 et seq. This Court has subject matter jurisdiction over the matters
`
`asserted in this Complaint under 28 U.S.C. §§ 1331 and 1338(a) and 35 U.S.C. §§ 271 et seq.
`
`16.
`
`This Court has personal jurisdiction over Defendants in accordance with due
`
`process and/or the Texas Long Arm Statute because, in part, Defendants “recruit[] Texas
`
`residents, directly or through an intermediary located in this state, for employment inside or
`
`outside this state.” Tex. Civ. Prac. & Rem. Code § 17.042(3).
`
`17.
`
`This Court has personal jurisdiction over Defendants, in part because Defendants
`
`do continuous and systematic business in this District, including by providing infringing
`
`products and services to residents of this District that Defendants knew would be used within this
`
`District, and by soliciting business from residents of this District.
`
`18.
`
`For example, Defendants are subject to personal jurisdiction in this Court
`
`because, inter alia, they have regular and established places of business in this District, including
`
`
`
`4
`
`Micron Ex. 1001, p. 4
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
`
`

`

`offices located at 101 West Louis Henna Boulevard, Suite 210, Austin, Texas 78728.5 The
`
`Travis Central Appraisal District (CAD) website6 indicates that both Micron Technology and
`
`Micron Semiconductor own the property at 101 West Louis Henna Boulevard, Suite 210, Austin,
`
`Texas 78728, and that it is appraised at more the $2 million dollars.7
`
`19. Micron’s Austin offices are regular and established places of business at least
`
`because these locations include many members of Micron’s important teams, including storage
`
`system architects, SPME system architects, storage system engineers, storage solutions
`
`engineers, and software engineers. Micron posts job openings for its Austin office,8 and as of
`
`January 27, 2020, Micron was posting three job openings for its Austin office that were available
`
`or recently filled.9 These and additional job postings can be found on LinkedIn and various
`
`other websites.10
`
`20.
`
`Based on publicly-available information, since 2012, Micron Technology has
`
`been the employer of approximately twenty-one recipients of H-1B visas who work and reside in
`
`
`5 Ex. G, https://www.micron.com/about/locations?country=USA&city=Austin (last visited Feb.
`11, 2020).
`6 Ex. H, https://www.traviscad.org/property-search/ (last visited Feb. 11, 2020); Ex. I,
`http://propaccess.traviscad.org/clientdb/?cid=1 (last visited Feb. 11, 2020).
`7 Ex. J, http://propaccess.traviscad.org/clientdb/Property.aspx?prop_id=874673 (last visited
`Feb. 11, 2020) (property record for Micron Technology); Ex. K,
`http://propaccess.traviscad.org/clientdb/Property.aspx?prop_id=926072 (last visited Feb. 11,
`2020) (property record for Micron Semiconductor).
`8 Ex. L, https://jobs.micron.com/search/?createNewAlert=false&q=&locationsearch=Austin
`(last visited Feb. 11, 2020).
`9 Ex. M, https://jobs.micron.com/job/Austin-Sr_-Ecosystem-Enabling-Manager-TX-
`73301/585945500/ (printed January 27, 2020); Ex. N, https://jobs.micron.com/job/Austin-Intern-
`Storage-Solutions-Engineer-TX-73301/617871400/ (printed January 27, 2020); Ex. O,
`https://jobs.micron.com/job/San-Jose-Architect%2C-Storage-System-CA-95101/615114200/
`(printed January 27, 2020).
`10 Ex. P, https://www.linkedin.com/jobs/view/intern-storage-solutions-engineer-at-micron-
`technology-1665147174/ (last visited Feb. 11, 2020); Ex. Q,
`https://my.jobs/jobs/micron/architect-storage-system/1578878764707444980 (last visited Feb.
`11, 2020).
`
`
`
`5
`
`Micron Ex. 1001, p. 5
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
`
`

`

`the Austin, Texas area.11 Micron Semiconductor has been the employer of at least two recipients
`
`of H-1B visas who work and reside in the Austin area.12 Additionally, Micron Technology has
`
`been the employer of approximately twelve recipients of H-1B visas who work and reside in the
`
`Allen, Texas area.13
`
`21. Micron, directly and through agents, regularly conducts, solicits, and transacts
`
`business in this District and elsewhere in Texas, including through its micron.com website. For
`
`example, Defendants employ sales and marketing employees that regularly offer to sell, sell, or
`
`otherwise distribute DRAM products in this District and elsewhere in Texas.
`
`22.
`
`In particular, Micron has committed and continues to commit acts of infringement
`
`in violation of 35 U.S.C. § 271, and has made, used, marketed, distributed, offered for sale, and
`
`sold infringing products in Texas, including in this District, and engaged in infringing conduct
`
`within and directed at or from this District. The infringing DRAM products have been and
`
`continue to be distributed to and used in this District. Micron’s acts cause injury to IP Bridge,
`
`including injury suffered within this District.
`
`23.
`
`Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b) because a
`
`substantial part of the events or omissions giving rise to the claims occurred in this District, and
`
`because Defendants have committed acts of infringement in this District and have a regular and
`
`established place of business in this District.
`
`
`11 Ex. R, https://h1bdata.info/index.php?em=Micron+Technology&job=&city=Austin&
`year=All+Years (last visited Jan. 27, 2019); Ex. S, https://h1bdata.info/index.php?em=Micron+
`Technology&job=&city=ROUND+ROCK&year=All+Years (last visited Jan. 27, 2019).
`12 Ex. T, https://h1bdata.info/index.php?em=Micron+Semiconductor&job=&city=Austin&
`year=All+Years (last visited Jan. 27, 2019).
`13 Ex. U, https://h1bdata.info/index.php?em=Micron+Technology&job=&city=Allen&
`year=All+Years (last visited Jan. 27, 2019).
`
`
`
`6
`
`Micron Ex. 1001, p. 6
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
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`

`

`24.
`
`In particular, Micron Technology, Micron Semiconductor, and Micron Texas
`
`have regular and established places of business located at 101 West Louis Henna Boulevard,
`
`Suite 210, Austin, Texas 78728. Furthermore, Micron Technology, Micron Semiconductor, and
`
`Micron Texas are all registered to do business in Texas.
`
`25. Micron Semiconductor and Micron Texas are wholly owned subsidiaries of
`
`Micron Technology. Micron Technology does not separately report revenue from Micron
`
`Semiconductor or Micron Texas in its filings to the Securities Exchange Commission, but rather
`
`reports combined revenue from its various products and subsidiaries.
`
`26.
`
`On information and belief, Micron Technology not only “owns” but also
`
`“operates” Micron Semiconductor and Micron Texas, including the cooperative development,
`
`improvement, and support of Micron’s products and services.
`
`IP BRIDGE’S PATENTS
`
`27.
`
`U.S. Patent No. 7,189,616 (the “’616 patent”) is entitled “Semiconductor Memory
`
`Device with Trench-Type Stacked Cell Capacitors and Method for Manufacturing the Same” and
`
`issued on March 13, 2007. A true and correct copy of the ’616 patent is attached as Exhibit A to
`
`this Complaint. IP Bridge is the owner of all rights, title, and interest in and to the ’616 patent,
`
`with the full and exclusive right to bring suit to enforce the ’616 patent, including the right to
`
`recover for past infringement. The ’616 patent is valid and enforceable under United States
`
`patent laws.
`
`28.
`
`The ’616 patent claims are directed to a patent-eligible, non-abstract idea. They
`
`address, among other things, a specific improvement for the design and fabrication of
`
`semiconductor memory devices. The ’616 patent claims are particularly useful for DRAMs or
`
`other memory devices that have trench-type stacked cell capacitors. A mask pattern layout with
`
`hole patterns may be used to etch a target film in order to fabricate the capacitors. As capacitors
`
`
`
`7
`
`Micron Ex. 1001, p. 7
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
`
`

`

`have gotten smaller, there is an increased risk that adjacent capacitors may interfere with one
`
`another. By staggering the hole patterns, it is possible to fabricate capacitors that are less likely
`
`to interfere with one another, thereby, producing better and more reliable DRAMs.
`
`29.
`
`U.S. Patent No. 6,747,320 (the “’320 patent”) is entitled “Semiconductor Device
`
`with DRAM Inside” and issued on June 8, 2004. A true and correct copy of the ’320 patent is
`
`attached as Exhibit B to this Complaint. IP Bridge is the owner of all rights, title, and interest in
`
`and to the ’320 patent, with the full and exclusive right to bring suit to enforce the ’320 patent,
`
`including the right to recover for past infringement. The ’320 patent is valid and enforceable
`
`under United States patent laws.
`
`30.
`
`The ’320 patent claims are directed to a patent-eligible, non-abstract idea. They
`
`address, among other things, a specific improvement for the design and fabrication of
`
`semiconductor memory devices. The ’320 patent claims are particularly useful for DRAMs or
`
`other memory devices that have a high-speed CMOS logic region. Specifically, the claims are
`
`useful for improvements of sense amplifiers in high-speed logic. In a conventional sense
`
`amplifier, a parasitic capacitor is formed on one side, which impacts the amplifier’s usefulness in
`
`high-speed operation. In addition, if the mask’s alignment shifts during formation of an active
`
`region or during formation of a gate electrode, the balance between pairs of transistors is
`
`degraded, reducing sensitivity of the sense amplifier. The ’320 patent’s claims therefore enable
`
`the difference in characteristics between a pair of sense amplifier transistors to be suppressed and
`
`the sensitivity of the sense amplifier to be enhanced.
`
`31.
`
`U.S. Patent No. 6,445,047 (the “’047 patent”) is entitled “Semiconductor Device
`
`and Method for Fabricating the Same” and issued on September 3, 2002. A true and correct
`
`copy of the ’047 patent is attached as Exhibit C to this Complaint. IP Bridge is the owner of all
`
`
`
`8
`
`Micron Ex. 1001, p. 8
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
`
`

`

`rights, title, and interest in and to the ’047 patent, with the full and exclusive right to bring suit to
`
`enforce the ’047 patent, including the right to recover for past infringement. The ’047 patent is
`
`valid and enforceable under United States patent laws.
`
`32.
`
`The ’047 patent claims are directed to a patent-eligible, non-abstract idea. They
`
`address, among other things, a specific improvement for the design and fabrication of
`
`semiconductor memory devices. The ’047 patent claims are particularly useful for DRAMs or
`
`other memory devices that have surface-channel-type MOSFETs. In order to increase
`
`performance of a MOS semiconductor device, the ’047 patent recognizes that miniaturization,
`
`increasing the number of integrated devices and lowering operating voltages are required. One
`
`way to achieve this goal is by forming multiple types of surface-channel-type MOSFETs on
`
`semiconductor chips. But when forming surface-channel-type MOSFETs with relatively high
`
`threshold voltages, performance decreases as dopant concentrations increase. This can lead to
`
`shortened data retention times, and decreased carrier mobility. The ’047 patent solves these
`
`problems through the use of a first surface-channel-type MOSFET with a polysilicon film, and a
`
`second surface-channel-type MOSFET with a refractory metal film. The gate electrode of the
`
`second surface-channel-type MOSFET is made of a refractory metal or compound thereof,
`
`increasing its threshold voltage without increasing its dopant concentration.
`
`33.
`
`U.S. Patent No. 6,424,041 (the “’041 patent”) is entitled “Semiconductor Device”
`
`and issued on July 23, 2002. A true and correct copy of the ’041 patent is attached as Exhibit D
`
`to this Complaint. IP Bridge is the owner of all rights, title, and interest in and to the ’041 patent,
`
`with the full and exclusive right to bring suit to enforce the ’041 patent, including the right to
`
`recover for past infringement. The ’041 patent is valid and enforceable under United States
`
`patent laws.
`
`
`
`9
`
`Micron Ex. 1001, p. 9
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
`
`

`

`34.
`
`The ’041 patent claims are directed to a patent-eligible, non-abstract idea. They
`
`address, among other things, a specific improvement for the design and fabrication of
`
`semiconductor memory devices. The ’041 patent claims are particularly useful for DRAMs or
`
`other memory devices that have memory storage and copper wiring. While copper wiring has
`
`many benefits, copper atoms easily diffuse into silicon in silicon oxide film, causing short
`
`circuits, and into active regions of the silicon substrate, causing devices to malfunction. The
`
`’041 patent’s claims describe an improvement that reliably prevents this diffusion of copper
`
`atoms.
`
`35.
`
`IP Bridge’s Asserted Patents claim, among other things, a specific implementation
`
`of a solution to a problem in the design and fabrication of semiconductor devices. For example,
`
`the patents identify numerous specific advantages that IP Bridge’s claimed techniques provide
`
`compared to traditional forms of semiconductor devices. See, e.g., Ex. A, ’616 patent at 3:3-36;
`
`Ex. B, ’320 patent at 1:11-2:14; Ex. C, ’047 patent at 1:5-2:12; Ex. D, ’041 patent at 1:11-2:48.
`
`Further, the claimed technologies cannot be performed as mental steps by a human, nor do they
`
`represent the application of a generic computer to any well-known method of organizing human
`
`behavior.
`
`36.
`
`The Asserted Patents claim inventive concepts that are significantly more than
`
`any patent-ineligible, abstract idea. In particular, the claimed technologies, including individual
`
`limitations as well as ordered combinations of limitations, were not well-understood, routine, or
`
`conventional, and cover multiple advantages, and combinations of advantages, that were not
`
`well-understood, routine, or conventional. See, e.g., Ex. A, ’616 patent at 16:11-41; Ex. B, ’320
`
`patent at 7:22-8:48; Ex. C, ’047 patent at 8:58-10:14; Ex. D, ’041 patent at 9:54-12:3.
`
`
`
`10
`
`Micron Ex. 1001, p. 10
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
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`

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`DEFENDANTS’ INFRINGING PRODUCTS AND ACTIVITIES
`
`37. Micron is a global manufacturer and supplier of memory chips. Micron’s
`
`Compute and Networking Business Unit designs, makes, uses, offers to sell, sells, imports,
`
`supplies, or otherwise distributes memory chips for cloud server, enterprise, client, graphics, and
`
`networking purposes.14 Micron’s Mobile Business Unit designs, makes, uses, offers to sell,
`
`sells, imports, supplies, or otherwise distributes memory chips for smartphones and other
`
`mobile-devices.15 Micron’s Embedded Business Unit designs, makes, uses, offers to sell, sells,
`
`imports, supplies, or otherwise distributes memory chips for automotive, industrial, and
`
`consumer markets.
`
`38. Micron designs, makes, uses, offers to sell, sells, imports, supplies, or otherwise
`
`distributes, and provides support for, memory chips, including products with the part name or
`
`number GDDR5X, and other memory chips that have the same or similar structures, features, or
`
`functionalities, and/or are made by the same or similar manufacturing processes, as the
`
`aforementioned product (“Accused Memory Chips”). An exemplary technical analysis of the
`
`Micron MT58K256M32JA-100 GDDR5X SDRAM product (“GDDR5X”) is available for
`
`purchase at https://www.techinsights.com/products/0716-43012-o-5dm-100 (“TechInsights
`
`Report”).
`
`39.
`
`The Accused Memory Chips are integrated into devices made, used, offered for
`
`sale, sold, imported, supplied, or otherwise distributed in the United States by among others,
`
`Micron, Micron’s customers, original equipment manufacturers (“OEMS”), original design
`
`manufacturers (“ODMs”), foundry suppliers, distributers, and other third parties. Micron’s
`
`
`14 Micron’s 2018 Annual Report, available at http://www.annualreports.com/Company/micron-
`technology-inc (last visited Feb. 11, 2020), at 3.
`15 Id. at 2.
`
`
`
`11
`
`Micron Ex. 1001, p. 11
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`Accused Memory Chips are essential, non-trivial components of the products into which they are
`
`integrated.
`
`40. Micron also conducts research, development, and testing of Accused Memory
`
`Chips in the United States.
`
`41. Micron maintains a website that advertised Accused Memory Chips, including
`
`identifying the applications for which they can be used and specifications for the Accused
`
`Memory Chips.
`
`42. Micron’s development, sales, marketing, and manufacturing activities in the
`
`United States, including within this District, directly contributed to Micron’s net revenue in the
`
`United States.
`
`43.
`
`IP Bridge contacted Micron by letter dated January 27, 2020, informing Micron
`
`that IP Bridge owns a patent portfolio of more than 1,100 semiconductor related patents with
`
`broad patent coverage in the United States and other countries through the world; that based
`
`upon a review of publicly available information, IP Bridge has determined that its patents may be
`
`of particular interest to Micron and its DRAM business; and that IP Bridge would welcome the
`
`opportunity to provide additional information regarding IP Bridge’s patents and its licensing
`
`program on a confidential basis.
`
`44. Micron responded by letter dated February 5, 2020 that they saw nothing in their
`
`initial review that suggested a more detailed review is warranted.
`
`COUNT I: INFRINGEMENT OF U.S. PATENT NO. 7,189,616
`
`45.
`
`IP Bridge incorporates by reference and re-alleges all of the foregoing paragraphs
`
`of this Complaint as if fully set forth herein.
`
`46.
`
`Defendants have directly infringed and continue to infringe, either literally or
`
`under the doctrine of equivalents, at least claim 1 of the ’616 patent by making, using, offer for
`
`
`
`12
`
`Micron Ex. 1001, p. 12
`Micron v. Godo Kaisha IP Bridge 1
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`

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`sale, selling, and importing, without authority or license, the Accused Memory Chips in violation
`
`of 35 U.S.C. § 271(a). The Accused Memory Chips are non-limiting examples that were
`
`identified based on reverse engineering reports currently available, and IP Bridge reserves the
`
`right to identify additional infringing activities, products, and services, including, for example,
`
`on the basis of information obtained during discovery.
`
`47.
`
`Defendants have also infringed and continue to infringe under 35 U.S.C. 271(g)
`
`by importing into the United States or offering to sell, selling, or using within the United States a
`
`product which is made by a process in the United States during the term of the ’616 patent. Each
`
`of the Defendants either practiced the patented process; or owns or controls, or is owned or
`
`controlled by the person who practiced the patented process. As of at least the filing date of this
`
`action, Defendants have knowledge that a patented process was used to make the Accused
`
`Memory Chips.
`
`48.
`
`The Accused Memory Chips meet all the limitations of at least claim 1 of the ’616
`
`patent. Specifically, claim 1 of the ’616 patent recites:
`
`A method for manufacturing a semiconductor memory device comprising:
`
`depositing an interlayer insulating film on a semiconductor substrate provided
`with contact plugs;
`
`patterning a mask pattern on the interlayer insulating film, the mask pattern
`having a layout in which a plurality of hole patterns having the same shape are
`arranged in a stagger manner so that side edges of the adjacent hole patterns are
`only partially opposite to each other;
`
`forming holes for storage nodes in the interlayer insulating film by etching with
`the mask pattern;
`
`forming the storage nodes in the holes so as to be connected electrically to the
`contact plugs;
`
`forming a capacitor insulating film on the storage nodes; and
`
`forming a plate electrode on the capacitor insulating film,
`
`
`
`13
`
`Micron Ex. 1001, p. 13
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
`
`

`

`wherein the length of a portion where the opposing capacitors are overlapped in
`the mask layout is set so that the value of the parasitic capacitance between
`adjacent cell capacitors is not more than 10% of the set cell capacitance value.
`
`49.
`
`The Accused Memory Chips are formed using a method for manufacturing a
`
`semiconductor memory device. For example, Micron manufactures the GDDR5X, which is a
`
`semiconductor memory device. TechInsights Report at 1.
`
`50.
`
`The Accused Memory Chips are formed by depositing an interlayer insulating
`
`film on a semiconductor substrate provided with contact plugs. For example, the GDDR5X has
`
`a substrate. Id. at 16, 89.
`
`
`
`Id. at 89.
`
`51.
`
`The GDDR5X is formed by depositing an interlayer insulating film (see SiN
`
`regions) on a semiconductor substrate provided with contact plugs (see regions labelled “storage
`
`node plug”). Id. at 121.
`
`
`
`14
`
`Micron Ex. 1001, p. 14
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
`
`

`

`
`
`Id.
`
`52.
`
`The Accused Memory Chips are formed by patterning a mask pattern on the
`
`interlayer insulating film, the mask pattern having a layout in which a plurality of hole patterns
`
`having the same shape are arranged in a stagger manner so that side edges of the adjacent hole
`
`patterns are only partially opposite to each other. For example, the GDDR5X is formed by
`
`patterning a mask pattern on the interlayer insulating film (see SiN regions), the mask pattern
`
`having a layout in which a plurality of hole patterns having the same shape are arranged in a
`
`stagger manner so that side edges of the adjacent hole patterns are only partially opposite to each
`
`other. Id. at 78, 121.
`
`
`
`15
`
`Micron Ex. 1001, p. 15
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
`
`

`

`
`
`Id. at 78.
`
`53.
`
`The Accused Memory Chips are formed by forming holes for storage nodes in the
`
`interlayer insulating film by etching with the mask pattern. For example, the GDDR5X is
`
`formed by forming holes for storage nodes in the interlayer insulating film by etching with the
`
`mask pattern. Id. at 78, 84, 121.
`
`54.
`
`The Accused Memory Chips are formed by forming the storage nodes in the holes
`
`so as to be connected electrically to the contact plugs. For example, the GDDR5X is formed by
`
`forming the storage nodes in the holes so as to be connected electrically to the contact plugs. Id.
`
`at 78, 84, 121
`
`55.
`
`The Accused Memory Chips are formed by forming a capacitor insulating film on
`
`the storage nodes. For example, the GDDR5X is formed by forming a capacitor insulating film
`
`on the storage nodes. Id. at 78, 84, 121.
`
`
`
`16
`
`Micron Ex. 1001, p. 16
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
`
`

`

`56.
`
`The Accused Memory Chips are formed by forming a plate electrode on the
`
`capacitor insulating film. For example, the GDDR5X is formed by forming a plate electrode on
`
`the capacitor insulating film. Id. at 78, 84, 121.
`
`57.
`
`In the Accused Memory Chips, the length of a portion where the opposing
`
`capacitors are overlapped in the mask layout is set so that the value of the parasitic capacitance
`
`between adjacent cell capacitors is not more than 10% of the set cell capacitance value. For
`
`example, in the GDDR5X, the length of a portion where the opposing capacitors (see DRAM
`
`cells) are overlapped in the mask layout is set so that the value of the parasitic capacitance
`
`between adjacent cell capacitors is not more than 10% of the set cell capacitance value. Id. at 78,
`
`84, 121.
`
`58.
`
`The foregoing allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the Accused Memory Chips. IP Bridge
`
`reserves the right to modify this description, including, for example, on the basis of information
`
`about the Accused Memory Chips that it obtains during discovery.
`
`59.
`
`IP Bridge has made a reasonable effort to determine the process used by
`
`Defendants to produce the Accused Memory Chips. The TechInsights Report demonstrates a
`
`substantial likelihood that the Accused Memory Chips were made using IP Bridge’s patented
`
`process. Pursuant to 35 U.S.C. § 295, the Accused Memory Chips should be presumed to have
`
`been so made, and the burden of establishing that the product was not made by the process shall
`
`be on Defendants, to the extent they assert that it was not so made.
`
`60.
`
`Defendants’ infringement has damaged and continues to damage IP Bridge in an
`
`amount yet to be determined, of at least a reasonable royalty.
`
`
`
`17
`
`Micron Ex. 1001, p. 17
`Micron v. Godo Kaisha IP Bridge 1
`IPR2020-01008
`
`

`

`61.
`
`This is an exceptional case. IP Bridge is entitled to attorneys’ fees and costs
`
`under 35 U.S.C. § 285 as a result of the infringement of the ’616 patent by Defendants.
`
`COUNT II: INFRINGEMENT OF U.S. PATENT NO. 6,747,320
`
`62.
`
`IP Bridge incorporates by reference and re-alleges all of the foregoing paragraphs
`
`of this Complaint as if fully set forth herein.
`
`63.
`
`Defendants have directly infringed and continue to infringe, either literally or
`
`under the doctrine of equivalents, at least claim 1 of the ’320 patent by making, using, offer for
`
`sale, selling, and importing, without authority or license, the Accused Memory Chips in violation
`
`of 35 U.S.C. § 271(a). The Accused Memory Chips are non-limiting examples that were
`
`identified based on reverse engineering reports currently available, and IP Bridge reserves the
`
`right to identify additional infringing activities, products, and services, including, for example,
`
`on the basis of information obtained during discovery.
`
`64.
`
`The Accused Memory Chips meet all the limitations of at least claim 1 of the ’320
`
`patent. Specifically, claim 1 of the ’320 patent recites:
`
`A semiconductor device comprising a DRAM region and a high-speed CMOS
`logic region that are co-resident with each other,
`
`wherein a pair of gate electrodes of a N-type sense amplifier transistor and a pair
`of gate electrodes of a P-type sense amplifier transistor constituting a CMOS
`sense amplifier of the DRAM are disposed respectively in one active region in
`parallel to each other in the same direction as that of bit line