Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 1 of 71
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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`Ocean Semiconductor LLC,
`
`Plaintiff
`
`v.
`
`Silicon Laboratories Inc. (“SILABS”),
`
`Defendant.
`
`Civil Action No.: 6:20-cv-1214
`
`JURY TRIAL DEMANDED
`
`PATENT CASE
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff Ocean Semiconductor LLC (“Ocean Semiconductor” or “Plaintiff”) files this
`
`Complaint against Silicon Laboratories Inc. (“SILABS” or “Defendant”), seeking damages and
`
`other relief for patent infringement, and alleges with knowledge to its own acts, and on information
`
`and belief as to other matters, as follows:
`
`NATURE OF THE ACTION
`
`1.
`
`This is an action for patent infringement arising under the Patent Laws of the
`
`United States, 35 U.S.C. § 1 et seq.
`
`THE PARTIES
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`2.
`
`Plaintiff Ocean Semiconductor is a limited liability company organized and
`
`existing under the laws of the State of Delaware, and its registered agent for service of process in
`
`Delaware is Rita Carnevale, 717 N. Union Street, Wilmington, DE 19805.
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 2 of 71
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`3.
`
`On information and belief, SILABS is a Delaware corporation with a principal
`
`place of business at 400 W. Cesar Chavez, Austin, TX 78701. On information and belief,
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`Defendant may be served through its registered agent, The Corporation Trust Company, at 1209
`
`N. Orange St., Wilmington, DE 19801.
`
`4.
`
`On information and belief, Defendant SILABS sells, offers to sell, and/or uses
`
`products and services throughout the United States, including in this judicial District, and
`
`introduces infringing products and services into the stream of commerce knowing that they
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`would be sold and/or used in this judicial District and elsewhere in the United States.
`
`5.
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`Plaintiff Ocean Semiconductor is the assignee and owner of the patents at issue in
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`this action: U.S. Patents Nos. 6,660,651, 6,907,305, 6,725,402, 6,968,248, 7,080,330, 6,836,691,
`
`and 8,676,538 (collectively, the “Asserted Patents”). Ocean Semiconductor holds all substantial
`
`rights, title, and interest in the Asserted Patents, including the exclusive right to sue SILABS for
`
`infringement and recover damages, including damages for past infringement.
`
`6.
`
`Plaintiff Ocean Semiconductor seeks monetary damages and prejudgment interest
`
`for Defendant’s past and ongoing direct and indirect infringement of the Asserted Patents.
`
`7.
`
`Defendant SILABS is a semiconductor company that designs, develops, sells,
`
`offers to sell, and imports into the United States semiconductor products in the communications,
`
`internet of things, automotive, computer, and consumer electronics industry.
`
`8.
`
`Defendant SILABS, headquartered in Austin, Texas, contracts with third-party
`
`semiconductor fabricators or foundries (“SILABS Foundry Partners”) that own, operate, or
`
`control semiconductor fabrication plants (“fabs”) within and/or outside of the United States
`
`(“International Facilities”) to produce the Accused Products. One such SILABS Foundry Partner
`
`is Taiwan Semiconductor Manufacturing Company Ltd. (“TSMC”). TSMC has a contractual
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 3 of 71
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`partnership with SILABS to design, develop, or manufacture semiconductor products including
`
`integrated circuits for SILABS. See, e.g. “Silicon Labs Quality and Operations Overview,” at
`
`21, available at https://www.silabs.com/documents/public/miscellaneous/Silicon-Labs-Business-
`
`Introduction.pdf (last visited Oct. 12, 2020); see also “"Process Change Notice #1011021,”
`
`available at https://www.silabs.com/documents/public/pcns/1011021.pdf (last visited Oct. 12,
`
`2020).
`
`9.
`
`On information and belief, Defendant SILABS (directly or through one or more
`
`of its Foundry Partners such as TSMC) has a contractual relationship with Applied Materials,
`
`Inc. (“Applied Materials”) (see Applied Materials’ job posting for “TSMC F15 E3 project,”
`
`available at
`
`http://www.mse.ntu.edu.tw/attachments/article/154/AMT_Summer%20Student%20Program_Job
`
`%20Post_2013.pdf (last accessed October 12, 2020) and PDF Solutions Inc. (“PDF Solutions”)
`
`(e.g., “Taiwan Semiconductor Manufacturing Company adopts PDF Solutions yield
`
`improvement technology,” available at https://www.edn.com/taiwan-semiconductor-
`
`manufacturing-company-adopts-pdf-solutions-yield-improvement-technology/ (last accessed
`
`Oct. 12, 2020); see also “Exensio: Big Data in the Fab,” available at
`
`https://semiwiki.com/eda/4351-exensio-big-data-in-the-fab/ (last accessed Oct. 12, 2020)), and
`
`one or more of the SILABS Foundry Partners (e.g., TSMC) employ Applied Materials’
`
`semiconductor fabrication or manufacturing equipment, platforms, and/or framework, including
`
`Applied Materials’ E3 system, including the E3 factory advanced/automation process control
`
`(“APC”) hardware and/or software (collectively, “E3 system”), PDF Solutions’ Exensio
`
`hardware and/or software (collectively, “Exensio system”), and/or other in-house or third-party
`
`advanced/automation process control system and platform hardware and/or software (e.g., with
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 4 of 71
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`similar technical and functional features) to design, develop, and/or manufacture Defendant
`
`SILABS’s semiconductor devices, including integrated circuits.
`
`10.
`
`Upon information and belief, TSMC employs Applied Materials’ and/or PDF
`
`Solutions’ semiconductor fabrication or manufacturing equipment, platforms, and/or framework
`
`(e.g., Applied Materials’ E3 system and/or PDF Solutions’ Exensio system) at its manufacturing
`
`facilities. Applied Materials has received supplier awards and recognition from TSMC. See,
`
`e.g., “TSMC Recognizes Outstanding Suppliers at Supply Chain Management Forum,” available
`
`at https://pr.tsmc.com/english/news/1873 (last accessed October 12, 2020). On information and
`
`belief, TSMC also employs PDF Solutions’ Exensio system at TSMC’s manufacturing facilities.
`
`11.
`
`On information and belief, Defendant SILABS (directly or through its SILABS
`
`Foundry Partners such as TSMC) employs Applied Materials’ E3 system and/or PDF Solutions’
`
`Exensio system to develop or manufacture one or more systems, products, and/or devices for
`
`importation into the United States for use, sale, and/or offer for sale in this District and
`
`throughout the United States, including, but not limited to, semiconductor products and devices,
`
`such as wireless products (e.g., EFR32XG2X family), internet of things products (e.g.,
`
`EFM8BB10F8G-QFN20, EFM8BB10F2A-QFN20, EFM8BB10F2G-QFN20, EFM8BB10F2I-
`
`QFN20, EFM8BB10F4A-QFN20, EFM8BB10F4G-QFN20, EFM8BB10F4I-QFN20,
`
`EFM8BB10F8A-QFN20, EFM8BB10F8G-QSOP24, EFM8BB10F8G-SOIC16, EFM8BB10F8I-
`
`QFN20, EFM8BB10F8I-QSOP24, EFM8BB10F8I-SOIC16, EFM8BB21F16A-QFN20,
`
`EFM8BB21F16G-QFN20, EFM8BB21F16G-QSOP24, EFM8BB21F16I-QFN20,
`
`EFM8BB21F16I-QSOP24, EFM8BB22F16A-QFN28, EFM8BB22F16G-QFN28,
`
`EFM8BB22F16I-QFN28, EFM8BB31F16A-4QFN24, EFM8BB31F16A-5QFN32,
`
`EFM8BB31F16G-QFN24, EFM8BB31F16G-QFN32, EFM8BB31F16G-QFP32,
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 5 of 71
`
`EFM8BB31F16G-QSOP24, EFM8BB31F16I-4QFN24, EFM8BB31F16I-5QFN32,
`
`EFM8BB31F16I-QFN24, EFM8BB31F16I-QFN32, EFM8BB31F16I-QFP32, EFM8BB31F16I-
`
`QSOP24, EFM8BB31F32A-4QFN24, EFM8BB31F32A-5QFN32, EFM8BB31F32G-QFN24,
`
`EFM8BB31F32G-QFN32, EFM8BB31F32G-QFP32, EFM8BB31F32G-QSOP24,
`
`EFM8BB31F32I-4QFN24, EFM8BB31F32I-5QFN32, EFM8BB31F32I-QFN24,
`
`EFM8BB31F32I-QFN32, EFM8BB31F32I-QFP32, EFM8BB31F32I-QSOP24,
`
`EFM8BB31F64A-4QFN24, EFM8BB31F64A-5QFN32, EFM8BB31F64G-QFN24,
`
`EFM8BB31F64G-QFN32, EFM8BB31F64G-QFP32, EFM8BB31F64G-QSOP24,
`
`EFM8BB31F64I-4QFN24, EFM8BB31F64I-5QFN32, EFM8BB31F64I-QFN24,
`
`EFM8BB31F64I-QFN32, EFM8BB31F64I-QFP32, EFM8BB31F64I-QSOP24), infrastructure
`
`products (e.g., Si5332A-GM1, Si5332A-GM2, Si5332A-GM3, Si5332B-GM1, Si5332B-GM2,
`
`Si5332B-GM3, Si5332C-GM1, Si5332C-GM2, Si5332C-GM3, Si5332D-GM1, Si5332D-GM2,
`
`Si5332D-GM3, Si5332E-GM1, Si5332E-GM2, Si5332E-GM3, Si5332F-GM1, Si5332F-GM2,
`
`Si5332F-GM3, Si5332G-GM1, Si5332G-GM2, Si5332G-GM3, Si5332H-GM1, Si5332H-GM2,
`
`Si5332H-GM3, Si5332A-GM1, Si5332A-GM2, Si5332A-GM3, Si5332B-GM1, Si5332B-GM2,
`
`Si5332B-GM3, Si5332C-GM1, Si5332C-GM2, Si5332C-GM3, Si5332D-GM1, Si5332D-GM2,
`
`Si5332D-GM3, Si5332E-GM1, Si5332E-GM2, Si5332E-GM3, Si5332F-GM1, Si5332F-GM2,
`
`Si5332F-GM3, Si5332G-GM1, Si5332G-GM2, Si5332G-GM3, Si5332H-GM1, Si5332H-GM2,
`
`Si5332H-GM3), broadcast products (e.g., Si2160, Si2162, Si2164, Si2180, Si2181, Si2182,
`
`Si2183), access products (e.g., Si3000, Si3402-GM, Si3404-GM, Si3406-GM, Si34062-GM,
`
`Si3462-GM, Si3471A-IM, microcontrollers (e.g., Tiny Gecko series, EFM8 Busy Bee), buffers
`
`(e.g., Si5330x), oscillators (e.g., Si54x), clock generators (e.g., Si534x), jitter attenuators (e.g.,
`
`Si539x), synchronous ethernet (e.g., Si5383/48/88), isolation products (e.g., Si86xx, Si87xx,
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 6 of 71
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`Si88xx, Si823x, Si827x, Si828x, Si823Hx, Si890x, Si892x, Si82Hx, Si838x, Si834x, and
`
`Si875x), interface products (e.g., ethernet controllers, LC controllers, bridges), timing products
`
`(e.g., buffers, clock generators, oscillators, and network synchronizers), sensors (e.g., humidity,
`
`magnetic, optical, temperature, and biometric), audio & radio products (e.g., automotive tuners,
`
`and radios), power products (e.g., power management ICs, powered drivers, and PSE
`
`controllers), TV & video products (e.g., digital demodulators and TV tuners), modem & DAA
`
`products (e.g., voice modems), voice products (e.g., codec, proSLICs, and DAA), power over
`
`ethernet devices (e.g., power source equipment and powered device ICs)), and similar systems,
`
`products, devices, and integrated circuits (“SILABS APC Products”).
`
`12.
`
`On information and belief, Defendant SILABS (directly or through its SILABS
`
`Foundry Partners such as TSMC) uses Applied Materials’ E3 system and/or PDF Solutions’
`
`Exensio system to design, develop, or manufacture the SILABS APC Products for importation
`
`into the United States for use, sale, and/or offer for sale in this district and throughout the United
`
`States.
`
`13.
`
`On information and belief, Defendant SILABS, directly and/or through one or
`
`more of the SILABS Foundry Partners (e.g., TSMC), employs camline’s semiconductor
`
`fabrication or manufacturing solutions, including camLine’s LineWorks production automation
`
`solution (e.g., LineWorks eCap and LineWorks PULSE modules) (collectively, “LineWorks
`
`system”) and/or other similar proprietary or third-party scheduling and dispatching platform
`
`hardware and/or software (e.g., with similar technical and functional features) to design, develop,
`
`and/or manufacture Defendant SILABS’s semiconductor devices, including integrated circuits.
`
`See, e.g., “Agile and Intelligent Operations,” available at
`
`https://www.tsmc.com/english/dedicatedFoundry/manufacturing/intelligent_operations.htm (last
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 7 of 71
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`accessed Oct. 12, 2020); see also “Manufacturing Excellence,” available at
`
`https://www.tsmc.com/download/ir/annualReports/2012/english/e_5_3.html (last accessed Oct.
`
`12, 2020).
`
`14.
`
`Upon information and belief, TSMC employs camLine’s LineWorks system at
`
`TSMC’s manufacturing facilities. See, e.g., “LineWorks Product,” available at https://www.all-
`
`electronics.de/wp-
`
`content/uploads/migrated/document/97654/infodirectccamlineproductcatalog.pdf (last accessed
`
`Oct. 12, 2020) (“Customers … > TSMC”).
`
`15.
`
`On information and belief, Defendant SILABS (directly or through its SILABS
`
`Foundry Partners such as TSMC) employs camLine’s LineWorks system and/or other in-house
`
`or third-party scheduling and dispatching platform hardware and/or software (e.g., with similar
`
`technical and functional features) to develop or manufacture one or more systems, products,
`
`and/or devices for importation into the United States for use, sale, and/or offer for sale in this
`
`District and throughout the United States, including, but not limited to, semiconductor products
`
`and devices, such as wireless products (e.g., EFR32XG2X family), internet of things products
`
`(e.g., EFM8BB10F8G-QFN20, EFM8BB10F2A-QFN20, EFM8BB10F2G-QFN20,
`
`EFM8BB10F2I-QFN20, EFM8BB10F4A-QFN20, EFM8BB10F4G-QFN20, EFM8BB10F4I-
`
`QFN20, EFM8BB10F8A-QFN20, EFM8BB10F8G-QSOP24, EFM8BB10F8G-SOIC16,
`
`EFM8BB10F8I-QFN20, EFM8BB10F8I-QSOP24, EFM8BB10F8I-SOIC16, EFM8BB21F16A-
`
`QFN20, EFM8BB21F16G-QFN20, EFM8BB21F16G-QSOP24, EFM8BB21F16I-QFN20,
`
`EFM8BB21F16I-QSOP24, EFM8BB22F16A-QFN28, EFM8BB22F16G-QFN28,
`
`EFM8BB22F16I-QFN28, EFM8BB31F16A-4QFN24, EFM8BB31F16A-5QFN32,
`
`EFM8BB31F16G-QFN24, EFM8BB31F16G-QFN32, EFM8BB31F16G-QFP32,
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 8 of 71
`
`EFM8BB31F16G-QSOP24, EFM8BB31F16I-4QFN24, EFM8BB31F16I-5QFN32,
`
`EFM8BB31F16I-QFN24, EFM8BB31F16I-QFN32, EFM8BB31F16I-QFP32, EFM8BB31F16I-
`
`QSOP24, EFM8BB31F32A-4QFN24, EFM8BB31F32A-5QFN32, EFM8BB31F32G-QFN24,
`
`EFM8BB31F32G-QFN32, EFM8BB31F32G-QFP32, EFM8BB31F32G-QSOP24,
`
`EFM8BB31F32I-4QFN24, EFM8BB31F32I-5QFN32, EFM8BB31F32I-QFN24,
`
`EFM8BB31F32I-QFN32, EFM8BB31F32I-QFP32, EFM8BB31F32I-QSOP24,
`
`EFM8BB31F64A-4QFN24, EFM8BB31F64A-5QFN32, EFM8BB31F64G-QFN24,
`
`EFM8BB31F64G-QFN32, EFM8BB31F64G-QFP32, EFM8BB31F64G-QSOP24,
`
`EFM8BB31F64I-4QFN24, EFM8BB31F64I-5QFN32, EFM8BB31F64I-QFN24,
`
`EFM8BB31F64I-QFN32, EFM8BB31F64I-QFP32, EFM8BB31F64I-QSOP24), infrastructure
`
`products (e.g., Si5332A-GM1, Si5332A-GM2, Si5332A-GM3, Si5332B-GM1, Si5332B-GM2,
`
`Si5332B-GM3, Si5332C-GM1, Si5332C-GM2, Si5332C-GM3, Si5332D-GM1, Si5332D-GM2,
`
`Si5332D-GM3, Si5332E-GM1, Si5332E-GM2, Si5332E-GM3, Si5332F-GM1, Si5332F-GM2,
`
`Si5332F-GM3, Si5332G-GM1, Si5332G-GM2, Si5332G-GM3, Si5332H-GM1, Si5332H-GM2,
`
`Si5332H-GM3, Si5332A-GM1, Si5332A-GM2, Si5332A-GM3, Si5332B-GM1, Si5332B-GM2,
`
`Si5332B-GM3, Si5332C-GM1, Si5332C-GM2, Si5332C-GM3, Si5332D-GM1, Si5332D-GM2,
`
`Si5332D-GM3, Si5332E-GM1, Si5332E-GM2, Si5332E-GM3, Si5332F-GM1, Si5332F-GM2,
`
`Si5332F-GM3, Si5332G-GM1, Si5332G-GM2, Si5332G-GM3, Si5332H-GM1, Si5332H-GM2,
`
`Si5332H-GM3), broadcast products (e.g., Si2160, Si2162, Si2164, Si2180, Si2181, Si2182,
`
`Si2183), access products (e.g., Si3000, Si3402-GM, Si3404-GM, Si3406-GM, Si34062-GM,
`
`Si3462-GM, Si3471A-IM, microcontrollers (e.g., Tiny Gecko series, EFM8 Busy Bee), buffers
`
`(e.g., Si5330x), oscillators (e.g., Si54x), clock generators (e.g., Si534x), jitter attenuators (e.g.,
`
`Si539x), synchronous ethernet (e.g., Si5383/48/88), isolation products (e.g,. Si86xx, Si87xx,
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 9 of 71
`
`Si88xx, Si823x, Si827x, Si828x, Si823Hx, Si890x, Si892x, Si82Hx, Si838x, Si834x, and
`
`Si875x), interface products (e.g., ethernet controllers, LC controllers, bridges), timing products
`
`(e.g., buffers, clock generators, oscillators, and network synchronizers), sensors (e.g., humidity,
`
`magnetic, optical, temperature, and biometric), audio & radio products (e.g., automotive tuners,
`
`and radios), power products (e.g., power management ICs, powered drivers, and PSE
`
`controllers), TV & video products (e.g., digital demodulators and TV tuners), modem & DAA
`
`products (e.g., voice modems), voice products (e.g., codec, proSLICs, and DAA), power over
`
`ethernet devices (e.g., power source equipment and powered device ICs)), and similar systems,
`
`products, devices, and integrated circuits (“SILABS Scheduling Products”).
`
`16.
`
`On information and belief, Defendant SILABS (directly or through its SILABS
`
`Foundry Partners such as TSMC) uses camLine’s LineWorks system and/or other in-house or
`
`third-party scheduling and dispatching platform hardware and/or software (e.g., with similar
`
`technical and functional features) to design, develop, or manufacture the SILABS Scheduling
`
`Products for importation into the United States for use, sale, and/or offer for sale in this district
`
`and throughout the United States.
`
`17.
`
`On information and belief, Defendant SILABS (directly and/or through its
`
`SILABS Foundry Partners such as TSMC) has a contractual relationship with ASML Holding
`
`N.V. and/or its subsidiaries (“ASML”) and that one or more of the SILABS Foundry Partners
`
`(e.g., TSMC) employ ASML’s semiconductor fabrication or manufacturing equipment and/or
`
`platforms (e.g., ASML’s TWINSCAN system hardware and software or “TWINSCAN”) to
`
`design, develop, and/or manufacture Defendant SILABS’s semiconductor products and devices,
`
`such as wireless products (e.g., EFR32XG2X family), internet of things products (e.g.,
`
`EFM8BB10F8G-QFN20, EFM8BB10F2A-QFN20, EFM8BB10F2G-QFN20, EFM8BB10F2I-
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 10 of 71
`
`QFN20, EFM8BB10F4A-QFN20, EFM8BB10F4G-QFN20, EFM8BB10F4I-QFN20,
`
`EFM8BB10F8A-QFN20, EFM8BB10F8G-QSOP24, EFM8BB10F8G-SOIC16, EFM8BB10F8I-
`
`QFN20, EFM8BB10F8I-QSOP24, EFM8BB10F8I-SOIC16, EFM8BB21F16A-QFN20,
`
`EFM8BB21F16G-QFN20, EFM8BB21F16G-QSOP24, EFM8BB21F16I-QFN20,
`
`EFM8BB21F16I-QSOP24, EFM8BB22F16A-QFN28, EFM8BB22F16G-QFN28,
`
`EFM8BB22F16I-QFN28, EFM8BB31F16A-4QFN24, EFM8BB31F16A-5QFN32,
`
`EFM8BB31F16G-QFN24, EFM8BB31F16G-QFN32, EFM8BB31F16G-QFP32,
`
`EFM8BB31F16G-QSOP24, EFM8BB31F16I-4QFN24, EFM8BB31F16I-5QFN32,
`
`EFM8BB31F16I-QFN24, EFM8BB31F16I-QFN32, EFM8BB31F16I-QFP32, EFM8BB31F16I-
`
`QSOP24, EFM8BB31F32A-4QFN24, EFM8BB31F32A-5QFN32, EFM8BB31F32G-QFN24,
`
`EFM8BB31F32G-QFN32, EFM8BB31F32G-QFP32, EFM8BB31F32G-QSOP24,
`
`EFM8BB31F32I-4QFN24, EFM8BB31F32I-5QFN32, EFM8BB31F32I-QFN24,
`
`EFM8BB31F32I-QFN32, EFM8BB31F32I-QFP32, EFM8BB31F32I-QSOP24,
`
`EFM8BB31F64A-4QFN24, EFM8BB31F64A-5QFN32, EFM8BB31F64G-QFN24,
`
`EFM8BB31F64G-QFN32, EFM8BB31F64G-QFP32, EFM8BB31F64G-QSOP24,
`
`EFM8BB31F64I-4QFN24, EFM8BB31F64I-5QFN32, EFM8BB31F64I-QFN24,
`
`EFM8BB31F64I-QFN32, EFM8BB31F64I-QFP32, EFM8BB31F64I-QSOP24), infrastructure
`
`products (e.g., Si5332A-GM1, Si5332A-GM2, Si5332A-GM3, Si5332B-GM1, Si5332B-GM2,
`
`Si5332B-GM3, Si5332C-GM1, Si5332C-GM2, Si5332C-GM3, Si5332D-GM1, Si5332D-GM2,
`
`Si5332D-GM3, Si5332E-GM1, Si5332E-GM2, Si5332E-GM3, Si5332F-GM1, Si5332F-GM2,
`
`Si5332F-GM3, Si5332G-GM1, Si5332G-GM2, Si5332G-GM3, Si5332H-GM1, Si5332H-GM2,
`
`Si5332H-GM3, Si5332A-GM1, Si5332A-GM2, Si5332A-GM3, Si5332B-GM1, Si5332B-GM2,
`
`Si5332B-GM3, Si5332C-GM1, Si5332C-GM2, Si5332C-GM3, Si5332D-GM1, Si5332D-GM2,
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 11 of 71
`
`Si5332D-GM3, Si5332E-GM1, Si5332E-GM2, Si5332E-GM3, Si5332F-GM1, Si5332F-GM2,
`
`Si5332F-GM3, Si5332G-GM1, Si5332G-GM2, Si5332G-GM3, Si5332H-GM1, Si5332H-GM2,
`
`Si5332H-GM3), broadcast products (e.g., Si2160, Si2162, Si2164, Si2180, Si2181, Si2182,
`
`Si2183), access products (e.g., Si3000, Si3402-GM, Si3404-GM, Si3406-GM, Si34062-GM,
`
`Si3462-GM, Si3471A-IM, microcontrollers (e.g., Tiny Gecko series, EFM8 Busy Bee), buffers
`
`(e.g., Si5330x), oscillators (e.g., Si54x), clock generators (e.g., Si534x), jitter attenuators (e.g.,
`
`Si539x), synchronous ethernet (e.g., Si5383/48/88), isolation products (e.g,. Si86xx, Si87xx,
`
`Si88xx, Si823x, Si827x, Si828x, Si823Hx, Si890x, Si892x, Si82Hx, Si838x, Si834x, and
`
`Si875x), interface products (e.g., ethernet controllers, LC controllers, bridges), timing products
`
`(e.g., buffers, clock generators, oscillators, and network synchronizers), sensors (e.g., humidity,
`
`magnetic, optical, temperature, and biometric), audio & radio products (e.g., automotive tuners,
`
`and radios), power products (e.g., power management ICs, powered drivers, and PSE
`
`controllers), TV & video products (e.g., digital demodulators and TV tuners), modem & DAA
`
`products (e.g., voice modems), voice products (e.g., codec, proSLICs, and DAA), power over
`
`ethernet devices (e.g., power source equipment and powered device ICs)), and similar systems,
`
`products, devices, and integrated circuits (“SILABS TWINSCAN Products”). See, e.g., “TSMC
`
`Joins ASML’s Customer Co-Investment Program for Innovation,” available at
`
`https://www.asml.com/en/news/press-releases/tsmc-joins-asmls-customer-co-investment-
`
`program-for-innovation-(46903) (last visited Oct. 12, 2020); see also “ASML launches $16
`
`million Taiwanese training complex for TSMC,” available at
`
`https://www.theburnin.com/industry/asml-launches-16m-taiwanese-training-complex-tsmc-
`
`2020-08-20/ (last visited Oct. 12, 2020); see also “ASML shares gain after reports of large
`
`TSMC order,” available at https://seekingalpha.com/news/3636158-asml-shares-gain-after-
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 12 of 71
`
`reports-of-large-tsmc-order (last visited Oct. 12, 2020); see also “ASML apparently beats Nikon
`
`for UMC’s huge 300-mm scanner order,” available at https://www.eetimes.com/asml-
`
`apparently-beats-nikon-for-umcs-huge-300-mm-scanner-order/ (last accessed October 12, 2020);
`
`see also “ASML’s NXE Platform Performance,” available at
`
`http://euvlsymposium.lbl.gov/pdf/2013/pres/RudyPeeters.pdf (last visited Oct. 12, 2020); see
`
`also LinkedIn Profile for Spencer Lin, Operation Manager at ASML, available at
`
`https://www.linkedin.com/in/spencer-lin-a48a0082/ (last visited Oct. 12, 2020); LinkedIn Profile
`
`for Leo Li, Product Engineer at ASML, available at https://www.linkedin.com/in/leo-li-
`
`74222754/ (last visited Oct. 12, 2020); LinkedIn Profile for Tsung Ming C., Applicant Engineer
`
`at ASML, available at https://www.linkedin.com/in/tsung-ming-c-49b4b77/ (last visited Oct. 12,
`
`2020); LinkedIn Profile for Vince Liu, Product Manager at ASML, available at
`
`https://www.linkedin.com/in/vince-liu-4820b149/ (last visited Oct. 12, 2020); and LinkedIn
`
`Profile for Henry Yeh, Applicant Engineer at ASML, available at
`
`https://www.linkedin.com/in/heavyyeh/ (last visited Oct. 12, 2020).
`
`18.
`
`On information and belief, Defendant SILABS (directly or through its SILABS
`
`Foundry Partners) uses ASML’s TWINSCAN platform and/or its software to design, develop, or
`
`manufacture the SILABS TWINSCAN Products for importation into the United States for use,
`
`sale, and/or offer for sale in this district and throughout the United States.
`
`19.
`
`On information and belief, Defendant SILABS (directly and/or through its
`
`SILABS Foundry Partners such as TSMC) has a contractual relationship with ASML and/or its
`
`subsidiaries and that one or more of the SILABS Foundry Partners (e.g., TSMC) employ
`
`ASML’s semiconductor fabrication or manufacturing equipment and/or platforms (e.g., ASML’s
`
`YieldStar metrology and inspection system hardware and software or “YieldStar”) to design,
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 13 of 71
`
`develop, and/or manufacture Defendant SILABS’s semiconductor products and devices, such as
`
`wireless products (e.g., EFR32XG2X family), internet of things products (e.g., EFM8BB10F8G-
`
`QFN20, EFM8BB10F2A-QFN20, EFM8BB10F2G-QFN20, EFM8BB10F2I-QFN20,
`
`EFM8BB10F4A-QFN20, EFM8BB10F4G-QFN20, EFM8BB10F4I-QFN20, EFM8BB10F8A-
`
`QFN20, EFM8BB10F8G-QSOP24, EFM8BB10F8G-SOIC16, EFM8BB10F8I-QFN20,
`
`EFM8BB10F8I-QSOP24, EFM8BB10F8I-SOIC16, EFM8BB21F16A-QFN20,
`
`EFM8BB21F16G-QFN20, EFM8BB21F16G-QSOP24, EFM8BB21F16I-QFN20,
`
`EFM8BB21F16I-QSOP24, EFM8BB22F16A-QFN28, EFM8BB22F16G-QFN28,
`
`EFM8BB22F16I-QFN28, EFM8BB31F16A-4QFN24, EFM8BB31F16A-5QFN32,
`
`EFM8BB31F16G-QFN24, EFM8BB31F16G-QFN32, EFM8BB31F16G-QFP32,
`
`EFM8BB31F16G-QSOP24, EFM8BB31F16I-4QFN24, EFM8BB31F16I-5QFN32,
`
`EFM8BB31F16I-QFN24, EFM8BB31F16I-QFN32, EFM8BB31F16I-QFP32, EFM8BB31F16I-
`
`QSOP24, EFM8BB31F32A-4QFN24, EFM8BB31F32A-5QFN32, EFM8BB31F32G-QFN24,
`
`EFM8BB31F32G-QFN32, EFM8BB31F32G-QFP32, EFM8BB31F32G-QSOP24,
`
`EFM8BB31F32I-4QFN24, EFM8BB31F32I-5QFN32, EFM8BB31F32I-QFN24,
`
`EFM8BB31F32I-QFN32, EFM8BB31F32I-QFP32, EFM8BB31F32I-QSOP24,
`
`EFM8BB31F64A-4QFN24, EFM8BB31F64A-5QFN32, EFM8BB31F64G-QFN24,
`
`EFM8BB31F64G-QFN32, EFM8BB31F64G-QFP32, EFM8BB31F64G-QSOP24,
`
`EFM8BB31F64I-4QFN24, EFM8BB31F64I-5QFN32, EFM8BB31F64I-QFN24,
`
`EFM8BB31F64I-QFN32, EFM8BB31F64I-QFP32, EFM8BB31F64I-QSOP24), infrastructure
`
`products (e.g., Si5332A-GM1, Si5332A-GM2, Si5332A-GM3, Si5332B-GM1, Si5332B-GM2,
`
`Si5332B-GM3, Si5332C-GM1, Si5332C-GM2, Si5332C-GM3, Si5332D-GM1, Si5332D-GM2,
`
`Si5332D-GM3, Si5332E-GM1, Si5332E-GM2, Si5332E-GM3, Si5332F-GM1, Si5332F-GM2,
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 14 of 71
`
`Si5332F-GM3, Si5332G-GM1, Si5332G-GM2, Si5332G-GM3, Si5332H-GM1, Si5332H-GM2,
`
`Si5332H-GM3, Si5332A-GM1, Si5332A-GM2, Si5332A-GM3, Si5332B-GM1, Si5332B-GM2,
`
`Si5332B-GM3, Si5332C-GM1, Si5332C-GM2, Si5332C-GM3, Si5332D-GM1, Si5332D-GM2,
`
`Si5332D-GM3, Si5332E-GM1, Si5332E-GM2, Si5332E-GM3, Si5332F-GM1, Si5332F-GM2,
`
`Si5332F-GM3, Si5332G-GM1, Si5332G-GM2, Si5332G-GM3, Si5332H-GM1, Si5332H-GM2,
`
`Si5332H-GM3), broadcast products (e.g., Si2160, Si2162, Si2164, Si2180, Si2181, Si2182,
`
`Si2183), access products (e.g., Si3000, Si3402-GM, Si3404-GM, Si3406-GM, Si34062-GM,
`
`Si3462-GM, Si3471A-IM, microcontrollers (e.g., Tiny Gecko series, EFM8 Busy Bee), buffers
`
`(e.g., Si5330x), oscillators (e.g., Si54x), clock generators (e.g., Si534x), jitter attenuators (e.g.,
`
`Si539x), synchronous ethernet (e.g., Si5383/48/88), isolation products (e.g,. Si86xx, Si87xx,
`
`Si88xx, Si823x, Si827x, Si828x, Si823Hx, Si890x, Si892x, Si82Hx, Si838x, Si834x, and
`
`Si875x), interface products (e.g., ethernet controllers, LC controllers, bridges), timing products
`
`(e.g., buffers, clock generators, oscillators, and network synchronizers), sensors (e.g., humidity,
`
`magnetic, optical, temperature, and biometric), audio & radio products (e.g., automotive tuners,
`
`and radios), power products (e.g., power management ICs, powered drivers, and PSE
`
`controllers), TV & video products (e.g., digital demodulators and TV tuners), modem & DAA
`
`products (e.g., voice modems), voice products (e.g., codec, proSLICs, and DAA), power over
`
`ethernet devices (e.g., power source equipment and powered device ICs)), and similar systems,
`
`products, devices, and integrated circuits (“SILABS YieldStar Products”). See, e.g., “TSMC
`
`Joins ASML’s Customer Co-Investment Program for Innovation,” available at
`
`https://www.asml.com/en/news/press-releases/tsmc-joins-asmls-customer-co-investment-
`
`program-for-innovation-(46903) (last visited Oct. 12, 2020); see also “ASML launches $16
`
`million Taiwanese training complex for TSMC,” available at
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 15 of 71
`
`https://www.theburnin.com/industry/asml-launches-16m-taiwanese-training-complex-tsmc-
`
`2020-08-20/ (last visited Oct. 12, 2020); see also “ASML shares gain after reports of large
`
`TSMC order,” available at https://seekingalpha.com/news/3636158-asml-shares-gain-after-
`
`reports-of-large-tsmc-order (last visited Oct. 12, 2020); see also “ASML apparently beats Nikon
`
`for UMC’s huge 300-mm scanner order,” available at https://www.eetimes.com/asml-
`
`apparently-beats-nikon-for-umcs-huge-300-mm-scanner-order/ (last accessed October 12, 2020);
`
`see also “ASML’s NXE Platform Performance,” available at
`
`http://euvlsymposium.lbl.gov/pdf/2013/pres/RudyPeeters.pdf (last visited Oct. 12, 2020); see
`
`also LinkedIn Profile for Spencer Lin, Operation Manager at ASML, available at
`
`https://www.linkedin.com/in/spencer-lin-a48a0082/ (last visited Oct. 12, 2020); LinkedIn Profile
`
`for Leo Li, Product Engineer at ASML, available at https://www.linkedin.com/in/leo-li-
`
`74222754/ (last visited Oct. 12, 2020); LinkedIn Profile for Tsung Ming C., Applicant Engineer
`
`at ASML, available at https://www.linkedin.com/in/tsung-ming-c-49b4b77/ (last visited Oct. 12,
`
`2020); LinkedIn Profile for Vince Liu, Product Manager at ASML, available at
`
`https://www.linkedin.com/in/vince-liu-4820b149/ (last visited Oct. 12, 2020); and LinkedIn
`
`Profile for Henry Yeh, Applicant Engineer at ASML, available at
`
`https://www.linkedin.com/in/heavyyeh/ (last visited Oct. 12,
`
`2020).https://www.theburnin.com/industry/asml-launches-16m-taiwanese-training-complex-
`
`tsmc-2020-08-20/ (last visited Oct. 12, 2020).
`
`20.
`
`On information and belief, Defendant SILABS (directly or through its SILABS
`
`Foundry Partners) uses ASML’s YieldStar system to design, develop, or manufacture the
`
`SILABS YieldStar Products for importation into the United States for use, sale, and/or offer for
`
`sale in this district and throughout the United States.
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 16 of 71
`
`21.
`
` Defendant SILABS, one of leading wireless SoC and silicon solution providers,
`
`works with third parties to design and/or develop third party products, such as mobile devices,
`
`tablet products, internet of things devices, automotive devices, networking and broadband
`
`devices, and home devices that include one or more SILABS APC Products, SILABS
`
`Scheduling Products, SILABS TWINSCAN Products, and/or SILABS YieldStar Products
`
`(“Third Party Products”). SILABS assists third parties, directly or through others, to import the
`
`Third Party Products into the United States and offer to sell, and sell, such Third Party Products
`
`in the United States.
`
`JURISDICTION AND VENUE
`
`22.
`
`This is an action for patent infringement arising under the patent laws of the
`
`United States, 35 U.S.C. § 1, et seq.
`
`23.
`
`24.
`
`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
`
`SILABS is subject to this Court’s general personal jurisdiction at least because
`
`SILABS is a resident of Texas as defined by Texas law. On information and belief, SILABS is
`
`headquartered in Austin, Texas.
`
`25.
`
`SILABS is additionally subject to this Court’s general and specific personal
`
`jurisdiction because SILABS has sufficient minimum contacts within the State of Texas and this
`
`District, pursuant to due process and/or the Texas Long Arm Statute, Tex. Civ. Prac. & Rem.
`
`Code § 17.042. On information and belief, SILABS contracted with one or more Texas residents
`
`in this District and one or both parties performed the contract at least in part in the State of Texas
`
`and this District; SILABS committed the tort of patent infringement in State of Texas and this
`
`District; SILABS purposefully availed itself of the privileges of conducting business in the State
`
`of Texas and in this District; SILABS regularly conducts and solicits business within the State of
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2011
`
`

`

`Case 6:20-cv-01214-ADA Document 1 Filed 12/31/20 Page 17 of 71
`
`Texas and within this District; SILABS recruits residents of the State of Texas and this District
`
`for employment inside or outside the State of Texas; Plaintiff’s causes of action arise directly
`
`from SILABS’s business contacts and other activities in the State of Texas and this District; and
`
`SILABS designs, develops, manufactures, distributes, makes available, imports, sells and offers
`
`to sell products and services throughout the United States, including in this judicial District, and
`
`introduces infringing products and services that into the stream of commerce knowing that they
`
`would be used and sold in this judicial district and elsewhere in the United States.
`
`26.
`
`Venue is proper in this judicial district under 28 U.S.C. § 1391 and 28 U.S.C. §
`
`1400(b).
`
`27.
`
`On information and belief, SILABS has a regular and established place of
`
`business in this District, including at least at 400 W Cesar Chavez St, Austin, TX 78701.
`
`28.
`
`Additionally, SILABS—directly or through intermediaries (including distributors,
`
`retailers, and others), subsidiaries, alter egos, and/or agents—ships, distributes, offers for sale,
`
`and/or sells their products in the United States and this District. SILABS has purposefully and
`
`voluntarily placed one or more of its products into the stream of commerce that infringe the
`
`Asserted Patents with the awareness and/or