`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`Ocean Semiconductor LLC,
`
`Plaintiff
`
`v.
`
`Renesas Electronics Corporation and Renesas
`Electronics America, Inc. (“Renesas”)
`
`Defendant.
`
`Civil Action No.: 6:20-cv-1213
`
`JURY TRIAL DEMANDED
`
`PATENT CASE
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Ocean Semiconductor LLC (“Ocean Semiconductor” or “Plaintiff”) files this
`
`Complaint against Renesas Electronics Corporation (“Renesas Electronics”) and Renesas
`
`Electronics America, Inc. (“Renesas America”) (collectively “Renesas” or “Defendants”), 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
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
`
`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 2 of 70
`
`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.
`
`3.
`
`On information and belief, Renesas Electronics is a corporation organized under
`
`the laws of Japan, with its principal place of business at Toyosu Foresia, 3-2-24 Toyosu, Koto-
`
`ku, Tokyo 135-0061, Japan, and at 900 S. Capital of Texas Hwy, Las Cimas IV, Austin, TX
`
`78746.
`
`4.
`
`On information and belief, Renesas America is a Delaware corporation with a
`
`principal place of business at 1001 Murphy Ranch Road, Milpitas, CA 95035. On information
`
`and belief, Renesas America may be served through its registered agent, Corporation Service
`
`Company, 251 Little Falls Drive, Wilmington, DE 19808.
`
`5.
`
`On information and belief, Renesas 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 would be sold
`
`and/or used in this judicial District and elsewhere in the United States.
`
`6.
`
`Plaintiff Ocean Semiconductor is the assignee and owner of the patents at issue in
`
`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 Renesas for
`
`infringement and recover damages, including damages for past infringement.
`
`7.
`
`Plaintiff Ocean Semiconductor seeks monetary damages and prejudgment interest
`
`for Defendant’s past and ongoing direct and indirect infringement of the Asserted Patents.
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
`
`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 3 of 70
`
`8.
`
`Defendants are semiconductor companies that design, develop, sell, offer to sell,
`
`and import into the United States semiconductor products in the communications, internet of
`
`things, automotive, computer, and consumer electronics industry (“Accused Products”).
`
`9.
`
`Renesas, which has its own regular and established place of business in the United
`
`States (including a facility in Austin, Texas), produces or contracts with third-party
`
`semiconductor fabricators or foundries (“Renesas 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 Renesas Foundry Partner
`
`is Taiwan Semiconductor Manufacturing Company Ltd. (“TSMC”). TSMC has a contractual
`
`partnership with Renesas to design, develop, or manufacture semiconductor products including
`
`integrated circuits for Renesas. See, e.g., “Renesas Electronics and TSMC Announce 28nm
`
`MCU Collaboration for Next-Generation Green and Autonomous Vehicles,” available at
`
`https://www.renesas.com/cn/en/about/press-center/news/2016/news20160901.html (last accessed
`
`October 27, 2020); see also “TSMC to make automotive chips for Renesas,” available at
`
`https://asia.nikkei.com/Asia300/TSMC-to-make-automotive-chips-for-Renesas (last accessed
`
`October 27, 2020).
`
`10.
`
`On information and belief, Renesas (directly or through one or more of its
`
`Foundry Partners such as TSMC) also has a contractual relationship with Applied Materials, Inc.
`
`(“Applied Materials”) (see e.g., 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
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
`
`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 4 of 70
`
`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); see
`
`also Renesas’ job posting hiring “Product Engineer-Intern” with “Exensio” knowledge, available
`
`at https://jobs.renesas.com/job/San-Jose-Product-Engineer-Intern-CA-95101/613809601/ (Oct.
`
`12, 2020)), and one or more of the Renesas 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
`
`similar technical and functional features) to design, develop, and/or manufacture Defendant
`
`Renesas’s semiconductor devices, including integrated circuits.
`
`11.
`
`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.
`
`12.
`
`On information and belief, Renesas (directly or through its Renesas Foundry
`
`Partners such as TSMC) employs Applied Materials’ E3 system and/or PDF Solutions’ Exensio
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
`
`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 5 of 70
`
`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, microcontrollers and microprocessors (e.g., RL78 Family of
`
`8/16-bit Ultra-Low Energy MCUs, RX Family of 32-bit High Power Efficiency MCUs, RH850
`
`Family, RZ Family of 64-Bit & 32-Bit Arm-Based High-End MPUs, V850 Family, 78K Family,
`
`R8C Family, M16C Family (R32C / M32C / M16C), M32R Family, H8/S/SX Family, 720
`
`Family, 740 Family, SuperH RISC engine Family, H8 Super Low Power, PLC MCU, Renesas
`
`RA Family of 32-bit MCUs with Arm Cortex-M Core, RE Family, QzROM (740/720 Family),
`
`M16C (M32C/M16C) Family, R8C Family, 7700 Family, and SuperH RISC engine Family and
`
`MCUs with Arm Cortex-M Core Implemented on Silicon on Thin Buried Oxide (SOTB)),
`
`amplifiers and buffers (e.g., CA3XXX, CA5XXX, EL2XXX, EL4XXX, EL5XXX, EL8XXX,
`
`HA-2XXX, HA-5XXX, HFA11XX, ICL7XXX, ISL28XXX, ISL55XXX, ISL59XXX,
`
`READ23XXXSP, and UPCXXXXXX), analog products (e.g., switches and multiplexers), clocks
`
`and timing products (e.g., application-specific clocks, clock distribution, clock generation, and
`
`crystal oscillators), interface & connectivity products (e.g., wireless modules, switches and hubs,
`
`and wireless modules), audio and video products (e.g., ISL54XXX), automotive products (e.g.,
`
`Automotive System-on-Chip (SOC), Ambient Light Sensors, Analog ICs, Car Audio ICs,
`
`Battery Management Systems, CAN Transceivers, Discrete/Power MOFETs for Automotive,
`
`Display ICs, Intelligent Power Devices, Interface ICs, LSI for Automotive, Microcontrollers
`
`(RH850), Microcontrollers (RL78/F1x), Power Management (e.g., Power Management ICs for
`
`RH850, Power Supply ICs for R-Car, Switches & Multiplexers, Video ICs, Discrete Power
`
`Devices, regulators, MOSFETs and Motor Drivers, PMICs, and wireless power devices), ICs for
`
`Communications and Mobile Devices (e.g., SH-MobileR, SH-MobileR2, EMMA Mobile, SH-
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
`
`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 6 of 70
`
`Mobile MT1, and R-Mobile A1), sensor products (e.g., flow sensors, gas sensors, humidity
`
`sensors, light & proximity sensors, position sensors, sensor signal conditioners, and optical
`
`sensors such as ISL76671), data converters (e.g., HI-565A, HI-565A/883, and HI5XXX), ICs for
`
`Industrial Automation (R-IN) (e.g. R-IN32M3, R-IN32M4-CL2, TPS-1, EC-1, R-IN32M4-CL3,
`
`and R-IN32M3), ICs for Motor Driver/Actuator Driver, Interface devices (e.g., Bus Buffers, RS-
`
`485, RS-422, RS-232, Signal Integrity ICs, Dual Protocol RS-485, RS-232 Transceivers, and
`
`Industrial Network Transceivers), Legacy MCUs (e.g., 80C/82C Microprocessors &
`
`Peripherals), memory (e.g., ultra-fast Quad Data Rate SRAMs, SRAMs, EEPROM & PROM,
`
`MRAMS, FIFO products, interface products, and standard logic), Optoelectronics, power
`
`management devices (e.g., RAJ240XXXDNP), RF products (e.g., modulators, demodulators,
`
`transistor arrays, beamformers, mixers, switches, attenuators, VGAs, synthesizers and PLLs),
`
`Renesas USB Power Delivery Family (e.g., Renesas USB Power Delivery Family Features and
`
`U30 Group), Secure MCUs (e.g., AE-5 Series and RS-4 Series), Smart Analog devices (e.g.,
`
`Smart Analog IC101, IC300, IC301, IC500, IC501, and IC502), and space and harsh
`
`environment devices (e.g., µPD720115, µPD720201, µPD720202, µPD720210, µPD720211,
`
`M66291, R8A66593, and R8A66597), products manufactured at 28nm and 40nm technology
`
`node by TSMC for Renesas such as eFlash and MCUs, microprocessors, sensors, radars, power
`
`efficiency systems, electronic control units, and automotive products, and similar systems,
`
`products, devices, and integrated circuits (“Renesas APC Products”).
`
`13.
`
`On information and belief, Renesas (directly or through its Renesas Foundry
`
`Partners such as TSMC) uses Applied Materials’ E3 system and/or PDF Solutions’ Exensio
`
`system to design, develop, or manufacture the Renesas APC 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 2012
`
`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 7 of 70
`
`14.
`
`On information and belief, Renesas (directly and/or through its Renesas Foundry
`
`Partners) has a contractual relationship with ASML Holding N.V. and/or its subsidiaries
`
`(“ASML”) (see, e.g., 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)), and that Renesas, and/or
`
`one or more of the Renesas Foundry Partners (e.g., TSMC), employs 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
`
`Renesas’s semiconductor products and devices, such as microcontrollers and microprocessors
`
`(e.g., RL78 Family of 8/16-bit Ultra-Low Energy MCUs, RX Family of 32-bit High Power
`
`Efficiency MCUs, RH850 Family, RZ Family of 64-Bit & 32-Bit Arm-Based High-End MPUs,
`
`V850 Family, 78K Family, R8C Family, M16C Family (R32C / M32C / M16C), M32R Family,
`
`H8/S/SX Family, 720 Family, 740 Family, SuperH RISC engine Family, H8 Super Low Power,
`
`PLC MCU, Renesas RA Family of 32-bit MCUs with Arm Cortex-M Core, RE Family, QzROM
`
`(740/720 Family), M16C (M32C/M16C) Family, R8C Family, 7700 Family, and SuperH RISC
`
`engine Family and MCUs with Arm Cortex-M Core Implemented on Silicon on Thin Buried
`
`Oxide (SOTB)), amplifiers and buffers (e.g., CA3XXX, CA5XXX, EL2XXX, EL4XXX,
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
`
`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 8 of 70
`
`EL5XXX, EL8XXX, HA-2XXX, HA-5XXX, HFA11XX, ICL7XXX, ISL28XXX, ISL55XXX,
`
`ISL59XXX, READ23XXXSP, and UPCXXXXXX), analog products (e.g., switches and
`
`multiplexers), clocks and timing products (e.g., application-specific clocks, clock distribution,
`
`clock generation, and crystal oscillators), interface & connectivity products (e.g., wireless
`
`modules, switches and hubs, and wireless modules), audio and video products (e.g., ISL54XXX),
`
`automotive products (e.g., Automotive System-on-Chip (SOC), Ambient Light Sensors, Analog
`
`ICs, Car Audio ICs, Battery Management Systems, CAN Transceivers, Discrete/Power MOFETs
`
`for Automotive, Display ICs, Intelligent Power Devices, Interface ICs, LSI for Automotive,
`
`Microcontrollers (RH850), Microcontrollers (RL78/F1x), Power Management (e.g., Power
`
`Management ICs for RH850, Power Supply ICs for R-Car, Switches & Multiplexers, Video ICs,
`
`Discrete Power Devices, regulators, MOSFETs and Motor Drivers, PMICs, and wireless power
`
`devices), ICs for Communications and Mobile Devices (e.g., SH-MobileR, SH-MobileR2,
`
`EMMA Mobile, SH-Mobile MT1, and R-Mobile A1), sensor products (e.g., flow sensors, gas
`
`sensors, humidity sensors, light & proximity sensors, position sensors, sensor signal
`
`conditioners, and optical sensors such as ISL76671), data converters (e.g., HI-565A, HI-
`
`565A/883, and HI5XXX), ICs for Industrial Automation (R-IN) (e.g. R-IN32M3, R-IN32M4-
`
`CL2, TPS-1, EC-1, R-IN32M4-CL3, and R-IN32M3), ICs for Motor Driver/Actuator Driver,
`
`Interface devices (e.g., Bus Buffers, RS-485, RS-422, RS-232, Signal Integrity ICs, Dual
`
`Protocol RS-485, RS-232 Transceivers, and Industrial Network Transceivers), Legacy MCUs
`
`(e.g., 80C/82C Microprocessors & Peripherals), memory (e.g., ultra-fast Quad Data Rate
`
`SRAMs, SRAMs, EEPROM & PROM, MRAMS, FIFO products, interface products, and
`
`standard logic), Optoelectronics, power management devices (e.g., RAJ240XXXDNP), RF
`
`products (e.g., modulators, demodulators, transistor arrays, beamformers, mixers, switches,
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
`
`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 9 of 70
`
`attenuators, VGAs, synthesizers and PLLs), Renesas USB Power Delivery Family (e.g., Renesas
`
`USB Power Delivery Family Features and U30 Group), Secure MCUs (e.g., AE-5 Series and
`
`RS-4 Series), Smart Analog devices (e.g., Smart Analog IC101, IC300, IC301, IC500, IC501,
`
`and IC502), and space and harsh environment devices (e.g., µPD720115, µPD720201,
`
`µPD720202, µPD720210, µPD720211, M66291, R8A66593, and R8A66597), products
`
`manufactured at 28nm and 40nm technology node by TSMC for Renesas such as eFlash and
`
`MCUs, microprocessors, sensors, radars, power efficiency systems, electronic control units, and
`
`automotive products, and similar systems, products, devices, and integrated circuits (“Renesas
`
`TWINSCAN Products”). See, e.g., “BRIEF-Taiwan’s UMC orders equipment from ASML for
`
`T$657 mln,” available at https://www.reuters.com/article/umc-corp-asml-holding-brief/brief-
`
`taiwans-umc-orders-equipment-from-asml-for-t657-mln-idUSS7N0P700I20140728 (last
`
`accessed October 12, 2020); see also “UMC buys equipment from ASML,” available at
`
`https://www.digitimes.com/news/a20160621PM200.html (last accessed October 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 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’s NXE Platform Performance,”
`
`available at http://euvlsymposium.lbl.gov/pdf/2013/pres/RudyPeeters.pdf (last visited Oct. 12,
`
`2020).
`
`15.
`
`On information and belief, Renesas (directly or through its Renesas Foundry
`
`Partners such as TSMC) uses ASML’s TWINSCAN platform and/or its software to design,
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
`
`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 10 of 70
`
`develop, or manufacture the Renesas TWINSCAN Products for importation into the United
`
`States for use, sale, and/or offer for sale in this district and throughout the United States.
`
`16.
`
`On information and belief, Renesas (directly and/or through its Renesas Foundry
`
`Partners such as TSMC) has a contractual relationship with ASML and/or its subsidiaries (see,
`
`e.g., 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)), and that Renesas, and/or
`
`one or more of the Renesas Foundry Partners (e.g., TSMC), employs ASML’s metrology and
`
`inspection systems (e.g., ASML’s YieldStar metrology and inspection system hardware and
`
`software or “YieldStar system”) to design, develop, and/or manufacture Defendant Renesas’s
`
`semiconductor products and devices, such as microcontrollers and microprocessors (e.g., RL78
`
`Family of 8/16-bit Ultra-Low Energy MCUs, RX Family of 32-bit High Power Efficiency
`
`MCUs, RH850 Family, RZ Family of 64-Bit & 32-Bit Arm-Based High-End MPUs, V850
`
`Family, 78K Family, R8C Family, M16C Family (R32C / M32C / M16C), M32R Family,
`
`H8/S/SX Family, 720 Family, 740 Family, SuperH RISC engine Family, H8 Super Low Power,
`
`PLC MCU, Renesas RA Family of 32-bit MCUs with Arm Cortex-M Core, RE Family, QzROM
`
`(740/720 Family), M16C (M32C/M16C) Family, R8C Family, 7700 Family, and SuperH RISC
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
`
`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 11 of 70
`
`engine Family and MCUs with Arm Cortex-M Core Implemented on Silicon on Thin Buried
`
`Oxide (SOTB)), amplifiers and buffers (e.g., CA3XXX, CA5XXX, EL2XXX, EL4XXX,
`
`EL5XXX, EL8XXX, HA-2XXX, HA-5XXX, HFA11XX, ICL7XXX, ISL28XXX, ISL55XXX,
`
`ISL59XXX, READ23XXXSP, and UPCXXXXXX), analog products (e.g., switches and
`
`multiplexers), clocks and timing products (e.g., application-specific clocks, clock distribution,
`
`clock generation, and crystal oscillators), interface & connectivity products (e.g., wireless
`
`modules, switches and hubs, and wireless modules), audio and video products (e.g., ISL54XXX),
`
`automotive products (e.g., Automotive System-on-Chip (SOC), Ambient Light Sensors, Analog
`
`ICs, Car Audio ICs, Battery Management Systems, CAN Transceivers, Discrete/Power MOFETs
`
`for Automotive, Display ICs, Intelligent Power Devices, Interface ICs, LSI for Automotive,
`
`Microcontrollers (RH850), Microcontrollers (RL78/F1x), Power Management (e.g., Power
`
`Management ICs for RH850, Power Supply ICs for R-Car, Switches & Multiplexers, Video ICs,
`
`Discrete Power Devices, regulators, MOSFETs and Motor Drivers, PMICs, and wireless power
`
`devices), ICs for Communications and Mobile Devices (e.g., SH-MobileR, SH-MobileR2,
`
`EMMA Mobile, SH-Mobile MT1, and R-Mobile A1), sensor products (e.g., flow sensors, gas
`
`sensors, humidity sensors, light & proximity sensors, position sensors, sensor signal
`
`conditioners, and optical sensors such as ISL76671), data converters (e.g., HI-565A, HI-
`
`565A/883, and HI5XXX), ICs for Industrial Automation (R-IN) (e.g. R-IN32M3, R-IN32M4-
`
`CL2, TPS-1, EC-1, R-IN32M4-CL3, and R-IN32M3), ICs for Motor Driver/Actuator Driver,
`
`Interface devices (e.g., Bus Buffers, RS-485, RS-422, RS-232, Signal Integrity ICs, Dual
`
`Protocol RS-485, RS-232 Transceivers, and Industrial Network Transceivers), Legacy MCUs
`
`(e.g., 80C/82C Microprocessors & Peripherals), memory (e.g., ultra-fast Quad Data Rate
`
`SRAMs, SRAMs, EEPROM & PROM, MRAMS, FIFO products, interface products, and
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
`
`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 12 of 70
`
`standard logic), Optoelectronics, power management devices (e.g., RAJ240XXXDNP), RF
`
`products (e.g., modulators, demodulators, transistor arrays, beamformers, mixers, switches,
`
`attenuators, VGAs, synthesizers and PLLs), Renesas USB Power Delivery Family (e.g., Renesas
`
`USB Power Delivery Family Features and U30 Group), Secure MCUs (e.g., AE-5 Series and
`
`RS-4 Series), Smart Analog devices (e.g., Smart Analog IC101, IC300, IC301, IC500, IC501,
`
`and IC502), and space and harsh environment devices (e.g., µPD720115, µPD720201,
`
`µPD720202, µPD720210, µPD720211, M66291, R8A66593, and R8A66597), products
`
`manufactured at 28nm and 40nm technology node by TSMC for Renesas such as eFlash and
`
`MCUs, microprocessors, sensors, radars, power efficiency systems, electronic control units, and
`
`automotive products, and similar systems, products, devices, and integrated circuits (“Renesas
`
`YieldStar Products”). See, e.g., “BRIEF-Taiwan’s UMC orders equipment from ASML for
`
`T$657 mln,” available at https://www.reuters.com/article/umc-corp-asml-holding-brief/brief-
`
`taiwans-umc-orders-equipment-from-asml-for-t657-mln-idUSS7N0P700I20140728 (last
`
`accessed October 12, 2020); see also “UMC buys equipment from ASML,” available at
`
`https://www.digitimes.com/news/a20160621PM200.html (last accessed October 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 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’s NXE Platform Performance,”
`
`available at http://euvlsymposium.lbl.gov/pdf/2013/pres/RudyPeeters.pdf (last visited Oct. 12,
`
`2020).
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`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
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`
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 13 of 70
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`17.
`
`On information and belief, Renesas (directly or through its Renesas Foundry
`
`Partners such as TSMC) uses ASML’s YieldStar platform and/or its software to design, develop,
`
`or manufacture the Renesas YieldStar Products for importation into the United States for use,
`
`sale, and/or offer for sale in this district and throughout the United States.
`
`18.
`
`On information and belief, Defendant Renesas, directly and/or through one or
`
`more of the Renesas 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 in-house 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 Renesas’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
`
`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).
`
`19.
`
`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”).
`
`20.
`
`On information and belief, Defendant Renesas (directly or through its Renesas
`
`Foundry Partners such as TSMC) employs camLine’s LineWorks system and/or other in-house
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
`
`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 14 of 70
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`or third-party scheduling and dispatching platform hardware and/or software (e.g., with similar
`
`technical and functional features) at TSMC’s manufacturing facilities. On information and
`
`belief, Defendant Renesas employs similar in-house or proprietary scheduling and dispatching
`
`platform (with technical and functional features similar to camLine’s LineWorks system) at its
`
`own manufacturing facilities.
`
`21.
`
`On information and belief, Defendant Renesas (directly or through its Renesas
`
`Foundry Partners such as TSMC) employs camLine’s LineWorks system and/or other similar
`
`Renesas proprietary or third-party scheduling and dispatching platform hardware and/or software
`
`(e.g., with similar technical and functional features) to design, 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 microcontrollers and microprocessors (e.g.,
`
`RL78 Family of 8/16-bit Ultra-Low Energy MCUs, RX Family of 32-bit High Power Efficiency
`
`MCUs, RH850 Family, RZ Family of 64-Bit & 32-Bit Arm-Based High-End MPUs, V850
`
`Family, 78K Family, R8C Family, M16C Family (R32C / M32C / M16C), M32R Family,
`
`H8/S/SX Family, 720 Family, 740 Family, SuperH RISC engine Family, H8 Super Low Power,
`
`PLC MCU, Renesas RA Family of 32-bit MCUs with Arm Cortex-M Core, RE Family, QzROM
`
`(740/720 Family), M16C (M32C/M16C) Family, R8C Family, 7700 Family, and SuperH RISC
`
`engine Family and MCUs with Arm Cortex-M Core Implemented on Silicon on Thin Buried
`
`Oxide (SOTB)), amplifiers and buffers (e.g., CA3XXX, CA5XXX, EL2XXX, EL4XXX,
`
`EL5XXX, EL8XXX, HA-2XXX, HA-5XXX, HFA11XX, ICL7XXX, ISL28XXX, ISL55XXX,
`
`ISL59XXX, READ23XXXSP, and UPCXXXXXX), analog products (e.g., switches and
`
`multiplexers), clocks and timing products (e.g., application-specific clocks, clock distribution,
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
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`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 15 of 70
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`clock generation, and crystal oscillators), interface & connectivity products (e.g., wireless
`
`modules, switches and hubs, and wireless modules), audio and video products (e.g., ISL54XXX),
`
`automotive products (e.g., Automotive System-on-Chip (SOC), Ambient Light Sensors, Analog
`
`ICs, Car Audio ICs, Battery Management Systems, CAN Transceivers, Discrete/Power MOFETs
`
`for Automotive, Display ICs, Intelligent Power Devices, Interface ICs, LSI for Automotive,
`
`Microcontrollers (RH850), Microcontrollers (RL78/F1x), Power Management (e.g., Power
`
`Management ICs for RH850, Power Supply ICs for R-Car, Switches & Multiplexers, Video ICs,
`
`Discrete Power Devices, regulators, MOSFETs and Motor Drivers, PMICs, and wireless power
`
`devices), ICs for Communications and Mobile Devices (e.g., SH-MobileR, SH-MobileR2,
`
`EMMA Mobile, SH-Mobile MT1, and R-Mobile A1), sensor products (e.g., flow sensors, gas
`
`sensors, humidity sensors, light & proximity sensors, position sensors, sensor signal
`
`conditioners, and optical sensors such as ISL76671), data converters (e.g., HI-565A, HI-
`
`565A/883, and HI5XXX), ICs for Industrial Automation (R-IN) (e.g. R-IN32M3, R-IN32M4-
`
`CL2, TPS-1, EC-1, R-IN32M4-CL3, and R-IN32M3), ICs for Motor Driver/Actuator Driver,
`
`Interface devices (e.g., Bus Buffers, RS-485, RS-422, RS-232, Signal Integrity ICs, Dual
`
`Protocol RS-485, RS-232 Transceivers, and Industrial Network Transceivers), Legacy MCUs
`
`(e.g., 80C/82C Microprocessors & Peripherals), memory (e.g., ultra-fast Quad Data Rate
`
`SRAMs, SRAMs, EEPROM & PROM, MRAMS, FIFO products, interface products, and
`
`standard logic), Optoelectronics, power management devices (e.g., RAJ240XXXDNP), RF
`
`products (e.g., modulators, demodulators, transistor arrays, beamformers, mixers, switches,
`
`attenuators, VGAs, synthesizers and PLLs), Renesas USB Power Delivery Family (e.g., Renesas
`
`USB Power Delivery Family Features and U30 Group), Secure MCUs (e.g., AE-5 Series and
`
`RS-4 Series), Smart Analog devices (e.g., Smart Analog IC101, IC300, IC301, IC500, IC501,
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
`
`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 16 of 70
`
`and IC502), and space and harsh environment devices (e.g., µPD720115, µPD720201,
`
`µPD720202, µPD720210, µPD720211, M66291, R8A66593, and R8A66597), products
`
`manufactured at 28nm and 40nm technology node by TSMC for Renesas such as eFlash and
`
`MCUs, microprocessors, sensors, radars, power efficiency systems, electronic control units, and
`
`automotive products, and similar systems, products, devices, and integrated circuits (“Renesas
`
`Scheduling Products”).
`
`22.
`
`On information and belief, Defendant Renesas (directly or through its Renesas
`
`Foundry Partners such as TSMC) uses camLine’s LineWorks system and/or other Renesas 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 Renesas
`
`Scheduling Products for importation into the United States for use, sale, and/or offer for sale in
`
`this district and throughout the United States.
`
`23.
`
`Defendant Renesas works with third parties to design and/or develop third party
`
`products, such as internet of things products, communications products, automotive products,
`
`computing products, and embedded products that include one or more Renesas APC Products,
`
`Renesas TWINSCAN Products, Renasas YieldStar Products, and/or Renesas Scheduling
`
`Products (“Third Party Products”). For example, on information and belief, Renesas is the
`
`world’s largest supplier of automotive microprocessors. Renesas assists third parties from the
`
`automotive industry, 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
`
`24.
`
`This is an action for patent infringement arising under the patent laws of the
`
`United States, 35 U.S.C. § 1, et seq.
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2012
`
`
`
`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 17 of 70
`
`25.
`
`26.
`
`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).