IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`GREENTHREAD, LLC
`
`Plaintiff,
`
`vs.
`
`CIRRUS LOGIC, INC.
`
`Defendant.
`
`Civil Action No. 1:23-cv-369
`
`JURY TRIAL DEMANDED
`
`FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Greenthread, LLC (“Greenthread” or “Plaintiff”) files this First Amended
`
`Complaint against Cirrus Logic, Inc. (“Cirrus Logic” or “Defendant”) hereby alleges as follows:
`
`THE NATURE OF THE ACTION
`
`1.
`
`Greenthread owns a family of patents related to transistors and other components
`
`of integrated semiconductor devices. Greenthread’s patented inventions describe semiconductor
`
`devices that employ graded dopants and well regions for creating electric fields for aiding and/or
`
`limiting the movement of carriers to (or from) the semiconductor surface to (or from) the
`
`semiconductor substrate. These inventions improve semiconductor devices by (1) creating faster,
`
`more efficient, and more reliable processors, logic devices, DRAM and NAND flash, and image
`
`sensors and (2) allowing manufacturers to scale down the feature size of their semiconductor
`
`products.
`
`2.
`
`Defendant has infringed and continues to infringe six Greenthread patents: U.S.
`
`Patent Nos. 8,421,195 (the “’195 Patent”), 9,190,502 (the “’502 Patent”), 10,510,842 (the “’842
`
`Patent”), 10,734,481 (the “’481 Patent”), 11,121,222 (the “’222 Patent”), and 11,316,014 (the
`
`1
`
`IPR2024-001, -00016, -00017, -00018,
`-00019, -00020, -00021 Ex. 3005
`
`

`

`“’014 Patent”), (collectively “the Greenthread Patents”), copies of which are attached hereto as
`
`Exhibits 1-6, respectively. Defendant has infringed and continues to infringe the Greenthread
`
`Patents by:
`
`a.
`
`b.
`
`making, using, selling, offering for sale, and/or importing into the United States,
`semiconductor devices with infringing graded dopant regions and/or electronic
`products containing the same;
`
`incorporating or using the above-described semiconductor devices into
`electronic products such as laptop computers, desktop computers, and mobile
`workstations.
`
`THE PARTIES
`
`3.
`
`Plaintiff Greenthread, LLC (“Greenthread”) is a limited liability company
`
`organized and existing under the laws of Texas, having its principal place of business at 7424
`
`Mason Dells Drive, Dallas, Texas 75230-3244.
`
`4.
`
`Defendant Cirrus Logic, Inc. (“Cirrus Logic”) is a corporation organized and
`
`existing under the laws of Delaware with its headquarters and principal place of business at 800
`
`West 6th Street, Austin, Texas 78701.
`
`SUBJECT MATTER JURISDICTION
`
`5.
`
`This court has subject matter jurisdiction over the patent infringement claims
`
`asserted in this case under 28 U.S.C. §§ 1331 and 1338(a).
`
`PERSONAL JURISDICTION, VENUE, AND JOINDER
`
`6.
`
`This Court has personal jurisdiction over Defendant Cirrus Logic pursuant to due
`
`process and Texas’ long-arm statute, Tex. Civ. Prac. & Rem. Code Ann. §§ 17.041-17.045, which
`
`extends jurisdiction as far as the federal constitutional requirements of due process will permit.
`
`7.
`
`Cirrus Logic has a regular and established place of business in this District, having
`
`its principal place of business in Austin, Texas. On information and belief, Cirrus Logic has
`
`
`
`2
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`

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`regularly conducted and continues to conduct business in the United States, in the State of Texas,
`
`and in this judicial district. On information and belief, Cirrus Logic has committed acts of
`
`infringement in Texas and in this judicial district by making, using, offering for sale, and/or selling
`
`in the United States and/or importing into the United States, products and systems that infringe
`
`upon the Greenthread Patents, or by placing such infringing products and systems into the stream
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`of commerce with the awareness, knowledge, and intent that they would be used, offered for sale,
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`or sold by others in this judicial district and/or purchased by consumers in this district.
`
`8.
`
`Venue is proper as to Cirrus Logic pursuant to 28 U.S.C. §§ 1391(b) and 1400(b)
`
`because Cirrus Logic has committed, and continue to commit, acts of infringement in this District.
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`Further, Cirrus Logic is domiciled in the State of Texas and this District as an entity with its
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`principal place of business in Austin, Texas.
`
`9.
`
`“Cirrus Logic Accused Products” are products accused of meeting the claim
`
`limitations of a Greenthread Patent in this suit. Cirrus Logic designs and sells semiconductor
`
`devices containing transistors and other structures that infringe the Greenthread Patents in the
`
`United States. The infringing structures within semiconductor devices have application in many
`
`types of devices designed and sold by Cirrus Logic, including amplifiers1, decoder and encoder
`
`integrated circuits (ICs)2, digital-to-analog converters3, analog-to-digital converters4, haptic
`
`drivers5, voice processor ICs6, and other ICs.
`
`10.
`
`Exhibit 8 demonstrates how exemplary Cirrus Logic Accused Products meet the
`
`
`1 https://www.cirrus.com/products/#psearch_T200
`2 https://www.cirrus.com/products/#psearch_T100
`3 https://www.cirrus.com/products/#psearch_T400
`4 https://www.cirrus.com/products/#psearch_T300
`5 https://www.cirrus.com/products/#psearch_T800
`6 https://www.cirrus.com/products/#psearch_T3000
`
`
`
`3
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`

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`claim limitations of Greenthread Patents and is herein incorporated by reference.
`
`11.
`
`On information and belief, the decision to test the infringing designs and
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`incorporate the infringing designs into Cirrus Logic’s products were made by employees in this
`
`district. Cirrus Logic’s Austin headquarters is the nerve center not only of Cirrus Logic’s sales
`
`team, but also its research, development, and testing of the Cirrus Logic Accused Products.7
`
`12.
`
`For example, Cirrus Logic’s U.S. Patent Nos. 10,586,865, 9,919,913, and
`
`
`
`9,853,103, pertain to the doping of semiconductor devices and name Austin-based Cirrus Logic
`
`employees as inventors. Cirrus Logic is also advertising a “Sr. Analog Design Engineer” position
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`in this district that includes as part of its job responsibilities “transistor-level design.”8 Cirrus
`
`Logic is also advertising a “Senior Analog IC Design Engineer – Power” position in this district
`
`that includes “Expertise in … transistor-level design” among the “Required Skills and
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`Qualifications” for the position.9
`
`13.
`
`Cirrus Logic sells Cirrus Logic Accused Products directly and indirectly within the
`
`United States.10
`
`
`7 Cirrus Logic, Inc., Form 10-K (May 20, 2022), at 23.
`8 https://www.cirrus.com/careers/job-detail/?p=job/ovj6lfwZ
`9 https://www.cirrus.com/careers/job-detail/?p=job/obcfkfwG
`10 Cirrus Logic, Inc., Form 10-K (May 20, 2022), at 4.
`
`
`
`4
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`

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`
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`14.
`
`For example, Cirrus Logic attributes 80% of its sales to California-based
`
`technology company Apple, Inc. and maintains a sales office that is, upon information and belief,
`
`only one mile Apple’s headquarters in Cupertino, California.11
`
`15.
`
`For direct sales of the Cirrus Logic Accused Products, Cirrus Logic also maintains
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`a primary sales office located in Austin, Texas.12
`
`16.
`
`For indirect sales, Cirrus Logic uses franchised distributors who sell online
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`throughout the United States.
`
`17.
`
`For example, one of Cirrus Logic’s franchisees is the Texas-based Mouser
`
`Electronics. Mouser Electronics’s website prominently features Cirrus Logic products, which
`
`upon information and belief include the Cirrus Logic Accused Products.
`
`
`
`
`
`
`11 Cirrus Logic, Inc., Form 10-K (May 20, 2022), at 4.
`12 Cirrus Logic, Inc., Form 10-K (May 20, 2022), at 3, 4.
`
`
`
`5
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`

`

`Cirrus Logic “Franchised Distributors”
`https://www.cirrus.com/company/contacts/
`
`
`
`Mouser Electronics’ Cirrus Logic Product Page
`https://www.mouser.com/manufacturer/cirrus-logic/
`
`
`
`18.
`
`Cirrus Logic has also admitted in other judicial proceedings that it provides
`
`6
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`
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`

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`products in the state of Texas and in this District.13
`
`
`
`THE GREENTHREAD PATENTS
`
`19.
`
`On April 16, 2013, the U.S. Patent and Trademark Office duly and legally issued
`
`U.S. Patent No. 8,421,195 (“the ’195 Patent”), entitled “Semiconductor Devices with Graded
`
`Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed January
`
`12, 2007. The ’195 Patent claims priority from U.S. Patent Application No. 10/934,915,14 filed on
`
`September 3, 2004. A true and correct copy of the ’195 Patent is attached hereto as Exhibit 1 and
`
`incorporated herein by reference.
`
`20.
`
`On November 17, 2015, the U.S. Patent and Trademark Office duly and legally
`
`issued U.S. Patent No. 9,190,502 (“the ’502 Patent”), entitled “Semiconductor Devices with
`
`Graded Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed
`
`October 16, 2014. The ’502 Patent claims priority from U.S. Patent Application No. 10/934,915,15
`
`filed on September 3, 2004. A true and correct copy of the ’502 Patent is attached hereto as Exhibit
`
`2 and incorporated herein by reference.
`
`21.
`
`On December 17, 2019, the U.S. Patent and Trademark Office duly and legally
`
`issued U.S. Patent No. 10,510,842 (“the ’842 Patent”), entitled “Semiconductor Devices with
`
`Graded Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed
`
`
`13 Defendant Cirrus Logic Inc.’s Answer, Vantage Micro LLC v. Cirrus Logic Inc., 6:19-cv-578-RP [Dkt.
`12] (W.D. Tex. Feb. 14, 2020)
`14 Pub. No. US 2006/0049464.
`15 Pub. No. US 2006/0049464.
`
`
`
`7
`
`

`

`on May 9, 2017. The ’842 Patent claims priority from U.S. Patent Application No. 10/934,915,16
`
`filed on September 3, 2004. A true and correct copy of the ’842 Patent is attached hereto as Exhibit
`
`3 and incorporated herein by reference.
`
`22.
`
`On August 4, 2020, the U.S. Patent and Trademark Office duly and legally issued
`
`U.S. Patent No. 10,734,481 (“the ’481 Patent”), entitled “Semiconductor Devices with Graded
`
`Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed on
`
`December 17, 2019. The ’481 Patent claims priority from U.S. Patent Application No.
`
`10/934,915,17 filed on September 3, 2004. A true and correct copy of the ’481 Patent is attached
`
`hereto as Exhibit 4 and incorporated herein by reference.
`
`23.
`
`On September 14, 2021, the U.S. Patent and Trademark Office duly and legally
`
`issued U.S. Patent No. 11,121,222 (“the ’222 Patent”), entitled “Semiconductor Devices with
`
`Graded Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed
`
`on July 27, 2020. The ’222 Patent claims priority from U.S. Patent Application No. 10/934,915,18
`
`filed on September 3, 2004. A true and correct copy of the ’222 Patent is attached hereto as Exhibit
`
`5 and incorporated herein by reference.
`
`24.
`
`On April 26, 2022, the U.S. Patent and Trademark Office duly and legally issued
`
`U.S. Patent No. 11,316,014 (“the ‘014 Patent”), entitled “Semiconductor Devices with Graded
`
`Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed on July 9,
`
`2021. The ‘014 Patent claims priority from U.S. Patent Application No. 10/934,915,19 filed on
`
`September 3, 2004. A true and correct copy of the ‘014 Patent is attached hereto as Exhibit 6 and
`
`
`16 Pub. No. US 2006/0049464.
`17 Pub. No. US 2006/0049464.
`18 Pub. No. US 2006/0049464.
`19 Pub. No. US 2006/0049464.
`
`
`
`8
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`

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`incorporated herein by reference.
`
`25.
`
`The ’195, ’502, ’842, ’481, ’222, and ’014 Patents are collectively referred to as
`
`the “Greenthread Patents.”
`
`26.
`
`Greenthread exclusively owns all rights, title, and interest in the Greenthread
`
`Patents necessary to bring this action, including the right to recover past and future damages.
`
`Certain of the Greenthread Patents were previously owned by Dr. G.R. Mohan Rao (“Dr. Rao”).
`
`On April 27, 2015, Dr. Rao assigned to Greenthread the then-issued Greenthread Patents and all
`
`related “continuations, continuations-in-part and extensions of said Applications and Patents and
`
`any pending applications or issued patents that directly claim or are amended to claim priority to
`
`any of the Applications or Patents.” Dr. Rao’s assignment was recorded with the U.S. Patent and
`
`Trademark Office on May 13, 2015, and again on July 22, 2021, and is attached hereto as Exhibit
`
`7. Greenthread has therefore owned all rights to the Greenthread Patents necessary to bring this
`
`action throughout the period of Cirrus Logic’s infringement and still owns those rights to the
`
`Greenthread Patents.
`
`27.
`
`28.
`
`Cirrus Logic is not currently licensed to practice the Greenthread Patents.
`
`The Greenthread Patents are valid and enforceable.
`
`FACTUAL BACKGROUND
`
`29.
`
`Dr. G.R. Mohan Rao (“Dr. Rao”), the sole inventor of the Greenthread Patents, has
`
`been an innovator in the semiconductor industry since the 1960s. He is a named inventor on more
`
`than 100 Patents worldwide and authored numerous technical publications over the last 50 years.
`
`30.
`
`In September 1968, Dr. Rao received a Ph.D. in physics with a specialization in
`
`electronics from Andhra University in Waltair, India. He then traveled to the United States to
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`attend a graduate program in physics at the University of Cincinnati.
`
`31.
`
`After learning of an opportunity to work with Professor William Carr of Southern
`
`
`
`9
`
`

`

`Methodist University (“SMU”), Dr. Rao transferred to SMU where he earned a Ph.D in Electrical
`
`Engineering. While there, he worked in the SMU laboratory with Jack Kilby of Texas Instruments
`
`(a pioneering electrical engineer who would later receive a Nobel Prize for his work), on metal-
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`oxide-silicon transistors (“MOS devices”), which are used for switching and amplifying electronic
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`signals in electronic devices. MOS devices form the basis of modern electronics and are the most
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`widely used semiconductor devices in the world. The U.S. Patent and Trademark Office has called
`
`this device a “groundbreaking invention that transformed life and culture around the world.”20 Dr.
`
`Rao built these devices from scratch while a graduate student at SMU.
`
`32.
`
`Through his mentor, Jack Kilby, Dr. Rao interviewed with—and was ultimately
`
`hired by—Texas Instruments to continue his work on MOS devices in 1972. Dr. Rao worked at
`
`Texas Instruments for the next twenty-two years, rising from an engineer to a Senior Fellow. At
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`that time, Texas Instruments had only 12 Senior Fellows out of approximately 20,000 engineers.
`
`Eventually, Dr. Rao moved into a management position at Texas Instruments, ultimately becoming
`
`a Senior Vice President in 1985.
`
`33.
`
`At Texas Instruments, Dr. Rao received his first patent while working in a process
`
`and product engineering capacity to solve a production problem with Texas Instruments’ 4-kilobit
`
`RAM product. That patent was merely the beginning of Dr. Rao’s long inventive career. Indeed,
`
`from the late 1970s through the mid-1980s, Dr. Rao worked on or managed projects relating to
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`Texas Instruments’ 64kb RAM, 256Kb RAM, 1Mb RAM, 4 Mb RAM, EEPROM, SRAM, and
`
`microcontrollers. For that work, Dr. Rao received numerous additional U.S. Patents.
`
`34.
`
`The USPTO was not the only organization to recognize Dr. Rao’s achievements.
`
`
`20 https://www.uspto.gov/about-us/news-updates/remarks-director-iancu-2019-international-
`lectual-property-conference
`
`
`
`10
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`

`

`Some of Dr. Rao’s work at Texas Instruments was so remarkable that it has been credited in
`
`multiple exhibits in the National Museum of American History at the Smithsonian Institution.21
`
`For example, the Smithsonian has displayed Texas Instruments’ experimental 1-megabit CMOS
`
`DRAM, produced in April 1985 under Dr. Rao’s leadership, and credited Dr. Rao for the
`
`achievement.22
`
`
`In 1994, Dr. Rao left Texas Instruments for Cirrus Logic. During his two-year
`
`35.
`
`tenure at Cirrus Logic, he received more U.S. Patents relating to his work on integrated graphics
`
`controllers and memory.
`
`36.
`
`In 1996, Dr. Rao started a company called Silicon Aquarius. Through a relationship
`
`between Silicon Aquarius and Matsushita, Dr. Rao led a design team in working on a 256Mb
`
`
`21 http://smithsonianchips.si.edu/texas/wafer.htm
`22 http://smithsonianchips.si.edu/texas/t_360.htm
`
`
`
`11
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`

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`DRAM chip. After Silicon Aquarius ceased operations, Dr. Rao did consulting work for a number
`
`of different consulting companies and devoted much of his free time to thinking about various
`
`challenges and problems with which the semiconductor industry had struggled for years.
`
`37.
`
`In 2003, Dr. Rao and Philip John founded Greenthread to continue Dr. Rao’s
`
`pioneering work. A focal point of Dr. Rao’s research was poor refresh time and the related
`
`problem of how to deal with and control the movement of both wanted and unwanted carriers in
`
`semiconductor devices, including memory and logic devices. Dr. Rao realized that graded dopants
`
`could be used to create a “drift layer” and other structures to facilitate the movement—in an
`
`upward or downward direction, as appropriate—of carriers from the semiconductor surfaces down
`
`into the substrate and vice versa. It was Dr. Rao’s work on this problem that culminated in the
`
`Greenthread Patents.
`
`CIRRUS LOGIC’S INFRINGEMENT
`
`38.
`
`Cirrus Logic has directly infringed, and continues to infringe, one or more claims
`
`of each of the Greenthread Patents through making, using, offering to sell, selling within the United
`
`States, and/or importing into the United States semiconductor products that practice the claimed
`
`inventions (i.e., Cirrus Logic Accused Products) including amplifiers, decoder and encoder ICs,
`
`digital-to-analog converters, analog-to-digital converters, digital clocks, haptic drivers, rate
`
`converters, receivers, transceivers, signal processor ICs, and other ICs.
`
`39.
`
`Further, in concert with among others, Apple and Cirrus Logic authorized
`
`distributors, Cirrus Logic caused or induced infringing accused products to be made, used, offered
`
`to be sold, sold within the United States, and/or imported into the United States. Cirrus Logic has
`
`knowledge of the Greenthread patents at least through the service of the Complaint.
`
`40.
`
`Specifically, Cirrus Logic has designed and/or incorporated into other products
`
`
`
`12
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`

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`semiconductor devices for use in mixed-signal and analog processing. The Cirrus Logic Accused
`
`Products include semiconductor devices for boosted audio amplifiers, audio codecs, digital-to-
`
`analog audio converters, analog-to-digital audio converters, audio digital signal processors,
`
`camera controllers, and context-aware haptics and sensing technology, and are further identified
`
`in Exhibit 8.
`
`41.
`
`As shown in Exhibit 8, transistors in the exemplary Cirrus Logic CLI1793B1 power
`
`management integrated circuit (“PIMIC”) meets each and every element of at least one claim of
`
`the Greenthread Patents.
`
`42.
`
`Upon information and belief, Cirrus Logic designed and sold semiconductor
`
`devices using similar designs according to a limited number of processes, many or all of which
`
`utilize substantially similar process steps, including process steps for creating regions with graded
`
`dopant concentrations. The claimed invention would have application in numerous types of Cirrus
`
`Logic products, including amplifiers, decoder and encoder ICs, digital-to-analog converters,
`
`analog-to-digital converters, digital clocks, haptic drivers, rate converters, receivers, transceivers,
`
`signal processor ICs, and other ICs, because such products would benefit from, among other
`
`things, improved switching time. Upon information and belief, the Cirrus Logic Accused Products
`
`are in relevant part substantially similar to the exemplary Cirrus Logic CLI1793B1 PIMIC shown
`
`in Exhibit 8, particularly with regard to the manner in which the exemplary Cirrus Logic
`
`CLI1793B1 PIMIC includes and utilizes regions with graded dopant concentrations. Exhibit 8 is
`
`thus illustrative of the manner in which the Cirrus Logic Accused Products meet the claim
`
`limitations of the Greenthread Patents.23
`
`
`23 Multiple courts have upheld Greenthread’s construction of the Greenthread Patents in related
`matters. In Greenthread, LLC v. Samsung Electronics Co., Ltd. et al., Case No. 2:19-cv-00147-
`JRG (E.D. Tex.), the Eastern District of Texas Court adopted Greenthread’s claim construction.
`
`
`
`13
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`

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`COUNT I: INFRINGEMENT OF U.S. PATENT NO. 8,421,195
`
`43.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Amended Complaint and exhibits attached hereto as if fully set forth herein.
`
`44.
`
`The following allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the Cirrus Logic Accused Products.
`
`Greenthread reserves the right to modify this description, including, for example, on the basis of
`
`information about the Cirrus Logic Accused Products that it obtains during discovery.
`
`45.
`
`Cirrus Logic’s infringement has damaged and continues to damage Greenthread in
`
`an amount yet to be determined, of at least a reasonable royalty.
`
`46.
`
`As alleged above and in Exhibit 8, the products analyzed in Exhibit 8 meet each
`
`and every one of the claim limitations of at least one claim of the ’195 patent.
`
`47.
`
`As alleged above, the products analyzed in Exhibit 8 are exemplary of the Cirrus
`
`Logic Accused Products.
`
`48.
`
`As alleged above, Cirrus Logic has and continues to infringe at least one claim of
`
`the ’195 patent by making, using, offering to sell, selling within the United States, and/or importing
`
`
`See Dkt. 67. In Greenthread, LLC v. Intel Corp., et al., Case No. 6:22-cv-00105-ADA (W.D. Tex),
`the Western District of Texas similarly issued a preliminary claim construction order adopting
`Greenthread’s construction. See Dkt. 36-21 in Greenthread, LLC v. Intel Corp., Case No. 3:22-cv-
`02001-JR (attaching as an exhibit the Western District of Texas’s preliminary claim construction
`order in a status update before the District of Oregon). The claims in this matter against Intel were
`ultimately severed and transferred to Oregon, and the District of Oregon adopted the Western
`District of Texas’ preliminary claim construction. See Dkt. 44 (“The Court also finds that the
`WDTX’s preliminary constructions and summary judgment rulings are neither legally incorrect
`nor factually distinguishable. As a result, the Court adopts the WDTX’s preliminary constructions
`and summary judgment rulings as its own. . .”). The Western District of Texas also denied
`Defendants’ motions to dismiss and for summary judgment on similar grounds. See Dkt. 36-22 in
`Greenthread, LLC v. Intel Corp., Case no. 3:22-cv-02001-JR (attaching as an exhibit the Western
`District of Texas’ denial of Defendants’ motion for summary judgment); Dkt. 110 in Greenthread
`LLC v. Intel Corp., Case No. 6:22-cv-00105-ADA (W.D. Tex). The District of Oregon similarly
`adopted these rulings. See Dkt. 44 in Greenthread, LLC v. Intel Corp., Case no. 3:22-cv-02001-
`JR.
`
`
`
`14
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`into the United States Cirrus Logic Accused Products.
`
`49.
`
`As alleged above, Cirrus Logic induced infringement of at least one claim of the
`
`’195 Patent by designing and marketing infringing products for sale, use, and importation into the
`
`United States.
`
`50.
`
`Cirrus Logic’s infringement has damaged and continues to damage Greenthread in
`
`an amount yet to be determined, of at least a reasonable royalty.
`
`COUNT II: INFRINGEMENT OF U.S. PATENT NO. 9,190,502
`
`51.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Amended Complaint and exhibits attached hereto as if fully set forth herein.
`
`52.
`
`The following allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the Cirrus Logic Accused Products.
`
`Greenthread reserves the right to modify this description, including, for example, on the basis of
`
`information about the Cirrus Logic Accused Products that it obtains during discovery.
`
`53.
`
`Cirrus Logic’s infringement has damaged and continues to damage Greenthread in
`
`an amount yet to be determined, of at least a reasonable royalty.
`
`54.
`
`As alleged above and in Exhibit 8, the products analyzed in Exhibit 8 meet each
`
`and every one of the claim limitations of at least one claim of the ’502 patent.
`
`55.
`
`As alleged above, the products analyzed in Exhibit 8 are exemplary of the Cirrus
`
`Logic Accused Products.
`
`56.
`
`As alleged above, Cirrus Logic has and continues to infringe at least one claim of
`
`the ’502 patent by making, using, offering to sell, selling within the United States, and/or importing
`
`into the United States Cirrus Logic Accused Products.
`
`57.
`
`As alleged above, Cirrus Logic induced infringement of at least one claim of the
`
`
`
`15
`
`

`

`’502 Patent by designing and marketing infringing products for sale, use, and importation into the
`
`United States.
`
`58.
`
`Cirrus Logic’s infringement has damaged and continues to damage Greenthread in
`
`an amount yet to be determined, of at least a reasonable royalty.
`
`COUNT III: INFRINGEMENT OF U.S. PATENT NO. 10,510,842
`
`59.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Amended Complaint and exhibits attached hereto as if fully set forth herein.
`
`60.
`
`The following allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the Cirrus Logic Accused Products.
`
`Greenthread reserves the right to modify this description, including, for example, on the basis of
`
`information about the Cirrus Logic Accused Products that it obtains during discovery.
`
`61.
`
`Cirrus Logic’s infringement has damaged and continues to damage Greenthread in
`
`an amount yet to be determined, of at least a reasonable royalty.
`
`62.
`
`As alleged above and in Exhibits 8, the products analyzed in Exhibit 8 meet each
`
`and every one of the claim limitations of at least one claim of the ’842 patent.
`
`63.
`
`As alleged above, the products analyzed in Exhibit 8 are exemplary of the Cirrus
`
`Logic Accused Products.
`
`64.
`
`As alleged above, Cirrus Logic has and continues to infringe at least one claim of
`
`the ’842 patent by making, using, offering to sell, selling within the United States, and/or importing
`
`into the United States Cirrus Logic Accused Products.
`
`65.
`
`As alleged above, Cirrus Logic induced infringement of at least one claim of the
`
`’842 Patent by designing and marketing infringing products for sale, use, and importation into the
`
`United States.
`
`
`
`16
`
`

`

`66.
`
`Cirrus Logic’s infringement has damaged and continues to damage Greenthread in
`
`an amount yet to be determined, of at least a reasonable royalty.
`
`COUNT IV: INFRINGEMENT OF U.S. PATENT NO. 10,734,481
`
`67.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Amended Complaint and exhibits attached hereto as if fully set forth herein.
`
`68.
`
`The following allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the Cirrus Logic Accused Products.
`
`Greenthread reserves the right to modify this description, including, for example, on the basis of
`
`information about the Cirrus Logic Accused Products that it obtains during discovery.
`
`69.
`
`Cirrus Logic’s infringement has damaged and continues to damage Greenthread in
`
`an amount yet to be determined, of at least a reasonable royalty.
`
`70.
`
`As alleged above and in Exhibits 8, the products analyzed in Exhibit 8 meet each
`
`and every one of the claim limitations of at least one claim of the ’841 patent.
`
`71.
`
`As alleged above, the products analyzed in Exhibit 8 are exemplary of the Cirrus
`
`Logic Accused Products.
`
`72.
`
`As alleged above, Cirrus Logic has and continues to infringe at least one claim of
`
`the ’841 patent by making, using, offering to sell, selling within the United States, and/or importing
`
`into the United States Cirrus Logic Accused Products.
`
`73.
`
`As alleged above, Cirrus Logic induced infringement of at least one claim of the
`
`’481 Patent by designing and marketing infringing products for sale, use, and importation into the
`
`United States.
`
`74.
`
`Cirrus Logic’s infringement has damaged and continues to damage Greenthread in
`
`an amount yet to be determined, of at least a reasonable royalty.
`
`
`
`17
`
`

`

`COUNT V: INFRINGEMENT OF U.S. PATENT NO. 11,121,222
`
`75.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Amended Complaint and exhibits attached hereto as if fully set forth herein.
`
`76.
`
`The following allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the Cirrus Logic Accused Products.
`
`Greenthread reserves the right to modify this description, including, for example, on the basis of
`
`information about the Cirrus Logic Accused Products that it obtains during discovery.
`
`77.
`
`Cirrus Logic’s infringement has damaged and continues to damage Greenthread in
`
`an amount yet to be determined, of at least a reasonable royalty.
`
`78.
`
`As alleged above and in Exhibit 8, the products analyzed in Exhibit 8 meet each
`
`and every one of the claim limitations of at least one claim of the ’222 patent.
`
`79.
`
`As alleged above, the products analyzed in Exhibit 8 are exemplary of the Cirrus
`
`Logic Accused Products.
`
`80.
`
`As alleged above, Cirrus Logic has and continues to infringe at least one claim of
`
`the ’222 patent by making, using, offering to sell, selling within the United States, and/or importing
`
`into the United States Cirrus Logic Accused Products.
`
`81.
`
`As alleged above, Cirrus Logic induced infringement of at least one claim of the
`
`’222 Patent by designing and marketing infringing products for sale, use, and importation into the
`
`United States.
`
`82.
`
`Cirrus Logic’s infringement has damaged and continues to damage Greenthread in
`
`an amount yet to be determined, of at least a reasonable royalty.
`
`COUNT VI: INFRINGEMENT OF U.S. PATENT NO. 11,316,014
`
`83.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`
`
`18
`
`

`

`paragraphs of this Amended Complaint and exhibits attached hereto as if fully set forth herein.
`
`84.
`
`The following allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the Cirrus Logic Accused Products.
`
`Greenthread reserves the right to modify this description, including, for example, on the basis of
`
`information about the Cirrus Logic Accused Products that it obtains during discovery.
`
`85.
`
`Cirrus Logic’s infringement has damaged and continues to damage Greenthread in
`
`an amount yet to be determined, of at least a reasonable royalty.
`
`86.
`
`As alleged above and in Exhibits 8, the products analyzed in Exhibit 8 meet each
`
`and every one of the claim limitations of at least one claim of the ’014 patent.
`
`87.
`
`As alleged above, the products analyzed in Exhibit 8 are exemplary of the Cirrus
`
`Logic Accused Products.
`
`88.
`
`As alleged above, Cirrus Logic has and continues to infringe at least one claim of
`
`the ’014 patent by making, using, offering to sell, selling within the United States, and/or importing
`
`into the United States Cirrus Logic Accused Products.
`
`89.
`
`As alleged above, Cirrus Logic induced infringement of at least one claim of the
`
`’014 Patent by designing and marketing infringing products for sale, use, and importation into the
`
`United States.
`
`90.
`
`Cirrus Logic’s infringement has damaged and continues to damage Greenthread in
`
`an amount yet to be determined, of at least a reasonable royalty.
`
`DAMAGES
`
`91.
`
`As a result of Cirrus Logic’s acts of infringement, Greenthread has suffered and
`
`continues to suffer actual and consequential damages. However, Greenthread does not yet know
`
`the full extent of the infringement and the amount of damages cannot be ascertained except through
`
`
`
`19
`
`

`

`discovery and special accounting. To the fullest extent pe