IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`GREENTHREAD, LLC,
`
`Plaintiff,
`
`v.
`
`OMNIVISION TECHNOLOGIES, INC.,
`
`Defendant.
`
`GREENTHREAD, LLC,
`
`Plaintiff,
`
`v.
`
`TEXAS INSTRUMENTS INCORPORATED,
`
`Defendant.
`
`GREENTHREAD, LLC,
`
`Plaintiff,
`
`v.
`
`AMS-OSRAM AG ET AL.
`
`Defendant.
`
`Case No. 2:23-cv-00212-JRG
`(Consolidated Lead Case)
`
`JURY TRIAL DEMANDED
`
`Case No. 2:23-cv-00157-JRG
`(Member Case)
`
`JURY TRIAL DEMANDED
`
`Case No. 2:23-cv-00179-JRG
`(Member Case)
`
`JURY TRIAL DEMANDED
`
`FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT AGAINST
`DEFENDANTS AMS-OSRAM AG, OSRAM GMBH, AND AMS SENSORS USA INC.
`
`Plaintiff Greenthread, LLC (“Greenthread” or “Plaintiff”) files this First Amended
`
`Complaint against Defendants AMS-OSRAM AG, OSRAM GmbH, and ams Sensors USA Inc.
`
`(collectively “AMS-OSRAM” or “Defendants”) and hereby alleges as follows:
`
`IPR2024-001, -00016, -00017, -00018,
`-00019, -00020, -00021 Ex. 3006
`
`

`

`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, and image sensors and (2) allowing
`
`manufacturers to scale down the feature size of their semiconductor products.
`
`2.
`
`Defendants have infringed and continue 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
`
`’014 Patent”), (collectively “the Greenthread Patents”), copies of which are attached hereto as
`
`Exhibits 1-6, respectively. Defendants have infringed and continue to infringe the Greenthread
`
`Patents by 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.
`
`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 AMS-OSRAM AG is a foreign corporation organized and existing under
`
`the laws of Austria, having its principal places of business at Tobelbader Strasse 30, 8141
`
`Premstaetten, Austria and at Marcel-Breuer-Strasse 4 80807 Munich, Germany.
`
`
`
`2
`
`

`

`5.
`
`Defendant OSRAM GmbH is a foreign corporation organized and existing under
`
`the laws of Germany, having its principal places of business at Marcel-Breuer-Strasse 4
`
`80807 Munich, Germany and Tobelbader Strasse 30, 8141 Premstaetten, Austria.
`
`6.
`
`Defendant ams Sensors USA Inc. is organized and exists under the law of Nevada,
`
`with its principal place of business at 5556 Tennyson Parkway, Plano, Texas 75024. Upon
`
`information and belief, ams Sensors USA Inc. is a wholly owned subsidiary of AMS-OSRAM AG
`
`and/or OSRAM GmbH. ams Sensors USA Inc.’s Nevada corporate registration lists its Plano
`
`address for all of its officers and directors.
`
`7.
`
`On information and belief AMS-OSRAM AG and OSRAM GmbH act with and
`
`through ams Sensors USA, Inc. and other US affiliates or partners to conduct their joint business
`
`in the United States, including designing, using, manufacturing, selling and importing into the
`
`United States AMS-OSRAM Accused Products. On information and belief, ams Sensors USA,
`
`Inc. employees and officers coordinate with employees of other AMS-OSRAM entities in these
`
`activities to pursue a common enterprise.
`
`8.
`
`The AMS-OSRAM enterprise purports to be a “global leader in optical solutions”
`
`that offers “a unique product and technology portfolio for sensing, illumination and visualization:
`
`from prime-quality light emitters and optical components to micro-modules, light sensors, ICs and
`
`related software.”1 AMS-OSRAM designs, manufactures, tests, and sells semiconductor devices
`
`to approximately 22,000 customers with over 40 research and development sites worldwide.2
`
`
`1 https://ams-osram.com/about-us
`2 https://ams-osram.com/
`
`
`
`3
`
`

`

`SUBJECT MATTER JURISDICTION
`
`9.
`
`This action arises under the patent laws of the United States, namely 35 U.S.C.
`
`§§ 271, 281, and 284-285, among others.
`
`10.
`
`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 AND VENUE
`
`11.
`
`The Court has general personal jurisdiction over ams Sensors, Inc. because its
`
`principal place of business is in this district. ams Sensors USA Inc.’s Nevada corporate registration
`
`lists 5556 Tennyson Parkway, Plano, Texas 75024 as the address for all of its officers and directors.
`
`12.
`
`The Court has general personal jurisdiction over AMS-OSRAM AG and OSRAM
`
`GmbH because they operate and control the common business AMS-OSRAM enterprise,
`
`including ams Sensors USA Inc. over which the court has general personal jurisdiction. For
`
`example, notwithstanding the purported corporate separateness of AMS-OSRAM AG and
`
`OSRAM GmbH, the companies maintain co-headquarters for the AMS-OSRAM enterprise.3
`
`13.
`
`On information and belief, AMS-OSRAM AG manufactures some AMS-OSRAM
`
`Accused Products (defined below) for sale and import into the United States with and through ams
`
`Sensors USA Inc. at a fabrication plant co-located with its Austrian co-headquarters.4
`
`14.
`
`Likewise, on information and belief, the AMS-OSRAM Advanced Optical Sensors
`
`division of the AMS-OSRAM enterprise is responsible for the design, testing, manufacture, and
`
`sale of many accused products. The AMS-OSRAM enterprise holds out that division as a “global
`
`
`3 https://ams-osram.com/about-us/locations-distribution/headquarters
`4 https://ams-osram.com/about-us/locations-distribution/headquarters
`
`
`
`4
`
`

`

`team in Europe, North America and Asia.”5 On information and belief, the persons comprising
`
`this team are formally employed by various AMS-OSRAM entities in the countries in which they
`
`work, including ams Sensors USA Inc., but operate as a single “team.” On information and belief,
`
`other AMS-OSRAM divisions are similarly organized.
`
`15.
`
`This Court has personal jurisdiction over Defendants in accordance with the Texas
`
`Long Arm Statute, Tex. Civ. Prac. & Rem. Code § 17.042, because, among other things,
`
`Defendants have (1) contracted in Texas to sell AMS-OSRAM Accused Products including at
`
`Defendants’ Plano facility, (2) contracted with Texas residents to sell AMS-OSRAM Accused
`
`Products in Texas (including Mouser Electronics), (3) committed other acts of infringement in
`
`Texas, including, on information and belief, testing accused products at Defendants’ Plano facility,
`
`and (3) recruited Texas residents for employment, including at Defendants’ facility in Plano Texas.
`
`16.
`
`This Court has specific personal jurisdiction over Defendants because they have
`
`committed acts within this District giving rise to this action (including acts of infringement) and
`
`have established minimum contacts with this forum such that the exercise of jurisdiction over
`
`Defendants would not offend traditional notions of fair play and substantial justice. Such acts
`
`include designing, testing, and selling AMS-OSRAM Accused Products in and from this district,
`
`including from AMS-OSRAM’s “Design Center” and “Sales Office” at 5556 Tennyson Parkway
`
`Plano, TX 75024.6
`
`17.
`
`Products of the AMS-OSRAM enterprise are designed and advertised specifically
`
`for the U.S. market. For example, AMS-OSRAM advertises that TMF8828 (identified below as
`
`
`5 https://ams-osram.com/news/press-releases/elektra-award-shortlist
`6 https://ams-osram.com/about-us/locations-distribution/design-application-test-center;
`https://ams-osram.com/about-us/locations-distribution/sales-offices-branches
`
`
`
`5
`
`

`

`an exemplary AMS-OSRAM Accused Product) complies with federal safety regulations, 21
`
`C.F.R. §§ 1040.10 and 1040.11.7
`
`18.
`
`Furthermore, OSRAM GmbH is an owner and operator of the Internet domain
`
`www.ams-osram.com. On information and belief, AMS-OSRAM AG, OSRAM GmbH, and the
`
`AMS-OSRAM enterprise are responsible for the website at www.ams-osram.com.
`
`
`7 https://ams.com/documents/20143/6015057/TMF882X_DS000693_5-00.pdf
`
`
`
`
`
`6
`
`

`

`
`
`19.
`
`A visitor to www.ams-osram.com attempting to purchase a TMF8828 (identified
`
`below as an exemplary AMS-OSRAM Accused Product) is directed to AMS-OSRAM’s Texas-
`
`based “Channel Partner” Mouser Electronics.
`
`
`
`
`
`1 AMS-OSRAM product page for TMF8828
`
`7
`
`
`
`
`
`

`

`2 Pop-up window for "Buy Now" button on TMF8828 product page
`
`
`
`3 Clicking "Mouser" button on AMS-OSRAM TMF8828 product page leads to Mouser TMF8828
`product page.
`
`
`
`
`
`
`8
`
`

`

`4 AMS-OSRAM site listing Mouser as a “Distribution partner.” The address provided for
`Mouser’s “HQ” is located outside Dallas, Texas.
`
`20.
`
`Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391 and 1400 because
`
`
`
`AMS-OSRAM has committed, and continues to commit, acts of infringement in this District and
`
`has a regular and established place of business in this District at 5556 Tennyson Parkway, Plano,
`
`TX 75024. Venue is also proper because ams Sensors USA Inc. maintains its principal place of
`
`
`
`business in this District at 5556 Tennyson Parkway, Plano, TX 75024.
`
`21.
`
`“AMS-OSRAM Accused Products” are products accused of meeting the claim
`
`limitations of a Greenthread Patent in this suit. AMS-OSRAM designs and manufactures
`
`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 manufactured by AMS-OSRAM, including
`
`capacitive sensors, light sensors, 3D sensors, position sensors, complementary metal-oxide
`
`semiconductor (“CMOS”) imaging sensors, sensor interfaces, analog and mixed signal application
`
`specific integrated circuits (“ASIC”), infrared emitters, laser diodes, sensors for phototransistors,
`
`photodiodes, optical sensors, and photo integrated circuits; and LEDs for illumination and
`
`
`
`9
`
`

`

`automotive, consumer, and industry applications.8
`
`22.
`
`Exhibit 8 demonstrates how an exemplary AMS-OSRAM Accused Product meets
`
`the claim limitations of Greenthread Patents and is herein incorporated by reference.
`
`THE GREENTHREAD PATENTS
`
`23.
`
`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. 10/934,915,9 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.
`
`24.
`
`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. 10/934,915,10
`
`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.
`
`25.
`
`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
`
`
`8 https://ams.com/en/products; https://www.osram.com/os/products/index.jsp
`9 Pub. No. US 2006/0049464.
`10 Pub. No. US 2006/0049464.
`
`
`
`10
`
`

`

`on May 9, 2017. The ’842 Patent claims priority from U.S. Patent Application No. 10/934,915,11
`
`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.
`
`26.
`
`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.
`
`10/934,915,12 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.
`
`27.
`
`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. 10/934,915,13
`
`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.
`
`28.
`
`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. 10/934,915,14 filed on
`
`
`11 Pub. No. US 2006/0049464.
`12 Pub. No. US 2006/0049464.
`13 Pub. No. US 2006/0049464.
`14 Pub. No. US 2006/0049464.
`
`
`
`11
`
`

`

`September 3, 2004. A true and correct copy of the ’014 Patent is attached hereto as Exhibit 6 and
`
`incorporated herein by reference.
`
`29.
`
`The ’195, ’502, ’842, ’481, ’222, and ’014 Patents are collectively referred to as
`
`the “Greenthread Patents.”
`
`30.
`
`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 Defendants’ infringement and still owns those rights to the
`
`Greenthread Patents.
`
`31.
`
`32.
`
`Defendants are not currently licensed to practice the Greenthread Patents.
`
`The Greenthread Patents are valid and enforceable.
`
`FACTUAL BACKGROUND
`
`33.
`
`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.
`
`34.
`
`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
`
`attend a graduate program in physics at the University of Cincinnati.
`
`
`
`12
`
`

`

`35.
`
`After learning of an opportunity to work with Professor William Carr of Southern
`
`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-
`
`oxide-silicon transistors (“MOS devices”), which are used for switching and amplifying electronic
`
`signals in electronic devices. MOS devices form the basis of modern electronics and are the most
`
`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.”15 Dr.
`
`Rao built these devices from scratch while a graduate student at SMU.
`
`36.
`
`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
`
`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.
`
`37.
`
`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
`
`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.
`
`
`15 https://www.uspto.gov/about-us/news-updates/remarks-director-iancu-2019-international-
`lectual-property-conference
`
`
`
`13
`
`

`

`38.
`
`The USPTO was not the only organization to recognize Dr. Rao’s achievements.
`
`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.16
`
`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.17
`
`
`In 1994, Dr. Rao left Texas Instruments for Cirrus Logic. During his two-year
`
`39.
`
`tenure at Cirrus Logic, he received more U.S. Patents relating to his work on integrated graphics
`
`controllers and memory.
`
`
`16 http://smithsonianchips.si.edu/texas/wafer.htm
`17 http://smithsonianchips.si.edu/texas/t_360.htm
`
`
`
`14
`
`

`

`40.
`
`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
`
`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.
`
`41.
`
`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.
`
`42.
`
`Dr. Rao resides in this District.
`
`AMS-OSRAM’S INFRINGEMENT
`
`43.
`
`AMS-OSRAM 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, including capacitive
`
`sensors, light sensors, 3D sensors, position sensors, CMOS imaging sensors, sensor interfaces,
`
`analog and mixed signal ASICs, infrared emitters, laser diodes, sensors for phototransistors,
`
`photodiodes, optical sensors, and photo integrated circuits; and LEDs for illumination and
`
`
`
`15
`
`

`

`automotive, consumer, and industry applications18 that practice the claimed inventions (i.e., the
`
`AMS-OSRAM Accused Products). A non-exhaustive, exemplary list of the types of products or
`
`devices that infringe are further identified in Exhibit 8.
`
`44.
`
`Further, in concert with others, including AMS-OSRAM authorized distributors
`
`and customers, AMS-OSRAM 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. AMS-
`
`OSRAM has knowledge of the Greenthread patents at least through the service of the Complaint.
`
`Further, any use, sale, offer to sell, or importation into the United States the of the AMS-OSRAM
`
`Accused Products necessarily infringes, regardless of the use case, configuration, or other
`
`circumstances, because the claims relate to the individual transistors within the accused product.
`
`Therefore, simply by virtue of its knowledge of its sale of the AMS-OSRAM Accused Products
`
`AMS-OSRAM has knowledge of downstream infringement.
`
`45.
`
`For example, AMS-OSRAM, on information and belief, is a supplier to electronics
`
`companies, such as Bang & Olufsen, a manufacturer and seller of high-end audio and video
`
`products in the United States.19 Bang & Olufsen products include over-ear headphones that retail
`
`for $999 U.S. dollars and incorporate ASM-OSRAM Accused Products.20 Bang & Olufsen (and
`
`other direct or indirect customers of AMS-OSRAM) infringe Greenthread’s Patents by using,
`
`selling, offering to sell, or importing into the United States products containing AMS-OSRAM
`
`Accused Products as components. By providing Bang & Olufsen (and other electronics
`
`manufacturers) with AMS-OSRAM Accused Products for incorporation into their products, AMS-
`
`
`18 https://ams.com/en/products; https://www.osram.com/os/products/index.jsp
`19 https://ams-osram.com/news/press-releases/bang-olufsen
`20 https://www.bang-olufsen.com/en/us/headphones/beoplay-h95
`
`
`
`16
`
`

`

`OSRAM induces infringement by Bang & Olufsen and others who use, sell, offer to sell, or import
`
`into the United States products containing AMS-OSRAM Accused Products as components.
`
`46.
`
`As shown in Exhibit 8, an exemplary AMS-OSRAM Accused Product, TMF8828,
`
`meets each and every element of at least one claim of the Greenthread Patents. As shown above,
`
`the exemplary accused products are sold in the United States through AMS-OSRAM authorized
`
`distributors, such as Mouser Electronics.
`
`47.
`
`Upon information and belief, AMS-OSRAM fabricates and designs the AMS-
`
`OSRAM Accused Products 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, because the invention would have application in those
`
`categories of products. For example, using Greenthread’s invention improves switching time in
`
`transistors used in AMS-OSRAM Accused Products. Upon information and belief, the AMS-
`
`OSRAM Accused Products are in relevant part substantially similar to the exemplary TMF8828
`
`shown in Exhibit 8, particularly with regard to the manner in which the exemplary TMF8828
`
`includes and utilizes regions with graded dopant concentrations. Exhibit 8 is thus illustrative of
`
`the manner in which the AMS-OSRAM Accused Products meet the claim limitations of the
`
`Greenthread Patents.21
`
`
`21 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.
`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 preliminary claim constructions adopting
`Greenthread’s construction. See Dkt. 36-21 in Greenthread, LLC v. Intel Corp., Case No. 3:22-cv-
`02001-JR (D. Or.) (attaching as an exhibit the Western District of Texas’s preliminary claim
`constructions in a status update before the District of Oregon). The claims in that matter against
`Intel were ultimately severed and transferred to Oregon, and the District of Oregon adopted the
`Western District of Texas’ preliminary claim constructions. See Dkt. 44 (“The Court also finds
`that the WDTX’s preliminary constructions and summary judgment rulings are neither legally
`
`
`
`17
`
`

`

`COUNT I: INFRINGEMENT OF U.S. PATENT NO. 8,421,195
`
`48.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein.
`
`49.
`
`The following allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the AMS-OSRAM Accused Products.
`
`Greenthread reserves the right to modify this description, including, for example, on the basis of
`
`information about the AMS-OSRAM Accused Products that it obtains during discovery.
`
`50.
`
`Defendants’ infringement has damaged and continues to damage Greenthread in an
`
`amount yet to be determined, of at least a reasonable royalty.
`
`51.
`
`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.
`
`52.
`
`As alleged above, the products analyzed in Exhibit 8 are exemplary of the AMS-
`
`OSRAM Accused Products.
`
`53.
`
`As alleged above, Defendants have infringed and continue to infringe at least one
`
`claim of the ’195 Patent by making, using, offering to sell, selling within the United States, and/or
`
`importing into the United States AMS-OSRAM Accused Products.
`
`
`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 the 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 the 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.
`
`
`
`18
`
`

`

`54.
`
`As alleged above, AMS-OSRAM 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.
`
`55.
`
`Defendants’ 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
`
`56.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein.
`
`57.
`
`The following allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the AMS-OSRAM Accused Products.
`
`Greenthread reserves the right to modify this description, including, for example, on the basis of
`
`information about the AMS-OSRAM Accused Products that it obtains during discovery.
`
`58.
`
`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.
`
`59.
`
`As alleged above, the products analyzed in Exhibit 8 are exemplary of the AMS-
`
`OSRAM Accused Products.
`
`60.
`
`As alleged above, Defendants have infringed and continue 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 AMS-OSRAM Accused Products.
`
`61.
`
`As alleged above, AMS-OSRAM induced infringement of at least one claim of the
`
`’502 Patent by designing and marketing infringing products for sale, use, and importation into the
`
`United States.
`
`
`
`19
`
`

`

`62.
`
`Defendants’ 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
`
`63.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein.
`
`64.
`
`The following allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the AMS-OSRAM Accused Products.
`
`Greenthread reserves the right to modify this description, including, for example, on the basis of
`
`information about the AMS-OSRAM Accused Products that it obtains during discovery.
`
`65.
`
`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.
`
`66.
`
`As alleged above, the products analyzed in Exhibit 8 are exemplary of the AMS-
`
`OSRAM Accused Products.
`
`67.
`
`As alleged above, Defendants have infringed and continue 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 AMS-OSRAM Accused Products.
`
`68.
`
`As alleged above, AMS-OSRAM 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.
`
`69.
`
`Defendants’ infringement has damaged and continues to damage Greenthread in an
`
`amount yet to be determined, of at least a reasonable royalty.
`
`
`
`20
`
`

`

`COUNT IV: INFRINGEMENT OF U.S. PATENT NO. 10,734,481
`
`70.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein.
`
`71.
`
`The following allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the AMS-OSRAM Accused Products.
`
`Greenthread reserves the right to modify this description, including, for example, on the basis of
`
`information about the AMS-OSRAM Accused Products that it obtains during discovery.
`
`72.
`
`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 ’481 Patent.
`
`73.
`
`As alleged above, the products analyzed in Exhibit 8 are exemplary of the AMS-
`
`OSRAM Accused Products.
`
`74.
`
`As alleged above, Defendants have infringed and continue to infringe at least one
`
`claim of the ’481 Patent by making, using, offering to sell, selling within the United States, and/or
`
`importing into the United States AMS-OSRAM Accused Products.
`
`75.
`
`As alleged above, AMS-OSRAM 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.
`
`76.
`
`Defendants’ infringement has damaged and continues to damage Greenthread in an
`
`amount yet to be determined, of at least a reasonable royalty.
`