Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 1 of 42
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`
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`GREENTHREAD, LLC
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`Plaintiff,
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`Civil Action No. 6:22-cv-105
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`vs.
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`
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`INTEL CORPORATION, DELL INC., AND
`DELL TECHNOLOGIES INC.;
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`JURY TRIAL DEMANDED
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`Defendants.
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`
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`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`
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`Plaintiff Greenthread, LLC (“Greenthread” or “Plaintiff”) files this Complaint against Intel
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`Corporation (“Intel”), and Dell Inc. and Dell Technologies Inc. (collectively, “Dell,” or “Dell
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`Defendants,” and together with Intel, “Defendants”), and hereby alleges as follows:
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`THE NATURE OF THE ACTION
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`1.
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`Greenthread owns a family of patents related to transistors and other components
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`of integrated semiconductor devices. Greenthread’s patented inventions describe semiconductor
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`devices that employ graded dopants and well regions for creating electric fields for aiding and/or
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`limiting the movement of carriers to (or from) the semiconductor surface to (or from) the
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`semiconductor substrate. These inventions improve semiconductor devices by (1) creating faster,
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`more efficient, and more reliable processors, logic devices, DRAM and NAND flash, and image
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`sensors and (2) allowing manufacturers to scale down the feature size of their semiconductor
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`products.
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`2.
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`Defendants have infringed and continue to infringe five Greenthread patents: U.S.
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`Patent Nos. 8,421,195 (the “’195 Patent”), 9,190,502 (the “’502 Patent”), 10,510,842 (the “’842
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`1
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`Greenthread Ex 2001, p.1 of 42
`Cirrus Logic, et. al. v. Greenthread
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`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 2 of 42
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`Patent”), 10,734,481 (the “’4481 Patent”), and 11,121,222 (the “’222 Patent”) (collectively “the
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`Greenthread Patents”), copies of which are attached hereto as Exhibits A-G, respectively.
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`Defendants have infringed and continue to infringe the Greenthread Patents by:
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`a.
`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;
`b.
`incorporating or using the above-described semiconductor devices into
`electronic products such as laptop computers, desktop computers, and mobile
`workstations.
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`THE PARTIES
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`3.
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`Plaintiff Greenthread, LLC (“Greenthread”) is a limited liability company
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`organized and existing under the laws of Texas, having its principal place of business at 7424
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`Mason Dells Drive, Dallas, Texas 75230-3244.
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`4.
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`Defendant Intel Corporation (“Intel”) is a corporation organized and existing under
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`the laws of the state of Delaware.
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`5.
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`6.
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`7.
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`On information and belief, Intel owns and controls the internet domain “intel.com.”
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`Intel says that it is “proud to call [Austin] Texas home.”1
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`Defendant Dell Inc. is a corporation organized under the laws of the state of
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`Delaware, having its principal place of business at One Dell Way, Round Rock, Texas, 78664.
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`8.
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`Defendant Dell Technologies Inc. is a corporation organized and existing under the
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`laws of Delaware, having its principal place of business at One Dell Way, Round Rock, Texas,
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`78682.
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`9.
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`On information and belief, Dell owns and controls the internet domains “dell.com”
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`and “delltechnologies.com.”
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`1 https://www.intel.com/content/www/us/en/corporate-responsibility/intel-in-texas.html
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`2
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`Greenthread Ex 2001, p.2 of 42
`Cirrus Logic, et. al. v. Greenthread
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`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 3 of 42
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`SUBJECT MATTER JURISDICTION
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`10.
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`This court has subject matter jurisdiction over the patent infringement claims
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`asserted in this case under 28 U.S.C. §§ 1331 and 1338(a).
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`PERSONAL JURISDICTION, VENUE, AND JOINDER
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`11.
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`Intel has a regular and established places of business in this District, including at
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`1300 S. Mopac Expressway, Austin, Texas 78746 and at 9442 N Capital of Texas Hwy, Bldg 2,
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`Suite 600, Austin, Texas 78759.
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`12.
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`Intel is “proud to call [Austin] Texas home.”2
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`13.
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`Intel distributes its products through, among others, Intel authorized “original
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`equipment manufacturers” and Intel authorized “System Manufacturers” as part of the “Intel
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`Partner Alliance.”3
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`14.
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`Dell is an Intel authorized “System Manufacturer[],”4 an Intel authorized “original
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`equipment manufacturer,” and a “Titanium” member of the “Intel Partner Alliance.”5
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`15.
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`Intel directs persons wishing to transact business with Dell relating to Intel products
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`(including Dell Accused Products) to contact Dell in this District at 401 Dell Way Round Rock,
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`TX, 78664.6
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`16.
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`Dell’s principal place of business is in this District at One Dell Way, Round Rock,
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`TX 78664.7
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`2 https://www.intel.com/content/www/us/en/corporate-responsibility/intel-in-texas.html
`3 https://www.intel.com/content/www/us/en/partner-alliance/membership/overview.html
`4 https://www.intel.com/content/www/us/en/support/contact-intel.html?tab=system-
`manufacturers#
`5 https://marketplace.intel.com/s/partner/a5S3b0000016OSmEAM/dell-
`technologies?language=en_US&wapkw=dell
`6 https://marketplace.intel.com/s/partner/a5S3b0000016OSmEAM/dell-
`technologies?language=en_US&wapkw=dell
`7 https://www.delltechnologies.com/en-us/contactus.htm
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`
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`3
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`Greenthread Ex 2001, p.3 of 42
`Cirrus Logic, et. al. v. Greenthread
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`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 4 of 42
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`17.
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`Dell’s online retail store at Dell.com sells, offers for sale, and advertises Dell
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`Accused Products for sale in this District, including the accused exemplary Dell Alienware M15
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`R6 laptop containing the accused exemplary Intel Core i7 11800H.8
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`18.
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`On information and belief, Dell’s online retail store at Dell.com, from which it sells
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`Dell Accused Products is controlled by Dell from Dell’s facilities in this District.
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`19.
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`Best Buy is an authorized Dell retailer9 selling and offering for sale Accused
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`Products10 (including Dell Accused Products containing the exemplary Intel Core i7 11800H),11
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`in this District, including at 9607 Research Blvd. Suite 500, Austin, TX 78759.
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`20.
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`Intel approves and authorizes sales of Dell products through Best Buy.12
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`21.
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`Costco is an authorized Dell retailer selling and offering for sale Accused Products
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`(including Dell Accused Products containing the exemplary Intel Core i7 11800H)13 in this
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`District, including at 10401 Research Blvd, Austin, TX 78759.14
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`22.
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`This Court has personal jurisdiction over Defendants in accordance with the Texas
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`Long Arm Statute, Tex. Civ. Prac. & Rem. Code § 17.042, because, among other things,
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`Defendants have contracted with Texas residents to sell Accused Products in Texas (including
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`Defendants’ agreements for Intel to sell Intel Accused Products to Dell), committed other acts of
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`8 https://www.dell.com/en-us/shop/dell-laptops/alienware-m15-r6-gaming-laptop/spd/alienware-
`m15-r6-laptop
`9 https://www.dell.com/en-us/shop/dell/cp/reseller_store_locator
`10 “Accused Products” are all Intel Accused Products and Dell Accused Products
`11 https://www.bestbuy.com/site/dell-g15-15-6-fhd-gaming-laptop-intel-core-i7-16gb-memory-
`nvidia-geforce-rtx-3050-512gb-solid-state-drive-black-dark-shadow-
`grey/6470463.p?skuId=6470463
`12 https://www.intel.com/content/www/us/en/newsroom/news/advancing-chipmaking-4000-
`steps.html#gs.k3n0p9; https://www.intel.com/content/www/us/en/products/docs/devices-
`systems/laptops/laptop-innovation-program/a-shared-vision-for-the-future-of-computing.html
`13 https://www.costco.com/dell-xps-17-laptop---11th-gen-intel-core-i7-11800h---geforce-rtx-
`3050---windows-11.product.100808060.html
`14 https://www.dell.com/en-us/shop/dell/cp/reseller_store_locator
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`4
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`Greenthread Ex 2001, p.4 of 42
`Cirrus Logic, et. al. v. Greenthread
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`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 5 of 42
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`infringement in Texas, and recruited Texas residents for employment.
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`23.
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`This Court has general personal jurisdiction over Defendants because Dell’s
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`principal place of business is in this District and Intel claims to be at “home”15 in this District.
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`24.
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`This Court has specific personal jurisdiction over Defendants because they have
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`committed acts within this District giving rise to this action (including acts of infringement) and
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`have established minimum contacts with this forum such that the exercise of jurisdiction over
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`Defendants would not offend traditional notions of fair play and substantial justice.
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`25.
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`Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391 and 1400(b) because
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`Defendants reside in this District.
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`26.
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`Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391 and 1400(b) because
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`Defendants have regular and established places of business in this district and have committed acts
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`of infringement in this district.
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`27.
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`Joinder of Defendants is proper under 35 U.S.C. § 299, because Greenthread’s right
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`to relief arises from the same transactions or occurrences regarding the same Accused Products
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`(such as Intel’s sale of Intel Accused Products to Dell) and questions of fact common to all
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`Defendants will arise in this action.
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`THE GREENTHREAD PATENTS
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`28.
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`On April 16, 2013, the U.S. Patent and Trademark Office duly and legally issued
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`U.S. Patent No. 8,421,195 (“the ’195 Patent”), entitled “Semiconductor Devices with Graded
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`Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed January
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`12, 2007. The ’195 Patent claims priority from U.S. Patent Application No. 10/934,915,16 filed on
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`15 https://www.intel.com/content/www/us/en/corporate-responsibility/intel-in-texas.html
`16 Pub. No. US 2006/0049464.
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`5
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`Greenthread Ex 2001, p.5 of 42
`Cirrus Logic, et. al. v. Greenthread
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`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 6 of 42
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`September 3, 2004. A true and correct copy of the ’195 Patent is attached hereto as Exhibit A and
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`incorporated herein by reference.
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`29.
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`On November 17, 2015, the U.S. Patent and Trademark Office duly and legally
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`issued U.S. Patent No. 9,190,502 (“the ’502 Patent”), entitled “Semiconductor Devices with
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`Graded Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed
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`October 16, 2014. The ’502 Patent claims priority from U.S. Patent Application No. 10/934,915,17
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`filed on September 3, 2004. A true and correct copy of the ’502 Patent is attached hereto as Exhibit
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`B and incorporated herein by reference.
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`30.
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`On December 17, 2019, the U.S. Patent and Trademark Office duly and legally
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`issued U.S. Patent No. 10,510,842 (“the ’842 Patent”), entitled “Semiconductor Devices with
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`Graded Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed
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`on May 9, 2017. The ’842 Patent claims priority from U.S. Patent Application No. 10/934,915,18
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`filed on September 3, 2004. A true and correct copy of the ’842 Patent is attached hereto as Exhibit
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`C and incorporated herein by reference.
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`31.
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`On August 4, 2020, the U.S. Patent and Trademark Office duly and legally issued
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`U.S. Patent No. 10,734,481 (“the ’4481 Patent”), entitled “Semiconductor Devices with Graded
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`Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed on
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`December 17, 2019. The ’4481 Patent claims priority from U.S. Patent Application No.
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`10/934,915,19 filed on September 3, 2004. A true and correct copy of the ’4481Patent is attached
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`hereto as Exhibit D and incorporated herein by reference.
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`32.
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`On September 14, 2021, the U.S. Patent and Trademark Office duly and legally
`
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`17 Pub. No. US 2006/0049464.
`18 Pub. No. US 2006/0049464.
`19 Pub. No. US 2006/0049464.
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`6
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`Greenthread Ex 2001, p.6 of 42
`Cirrus Logic, et. al. v. Greenthread
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`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 7 of 42
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`issued U.S. Patent No. 11,121,222 (“the ’222 Patent”), entitled “Semiconductor Devices with
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`Graded Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed
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`on July 27, 2020. The ’222 Patent claims priority from U.S. Patent Application No. 10/934,915,20
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`filed on September 3, 2004. A true and correct copy of the ’222 Patent is attached hereto as Exhibit
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`E and incorporated herein by reference.
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`33.
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`The ’195, ’502, ’842, ’4481, and ’222 Patents are collectively referred to as the
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`“Greenthread Patents.”
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`34.
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`Greenthread exclusively owns all rights, title, and interest in the Greenthread
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`Patents necessary to bring this action, including the right to recover past and future damages.
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`Certain of the Greenthread Patents were previously owned by Dr. G.R. Mohan Rao (“Dr. Rao”).
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`On April 27, 2015, Dr. Rao assigned to Greenthread the then-issued Greenthread Patents and all
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`related “continuations, continuations-in-part and extensions of said Applications and Patents and
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`any pending applications or issued patents that directly claim or are amended to claim priority to
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`any of the Applications or Patents.” Dr. Rao’s assignment was recorded with the U.S. Patent and
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`Trademark Office on May 13, 2015 and is attached hereto as Exhibit F. Greenthread has therefore
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`owned all rights to the Greenthread Patents necessary to bring this action throughout the period of
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`Dell’s and Intel’s infringement and still owns those rights to the Greenthread Patents.
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`35.
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`36.
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`Dell and Intel are not currently licensed to practice the Greenthread Patents.
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`The Greenthread Patents are valid and enforceable.
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`FACTUAL BACKGROUND
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`37.
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`Dr. G.R. Mohan Rao (“Dr. Rao”), the sole inventor of the Greenthread Patents, has
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`been an innovator in the semiconductor industry since the 1960s. He is a named inventor on more
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`20 Pub. No. US 2006/0049464.
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`7
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`Greenthread Ex 2001, p.7 of 42
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`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 8 of 42
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`than 100 Patents worldwide and authored numerous technical publications over the last 50 years.
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`38.
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`In September 1968, Dr. Rao received a Ph.D. in physics with a specialization in
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`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.
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`39.
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`After learning of an opportunity to work with Professor William Carr of Southern
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`Methodist University (“SMU”), Dr. Rao transferred to SMU where he earned a Ph.D in Electrical
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`Engineering. While there, he worked in the SMU laboratory with Jack Kilby of Texas Instruments
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`(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
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`this device a “groundbreaking invention that transformed life and culture around the world.”21 Dr.
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`Rao built these devices from scratch while a graduate student at SMU.
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`40.
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`Through his mentor, Jack Kilby, Dr. Rao interviewed with—and was ultimately
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`hired by—Texas Instruments to continue his work on MOS devices in 1972. Dr. Rao worked at
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`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.
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`Eventually, Dr. Rao moved into a management position at Texas Instruments, ultimately becoming
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`a Senior Vice President in 1985.
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`41.
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`At Texas Instruments, Dr. Rao received his first patent while working in a process
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`and product engineering capacity to solve a production problem with Texas Instruments’ 4-kilobit
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`21 https://www.uspto.gov/about-us/news-updates/remarks-director-iancu-2019-international-
`intellectual-property-conference
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`8
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`Greenthread Ex 2001, p.8 of 42
`Cirrus Logic, et. al. v. Greenthread
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`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 9 of 42
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`RAM product. That patent was merely the beginning of Dr. Rao’s long inventive career. Indeed,
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`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
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`microcontrollers. For that work, Dr. Rao received numerous additional U.S. Patents.
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`42.
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`The USPTO was not the only organization to recognize Dr. Rao’s achievements.
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`Some of Dr. Rao’s work at Texas Instruments was so remarkable that it has been credited in
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`multiple exhibits in the National Museum of American History at the Smithsonian Institution.22
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`For example, the Smithsonian has displayed Texas Instruments’ experimental 1-megabit CMOS
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`DRAM, produced in April 1985 under Dr. Rao’s leadership, and credited Dr. Rao for the
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`achievement.23
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`22 http://smithsonianchips.si.edu/texas/wafer.htm
`23 http://smithsonianchips.si.edu/texas/t_360.htm
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`9
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`43.
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`In 1994, Dr. Rao left Texas Instruments for Cirrus Logic. During his two-year
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`tenure at Cirrus Logic, he received more U.S. Patents relating to his work on integrated graphics
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`controllers and memory.
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`44.
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`In 1996, Dr. Rao started a company called Silicon Aquarius. Through a relationship
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`between Silicon Aquarius and Matsushita, Dr. Rao led a design team in working on a 256Mb
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`DRAM chip. After Silicon Aquarius ceased operations, Dr. Rao did consulting work for a number
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`of different consulting companies and devoted much of his free time to thinking about various
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`challenges and problems with which the semiconductor industry had struggled for years.
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`45.
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`In 2003, Dr. Rao and Philip John founded Greenthread to continue Dr. Rao’s
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`pioneering work. A focal point of Dr. Rao’s research was poor refresh time and the related
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`problem of how to deal with and control the movement of both wanted and unwanted carriers in
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`semiconductor devices, including memory and logic devices. Dr. Rao realized that graded dopants
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`could be used to create a “drift layer” and other structures to facilitate the movement—in an
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`upward or downward direction, as appropriate—of carriers from the semiconductor surfaces down
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`into the substrate and vice versa. It was Dr. Rao’s work on this problem that culminated in the
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`Greenthread Patents.
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`INTEL’S INFRINGEMENT
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`46.
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`Intel has directly infringed, and continues to infringe, one or more claims of each
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`of the Greenthread Patents through making, using, offering to sell, selling within the United States,
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`and/or importing into the United States semiconductor products that practice the claimed
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`inventions (“Intel Accused Products”). One exemplary Intel Accused Product is the Intel Core i7
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`11800H. As described below, a scanning electron microscope, spreading resistance profile, and
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`secondary ion mass spectrometry analysis shows that the Intel Core i7 11800H meets each and
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`10
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`Greenthread Ex 2001, p.10 of 42
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`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 11 of 42
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`every element of at least one claim of the Greenthread Patents.
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`47.
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`Upon information and belief, Intel fabricates the Intel Accused Products using
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`similar designs according to a limited number of processes, many or all of which utilize
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`substantially similar process steps, including process steps for creating regions with graded dopant
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`concentrations. Upon information and belief, the Intel Accused Products are in relevant part
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`substantially similar to the exemplary Intel Core i7 11800H, in particular with regard to the manner
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`in which the exemplary Intel Core i7 11800H includes and utilizes regions with graded dopant
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`concentrations. Paragraphs in this complaint describing exemplary infringement by the Intel Core
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`i7 11800H are thus illustrative of the manner in which each of the Intel Accused Products infringes.
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`48.
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`The Intel Accused Products include Intel’s 12th generation of semiconductors
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`labeled as “Alder Lake,” Intel’s 11th generation of semiconductors labeled as “Tiger Lake,” and
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`Intel’s 10th generation of semiconductors labeled as “Comet Lake.” An exemplary list of Intel
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`Accused Products is identified in Exhibit G. Greenthread reserves the right to amend its list of
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`Intel Accused Products, including based on information learned in discovery.
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`DELL’S INFRINGEMENT
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`49.
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`Greenthread incorporates by reference the preceding paragraphs as though fully set
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`forth herein.
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`50.
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`The scanning electron microscope, spreading resistance profile, and secondary ion
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`mass spectrometry analysis shown in below was performed on an Intel Core i7 11800H obtained
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`from a Dell Alienware M15 R6 laptop purchased in the United States.
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`51.
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`In concert with Intel, through the “Intel Partner Alliance,” Dell incorporates many
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`Intel Accused Products into Dell’s products (“Dell Accused Products”). Dell has directly
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`infringed, and continues to infringe, one or more claims of each of the Greenthread Patents through
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`11
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`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 12 of 42
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`making, using, offering to sell, selling within, and/or importing into the United States Dell Accused
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`Products, including the exemplary Dell Alienware M15 R6 laptop that contains Intel Accused
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`Products, including the exemplary Intel Core i7 11800H and other Intel Accused Products.
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`52.
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`Dell Accused Products include at least all Dell Products that incorporate any Intel
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`Accused Product as a component. For example, Dell incorporates Intel Core i7 11800H into
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`Inspiron, New Inspiron, XPS, New XPS, G15, and Alienware laptops. An exemplary list of Dell
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`Accused Products is identified in Exhibit G. Greenthread reserves the right to amend its list of
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`Dell Accused Products, including based on information learned in discovery.
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`COUNT I: INFRINGEMENT OF U.S. PATENT NO. 8,421,195
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`53.
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`Greenthread incorporates by reference and re-alleges all of the foregoing
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`paragraphs of this Complaint as if fully set forth herein.
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`54.
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`The exemplary Intel Core i7 11800H infringes one or more claims of the ’195
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`Patent, including for example, claim 1 of the ’195 Patent. Greenthread’s allegations of
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`infringement are not limited to claim 1 and additional infringed claims will be identified and
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`disclosed through discovery and infringement contentions.
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`55.
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`Greenthread’s allegations are not limited to the exemplary Intel Core i7 11800H.
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`As previously alleged, the Intel Core i7 11800H is exemplary of numerous Intel Accused Products
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`which are incorporated into numerous Dell Accused Products. On information and belief, each of
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`the Intel Accused Products infringes in a substantially similar manner to the Intel Core i7 11800H
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`and each of the Dell Accused Products infringes by incorporating one or more of the Intel Accused
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`Products.
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`56.
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`To the extent that the preamble is a limitation, the Intel Core i7 11800H is a CMOS
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`semiconductor device.
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`12
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`Greenthread Ex 2001, p.12 of 42
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`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 13 of 42
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`57.
`
`The Intel Core i7 11800H has a surface layer.
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`58.
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`The Intel Core i7 11800H has a substrate.
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`
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`59.
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`The Intel Core i7 11800H has an active region including a source and a drain,
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`disposed on one surface of said surface layer.
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`
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`13
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`Greenthread Ex 2001, p.13 of 42
`Cirrus Logic, et. al. v. Greenthread
`
`

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`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 14 of 42
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`60.
`
`
`The Intel Core i7 11800H has a single drift layer disposed between the other surface
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`of said surface layer and said substrate, said drift layer having a graded concentration of dopants
`
`extending between said surface layer and said substrate, said drift layer further having a first static
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`unidirectional electric drift field to aid the movement of minority carriers from said surface layer
`
`to said substrate.
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`
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`
`
`14
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`Greenthread Ex 2001, p.14 of 42
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 15 of 42
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`61.
`
`The Intel Core i7 11800H has at least one well region disposed in said single drift
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`layer, said well region having a graded concentration of dopants and a second static unidirectional
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`electric drift field to aid the movement of minority carriers from said surface layer to said substrate.
`
`
`
`
`
`15
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`Greenthread Ex 2001, p.15 of 42
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 16 of 42
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`62.
`
`
`The foregoing allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the Accused Products. Greenthread
`
`reserves the right to modify this description, including, for example, on the basis of information
`
`about the Accused Products that it obtains during discovery.
`
`63.
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`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
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`64.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Complaint as if fully set forth herein.
`
`65.
`
`The exemplary Intel Core i7 11800H infringes one or more claims of the ’502
`
`
`
`16
`
`Greenthread Ex 2001, p.16 of 42
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 17 of 42
`
`
`
`Patent, including for example, claim 7 of the ’502 Patent. Greenthread’s allegations of
`
`infringement are not limited to claim 7 and additional infringed claims will be identified and
`
`disclosed through discovery and infringement contentions.
`
`66.
`
`Greenthread’s allegations are not limited to the exemplary Intel Core i7 11800H.
`
`As previously alleged, the Intel Core i7 11800H is exemplary of numerous Intel Accused Products
`
`which are incorporated into numerous Dell Accused Products. On information and belief, each of
`
`the Intel Accused Products infringes in a substantially similar manner to the Intel Core i7 11800H
`
`and each of the Dell Accused Products infringes by incorporating one or more of the Intel Accused
`
`Products.
`
`67.
`
`To the extent that the preamble is a limitation, the Intel Core i7 11800H is a
`
`semiconductor device.
`
`68.
`
` The Intel Core i7 11800H has a surface layer.
`
`69.
`
`The Intel Core i7 11800H has a substrate.
`
`
`
`
`
`17
`
`Greenthread Ex 2001, p.17 of 42
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 18 of 42
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`
`
`70.
`
`
`The Intel Core i7 11800H has an active region including a source and a drain,
`
`disposed on one surface of said surface layer.
`
`71.
`
`
`The Intel Core i7 11800H has a single drift layer disposed between the other surface
`
`of said surface layer and said substrate, said drift layer having a graded concentration of dopants
`
`generating a first static unidirectional electric drift field to aid the movement of minority carriers
`
`from said surface layer to said substrate.
`
`
`
`18
`
`Greenthread Ex 2001, p.18 of 42
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 19 of 42
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`
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`
`
`72.
`
`
`The Intel Core i7 11800H has at least one well region disposed in said single drift
`
`layer, said well region having a graded concentration of dopants generating a second static
`
`unidirectional electric drift field to aid the movement of minority carriers from said surface layer
`
`to said substrate.
`
`
`
`19
`
`Greenthread Ex 2001, p.19 of 42
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 20 of 42
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`
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`
`
`
`
`
`
`73.
`
`The foregoing allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the Accused Products. Greenthread
`
`
`
`20
`
`Greenthread Ex 2001, p.20 of 42
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 21 of 42
`
`
`
`reserves the right to modify this description, including, for example, on the basis of information
`
`about the Accused Products that it obtains during discovery.
`
`74.
`
`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
`
`75.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Complaint as if fully set forth herein.
`
`76.
`
`The exemplary Intel Core i7 11800H infringes one or more claims of the ’842
`
`Patent, including for example, claim 1 of the ’842 Patent. Greenthread’s allegations of
`
`infringement are not limited to claim 1 and additional infringed claims will be identified and
`
`disclosed through discovery and infringement contentions.
`
`77.
`
`Greenthread’s allegations are not limited to the exemplary Intel Core i7 11800H.
`
`As previously alleged, the Intel Core i7 11800H is exemplary of numerous Intel Accused Products
`
`which are incorporated into numerous Dell Accused Products. On information and belief, each of
`
`the Intel Accused Products infringes in a substantially similar manner to the Intel Core i7 11800H
`
`and each of the Dell Accused Products infringes by incorporating one or more of the Intel Accused
`
`Products.
`
`78.
`
`To the extent that the preamble is a limitation, the Intel Core i7 11800H is a
`
`semiconductor device.
`
`79.
`
`The Intel Core i7 11800H has a substrate of a first doping type at a first doping
`
`level having first and second surfaces.
`
`
`
`21
`
`Greenthread Ex 2001, p.21 of 42
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 22 of 42
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`
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`
`
`80.
`
`
`The Intel Core i7 11800H has a first active region disposed adjacent the first surface
`
`of the substrate with a second doping type opposite in conductivity to the first doping type and
`
`within which transistors can be formed. See images below.
`
`
`
`22
`
`Greenthread Ex 2001, p.22 of 42
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 23 of 42
`
`
`
`81.
`
`The Intel Core i7 11800H has a second active region separate from the first active
`
`region disposed adjacent to the first active region and within which transistors can be formed.
`
`
`
`
`
`23
`
`Greenthread Ex 2001, p.23 of 42
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 24 of 42
`
`82.
`
`The Intel Core i7 11800H has transistors formed in at least one of the first active
`
`
`
`24
`
`
`
`
`
`Greenthread Ex 2001, p.24 of 42
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 25 of 42
`
`
`
`region or second active region.
`
`83.
`
`
`The Intel Core i7 11800H has at least a portion of at least one of the first and second
`
`active regions having at least one graded dopant concentration to aid carrier movement from the
`
`first surface to the second surface of the substrate.
`
`
`
`25
`
`Greenthread Ex 2001, p.25 of 42
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 1 Filed 01/27/22 Page 26 of 42
`
`
`
`
`
`84.
`
`The foregoing allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the Accused Products. Greenthread
`
`reserves the right to modify this description, including, for example, on the basis of information
`
`about the Accused Products that it obtains during discovery.
`
`85.
`
`Defendants’ infringement has damaged and continues to damage Greenthread in an
`
`amount yet to be determined, of at least a reasonable royalty.
`
`
`
`
`
`
`
`26
`
`Greenthread Ex