Case 6:22-cv-00105-ADA Document 38 Filed 04/29/22 Page 1 of 29
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`
`
`
`GREENTHREAD, LLC
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`
`Plaintiff,
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`
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`
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`
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`Civil Action No. 6:22-cv-105-ADA
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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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`FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT
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`
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`Plaintiff Greenthread, LLC (“Greenthread” or “Plaintiff”) files this First Amended
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`Complaint against Intel Corporation (“Intel”), and Dell Inc. and Dell Technologies Inc.
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`(collectively, “Dell,” or “Dell Defendants,” and together with Intel, “Defendants”) pursuant to
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`Local Rule CV-15, 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
`
`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 six Greenthread patents: U.S.
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`
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`1
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`Greenthread Ex 2003, p.1 of 29
`Cirrus Logic, et. al. v. Greenthread
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`Case 6:22-cv-00105-ADA Document 38 Filed 04/29/22 Page 2 of 29
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`
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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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`Patent”), 10,734,481 (the “’481 Patent”), 11,121,222 (the “’222 Patent”), and 11,316,014 (the
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`“’014 Patent”), (collectively “the Greenthread Patents”), copies of which are attached hereto as
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`Exhibits 1-7, respectively. Defendants have infringed and continue to infringe the Greenthread
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`Patents by:
`
`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.
`
`THE PARTIES
`
`3.
`
`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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`1 https://www.intel.com/content/www/us/en/corporate-responsibility/intel-in-texas.html
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`
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`2
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`Greenthread Ex 2003, p.2 of 29
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`Case 6:22-cv-00105-ADA Document 38 Filed 04/29/22 Page 3 of 29
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`and “delltechnologies.com.”
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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 Intel 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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`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
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`
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`3
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`Greenthread Ex 2003, p.3 of 29
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`Case 6:22-cv-00105-ADA Document 38 Filed 04/29/22 Page 4 of 29
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`TX 78664.7
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`17.
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`“Accused Products” are products accused of meeting the claim limitations of a
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`Greenthread Patent in this suit.
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`18.
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`“Dell Products,” as used herein, means products made, used, offered for sale, or
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`sold within the United States, and/or imported into the United States by Dell. “Dell Accused
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`Products” are Dell Products accused of meeting the claim limitations of a Greenthread Patent in
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`this suit, including Dell-Intel Accused Products (defined below), the Dell-Micron Accused
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`Products (defined below), the Dell-WD Accused Products (defined below), and the Dell-Sony
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`Accused Products (defined below). Exhibits 8-12 demonstrating how exemplary Dell-Intel
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`Accused Products, Dell-Micron Accused Products, Dell-WD Accused Products, and Dell-Sony
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`Accused Products meet the claim limitations of Greenthread Patents are herein incorporated by
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`reference.
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`19.
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`Dell’s online retail store at Dell.com sells, offers for sale, and advertises Accused
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`Products for sale in this District, including the accused exemplary Dell Alienware M15 R6 laptop
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`containing the accused exemplary Intel Core i7 11800H.8
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`20.
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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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`21.
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`Best Buy is an authorized Dell retailer9 selling and offering for sale Accused
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`Products10 (including Dell-Intel Accused Products containing the exemplary Intel Core i7
`
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`7 https://www.delltechnologies.com/en-us/contactus.htm
`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
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`4
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`Case 6:22-cv-00105-ADA Document 38 Filed 04/29/22 Page 5 of 29
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`11800H),11 in this District, including at 9607 Research Blvd. Suite 500, Austin, TX 78759.
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`22.
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`Intel approves and authorizes sales of Dell Products through Best Buy.12
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`23.
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`Costco is an authorized Dell retailer selling and offering for sale Accused Products
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`(including Dell-Intel 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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`24.
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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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`infringement in Texas, and recruited Texas residents for employment.
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`25.
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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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`26.
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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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`27.
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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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`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
`15 https://www.intel.com/content/www/us/en/corporate-responsibility/intel-in-texas.html
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`
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`5
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`Defendants reside in this District.
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`28.
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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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`29.
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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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`30.
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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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`September 3, 2004. A true and correct copy of the ’195 Patent is attached hereto as Exhibit 1 and
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`incorporated herein by reference.
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`31.
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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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`2 and incorporated herein by reference.
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`
`16 Pub. No. US 2006/0049464.
`17 Pub. No. US 2006/0049464.
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`6
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`32.
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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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`3 and incorporated herein by reference.
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`33. 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 ’481 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 ’481 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 ’481Patent is attached
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`hereto as Exhibit 4 and incorporated herein by reference.
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`34.
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`On September 14, 2021, the U.S. Patent and Trademark Office duly and legally
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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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`5 and incorporated herein by reference.
`
`35.
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`On April 26, 2022, the U.S. Patent and Trademark Office duly and legally issued
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`U.S. Patent No. 11,316,014 (“the ‘014 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 July 9,
`
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`18 Pub. No. US 2006/0049464.
`19 Pub. No. US 2006/0049464.
`20 Pub. No. US 2006/0049464.
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`7
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`2021. The ‘014 Patent claims priority from U.S. Patent Application No. 10/934,915,21 filed on
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`September 3, 2004. A true and correct copy of the ‘014 Patent is attached hereto as Exhibit 6 and
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`incorporated herein by reference.
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`36.
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`The ’195, ’502, ’842, ’481, ’222, and ’014 Patents are collectively referred to as
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`the “Greenthread Patents.”
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`37.
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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 again on July 22, 2021, and is attached hereto as Exhibit
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`7. Greenthread has therefore owned all rights to the Greenthread Patents necessary to bring this
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`action throughout the period of Dell’s and Intel’s infringement and still owns those rights to the
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`Greenthread Patents.
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`38.
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`39.
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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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`40.
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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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`than 100 Patents worldwide and authored numerous technical publications over the last 50 years.
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`21 Pub. No. US 2006/0049464.
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`8
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`41.
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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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`42.
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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.”22 Dr.
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`Rao built these devices from scratch while a graduate student at SMU.
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`43.
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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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`44.
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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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`RAM product. That patent was merely the beginning of Dr. Rao’s long inventive career. Indeed,
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`22 https://www.uspto.gov/about-us/news-updates/remarks-director-iancu-2019-international-
`intellectual-property-conference
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`9
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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.
`
`45.
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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.23
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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.24
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`46.
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`In 1994, Dr. Rao left Texas Instruments for Cirrus Logic. During his two-year
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`
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`23 http://smithsonianchips.si.edu/texas/wafer.htm
`24 http://smithsonianchips.si.edu/texas/t_360.htm
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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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`47.
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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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`48.
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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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`49.
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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
`
`inventions, including Intel Accused CPUs and Intel Accused Flash Memory Products (“Intel
`
`Accused Products”).
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`A. Intel Accused CPUs
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`50.
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`The Intel Accused CPUs include all CPUs designed or manufactured (in whole or
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`in part) by Intel, including Intel’s 12th generation of semiconductors labeled as “Alder Lake,”
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`Intel’s 11th generation of semiconductors labeled as “Tiger Lake,” and Intel’s 10th generation of
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`semiconductors labeled as “Comet Lake.” An exemplary list of Intel Accused CPUs is identified
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`in Exhibit 8.
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`51.
`
`As shown in Exhibit 9 the Intel Core i7 11800H CPU meets each and every element
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`of at least one claim of the Greenthread Patents.
`
`52.
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`Upon information and belief, Intel fabricates CPUs using similar designs according
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`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. Upon information
`
`and belief, the Intel Accused CPUs are in relevant part substantially similar to the exemplary Intel
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`Core i7 11800H, in particular with regard to the manner in which the exemplary Intel Core i7
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`11800H includes and utilizes regions with graded dopant concentrations. Exhibit 9 is thus
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`illustrative of the manner in which each of the Intel Accused CPUs infringes.
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`53.
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`Greenthread reserves the right to amend its list of Intel Accused Products, including
`
`based on information learned in discovery.
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`B. Intel Accused Flash Memory Products
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`54.
`
`Intel Accused Flash Memory Products include all flash memory products designed
`
`or manufactured (in whole or in part) by Intel. Flash memory products include solid state drives
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`(“SSDs”), microSD/SD cards, and thumb drives.
`
`55.
`
`As shown in Exhibit 10 the Micron 16 nm node NAND flash memory meets each
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`and every element of at least one claim of the Greenthread Patents.
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`56.
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`The exemplary Micron 16 nm node NAND flash memory analyzed in Exhibit 10
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`bears Intel Die markings and was manufactured by Intel.
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`12
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`57.
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`Upon information and belief, Intel designs and/or fabricates flash memory 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.
`
`58.
`
`Upon information and belief, the Intel Accused Flash Memory Products are in
`
`relevant part substantially similar to the exemplary Micron 16 nm node NAND flash memory
`
`analyzed in Exhibit 10, in particular with regard to the manner in which the exemplary flash
`
`memory product includes and utilizes regions with graded dopant concentrations. Exhibit 10 is
`
`thus illustrative of the manner in which each of the Intel Accused Flash Memory Products.
`
`59.
`
`Greenthread reserves the right to amend its list of Intel Accused Products, including
`
`based on information learned in discovery.
`
`
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`Case 6:22-cv-00105-ADA Document 38 Filed 04/29/22 Page 14 of 29
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`
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`DELL’S INFRINGEMENT
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`60.
`
`Greenthread incorporates by reference the preceding paragraphs as though fully set
`
`forth herein. Greenthread further incorporates by reference Exhibit 8-12, which further detail
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`Dell’s infringement for each category of Accused Products identified below. As described below
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`Dell infringes the Greenthread Patents by making, using, offering to sell, selling within the United
`
`States, and/or importing into the United States the Dell Accused Products, which include at least
`
`Dell-Intel Accused Products (defined below), the Dell-Micron Accused Products (defined below),
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`the Dell-WD Accused Products (defined below), and the Dell-Sony Accused Products (defined
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`below).
`
`A. Dell-Intel Accused Products
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`61.
`
`In concert with Intel, through the “Intel Partner Alliance,” Dell incorporates many
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`Intel Accused CPUs and Intel Accused Flash Memory Products (“Intel Accused Products”) into
`
`Dell Products and/or many Dell Products comprise Intel Accused Products. Dell Products
`
`incorporating or comprising Intel Accused Products are the “Dell-Intel Accused Products,”
`
`regardless of how such products are branded.
`
`62.
`
`For example, the Intel Core i7 11800H analyzed in Exhibit 9 was obtained from a
`
`Dell Alienware M15 R6 laptop purchased in the United States. That same laptop included flash
`
`memory manufactured by Intel, as shown below. The laptop is therefore a Dell-Intel Accused
`
`Product both because it incorporates an Accused Intel CPU and because it incorporates an Intel
`
`Accused Flash Memory Product. By way of further example, Dell incorporates the Intel Core i7
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`11800H into other Dell Products, including Inspiron, New Inspiron, XPS, New XPS, G15, and
`
`Alienware laptops. Such Dell Products are Dell-Intel Accused Products. An exemplary list of
`
`Dell-Intel Accused Products is identified in Exhibit 8.
`
`
`
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`Case 6:22-cv-00105-ADA Document 38 Filed 04/29/22 Page 15 of 29
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`
`
`
`
`63.
`
`Dell 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, and/or importing
`
`into the United States Dell-Intel Accused Products, including the exemplary Dell Alienware M15
`
`R6 laptop. Greenthread reserves the right to amend its list of Dell-Intel Accused Products,
`
`including based on information learned in discovery.
`
`B. Dell-Micron Accused Products
`
`64.
`
`Dell-Micron Accused Products include all Dell Products containing or comprising
`
`flash memory designed or manufactured (in whole or in part) by Micron Technology, Inc., Micron
`
`Semiconductor Products, Inc., Micron Technology Texas, LLC and/or their affiliates (“Micron”)
`
`regardless of how such products are branded. Flash memory products include SSDs, microSD/SD
`
`cards, and thumb drives.
`
`65.
`
`As shown in Exhibit 10, the exemplary Micron 16 nm node NAND flash memory
`
`meets each and every element of at least one claim of the Greenthread Patents.
`
`66.
`
`Upon information and belief, Micron fabricates and designs flash memory using
`
`similar designs according to a limited number of processes, many or all of which utilize
`
`
`
`15
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`Case 6:22-cv-00105-ADA Document 38 Filed 04/29/22 Page 16 of 29
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`
`
`substantially similar process steps, including process steps for creating regions with graded dopant
`
`concentrations. Upon information and belief, the Micron flash memory products are in relevant
`
`part substantially similar to the exemplary Micron 16 nm node NAND flash memory shown in
`
`Exhibit 10, particularly with regard to the manner in which the exemplary Micron 16 nm node
`
`flash memory includes and utilizes regions with graded dopant concentrations. Exhibit 10 is thus
`
`illustrative of the manner in which Dell-Micron Accused Products meet the claim limitations of
`
`the Greenthread Patents.
`
`67.
`
`Upon information and belief, Dell has 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 Dell-Micron Accused Products.
`
`68.
`
`For example, Dell’s website states that numerous Dell PCs incorporate Micron
`
`SSDs:25
`
`69.
`
`The Dell-Micron Accused Products include Precision Fixed Workstations,
`
`
`
`Precision Mobile Workstations, Latitude, Optiplex, XPS Desktops, XPS Notebooks, Vostro
`
`
`25 https://www.dell.com/support/kbdoc/en-nz/000126687/micron-2200s-pcie-nvme-ssds-exhibit-
`intermittent-bsod-and-drive-detection-errors
`
`
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`Case 6:22-cv-00105-ADA Document 38 Filed 04/29/22 Page 17 of 29
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`
`
`Desktops, Inspiron Desktops, Inspiron Netbooks, Alienware Desktops, and Alienware Notebooks.
`
`C. Dell-WD Accused Products
`
`70.
`
`Dell-WD Accused Products include all Dell Products containing or comprising
`
`flash memory designed or manufactured (in whole or in part) by Western Digital Corporation,
`
`Western Digital Technologies, Inc., HGST, Inc., SanDisk LLC, SanDisk Holdings LLC, SanDisk
`
`Technologies LLC and/or their affiliates (“Western Digital” or “WD”) regardless of how such
`
`products are branded. Flash memory products include SSDs, microSD/SD cards, and thumb
`
`drives.
`
`71.
`
`As shown in Exhibit 11, the SanDisk 15 nm 16 GB NAND flash memory meets
`
`each and every element of at least one claim of the Greenthread Patents.
`
`72.
`
`Upon information and belief, WD fabricates and designs flash memory 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. Upon information and belief, WD flash memory products are in relevant part
`
`substantially similar to the exemplary SanDisk 15 nm 16 GB NAND flash memory shown in
`
`Exhibit 11, in particular with regard to the manner in which the exemplary SanDisk 15 nm 16 GB
`
`NAND flash memory includes and utilizes regions with graded dopant concentrations. Exhibit 11
`
`is thus illustrative of the manner in which Dell-WD Accused Products meet the claim limitations
`
`of the Greenthread Patents.
`
`73.
`
`Upon information and belief, Dell has 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 Dell-WD Accused Products.
`
`74.
`
`For example, Dell’s website advertises dozens of Dell-WD Accused Products.
`
`
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`17
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`
`
`Case 6:22-cv-00105-ADA Document 38 Filed 04/29/22 Page 18 of 29
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`
`
`
`
`75.
`
`An exemplary list of Dell-WD Accused Products is identified in Exhibit 8.
`
`Greenthread reserves the right to amend its list of Dell-WD Accused Products, including based on
`
`information learned in discovery.
`
`D. Dell-Sony Accused Products
`
`76.
`
`Dell-Sony Accused Products include all Dell Products containing or comprising
`
`image sensors designed or manufactured (in whole or in part) by Sony Corporation, Sony
`
`Semiconductor Solutions, Sony Global Manufacturing & Operations, Sony Electronics Inc., Sony
`
`Corporation of America or their affiliates (“Sony”) regardless of how such products are branded.
`
`77.
`
`As shown in Exhibit 12, an exemplary Sony image sensor meets each and every
`
`element of at least one claim of certain of the Greenthread Patents.
`
`78.
`
`Upon information and belief, Sony fabricates and designs image sensors 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. Upon information and belief, Sony image sensors are in relevant p