Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 1 of 36
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`GREENTHREAD, LLC
`
`
`Plaintiff,
`
`
`
`
`
`
`
`Civil Action No. 6:22-cv-105-ADA
`
`vs.
`
`
`
`JURY TRIAL DEMANDED
`
`DELL INC., DELL TECHNOLOGIES INC.;
`SONY GROUP CORPORATION, SONY
`SEMICONDUCTOR SOLUTIONS CORP.,
`SONY SEMICONDUCTOR
`MANUFACTURING CORP., SONY MOBILE
`COMMUNICATIONS, INC., SONY
`INTERACTIVE ENTERTAINMENT INC.,
`SONY INTERACTIVE ENTERTAINMENT
`LLC., SONY CORPORATION OF AMERICA,
`AND SONY ELECTRONICS INC.
`
`Defendants.
`
`
`
`
`
`
`SECOND AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Greenthread, LLC (“Greenthread” or “Plaintiff”) files this Second Amended
`
`Complaint against Sony Group Corporation, Sony Semiconductor Solutions Corporation, Sony
`
`Semiconductor Manufacturing Corporation, Sony Mobile Communications, Inc., Sony Interactive
`
`Entertainment Inc., Sony Interactive Entertainment LLC., Sony Corporation of America, and Sony
`
`Electronics (collectively “Sony” or “Sony Defendants”), and Dell Inc. and Dell Technologies Inc.
`
`(collectively, “Dell,” or “Dell Defendants,” and together with Sony, “Defendants”) pursuant to
`
`Local Rule CV-15, and hereby alleges as follows:
`
`THE NATURE OF THE ACTION
`
`1.
`
`Greenthread owns a family of patents related to transistors and other components
`
`of integrated semiconductor devices. Greenthread’s patented inventions describe semiconductor
`
`
`
`1
`
`Greenthread Ex 2009, p.1 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 2 of 36
`
`devices that employ graded dopants and well regions for creating electric fields for aiding and/or
`
`limiting the movement of carriers to (or from) the semiconductor surface to (or from) the
`
`semiconductor substrate. These inventions improve semiconductor devices by (1) creating faster,
`
`more efficient, and more reliable processors, logic devices, DRAM and NAND flash, and image
`
`sensors and (2) allowing manufacturers to scale down the feature size of their semiconductor
`
`products.
`
`2.
`
`Defendants have infringed and continue to infringe six Greenthread patents: U.S.
`
`Patent Nos. 8,421,195 (the “’195 Patent”), 9,190,502 (the “’502 Patent”), 10,510,842 (the “’842
`
`Patent”), 10,734,481 (the “’481 Patent”), 11,121,222 (the “’222 Patent”), and 11,316,014 (the
`
`“’014 Patent”), (collectively “the Greenthread Patents”), copies of which are attached hereto as
`
`Exhibits 1-7, respectively. Defendants have infringed and continue to infringe the Greenthread
`
`Patents by:
`
`making, using, selling, offering for sale, and/or importing into the United
`a.
`States, semiconductor devices with infringing graded dopant regions and/or
`electronic products containing the same;
`incorporating or using the above-described semiconductor devices into
`b.
`electronic products such as laptop computers, desktop computers, and mobile
`workstations.
`
`THE PARTIES
`
`3.
`
`Plaintiff Greenthread, LLC (“Greenthread”) is a limited liability company
`
`organized and existing under the laws of Texas, having its principal place of business at 7424
`
`Mason Dells Drive, Dallas, Texas 75230-3244.
`
`4.
`
`Defendant Sony Semiconductor Solutions Corporation is a corporation organized
`
`and existing under the laws of Japan with its headquarters at 4-14-1 Asahi-cho, Atsugi-shi,
`
`Kanagawa, Japan.
`
`5.
`
`Defendant Sony Semiconductor Manufacturing Corporation is a corporation
`
`
`
`2
`
`Greenthread Ex 2009, p.2 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 3 of 36
`
`organized and existing under the laws of Japan with its headquarters at 4000-1 Haramizu,
`
`Kikuyomachi, Kikuchi-gun 869-1102, Japan.
`
`6.
`
`Defendant Sony Group Corporation is a corporation organized and existing under
`
`the laws of Japan with its headquarters at 1-7-1 Konan Minato-ku, Tokyo, 108-0075 Japan.
`
`7.
`
`Defendant Sony Mobile Communications, Inc. is a corporation organized and
`
`existing under the laws of Japan with its headquarters at 1-7-1 Konan Minato-ku, Tokyo, 108-
`
`0075, Japan.
`
`8.
`
`Defendant Sony Interactive Entertainment Inc. is a corporation organized and
`
`existing under the laws of Japan with its principal place of business at 1-7-1 Konan Minato-ku,
`
`Tokyo, 108-0075, Japan.
`
`9.
`
`Defendant Sony Interactive Entertainment LLC is a limited liability company
`
`organized and existing under the laws of the state of California.
`
`10.
`
`Defendant Sony Corporation of America is a corporation organized and existing
`
`under the laws of the state of New York.
`
`11.
`
`Defendant Sony Electronics Inc. is a corporation organized and existing under the
`
`laws of Delaware.
`
`12.
`
`On information and belief, Sony owns and controls the internet domains
`
`“sony.com” and “playstation.com.” Sony—upon information and belief—has a regular and
`
`established place of business in this District at 5000 Plaza on the Lake, Suite 350, Austin, Texas
`
`78746. Sony further advertises job postings for this District, including positions for a Software
`
`Development Engineer and a Data Center Integration Services Manager.
`
`13.
`
`Defendant in a related matter, Intel Corporation (“Intel”) is a corporation organized
`
`and existing under the laws of the state of Delaware.
`
`
`
`3
`
`Greenthread Ex 2009, p.3 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 4 of 36
`
`14.
`
`15.
`
`16.
`
`On information and belief, Intel owns and controls the internet domain “intel.com.”
`
`Intel says that it is “proud to call [Austin] Texas home.”1
`
`Defendant Dell Inc. is a corporation organized under the laws of the state of
`
`Delaware, having its principal place of business at One Dell Way, Round Rock, Texas, 78664.
`
`17.
`
`Defendant Dell Technologies Inc. is a corporation organized and existing under the
`
`laws of Delaware, having its principal place of business at One Dell Way, Round Rock, Texas,
`
`78682.
`
`18.
`
`On information and belief, Dell owns and controls the internet domains “dell.com”
`
`and “delltechnologies.com.”
`
`SUBJECT MATTER JURISDICTION
`
`19.
`
`This court has subject matter jurisdiction over the patent infringement claims
`
`asserted in this case under 28 U.S.C. §§ 1331 and 1338(a).
`
`PERSONAL JURISDICTION, VENUE, AND JOINDER
`
`20.
`
`Intel has a regular and established places of business in this District, including at
`
`1300 S. Mopac Expressway, Austin, Texas 78746 and at 9442 N Capital of Texas Hwy, Bldg 2,
`
`Suite 600, Austin, Texas 78759.
`
`21.
`
`22.
`
`Intel is “proud to call [Austin] Texas home.”2
`
`Intel distributes its products through, among others, Intel authorized “original
`
`equipment manufacturers” and Intel authorized “System Manufacturers” as part of the “Intel
`
`Partner Alliance.”3
`
`
`1 https://www.intel.com/content/www/us/en/corporate-responsibility/intel-in-texas.html
`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
`
`Greenthread Ex 2009, p.4 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 5 of 36
`
`23.
`
`Dell is an Intel authorized “System Manufacturer[],”4 an Intel authorized “original
`
`equipment manufacturer,” and a “Titanium” member of the “Intel Partner Alliance.”5
`
`24.
`
`Intel directs persons wishing to transact business with Dell relating to Intel products
`
`(including Intel Accused Products) to contact Dell in this District at 401 Dell Way Round Rock,
`
`TX, 78664.6
`
`25.
`
`Sony—upon information and belief—has a regular and established place of
`
`business in this District at 5000 Plaza on the Lake, Suite 350, Austin, Texas 78746. Sony further
`
`advertises job postings for this District, including positions for a Software Development Engineer
`
`and a Data Center Integration Services Manager.
`
`26.
`
`Dell’s principal place of business is in this District at One Dell Way, Round Rock,
`
`TX 78664.7
`
`27.
`
`“Accused Products” are products accused of meeting the claim limitations of a
`
`Greenthread Patent in this suit.
`
`28.
`
`“Dell Products,” as used herein, means products made, used, offered for sale, or
`
`sold within the United States, and/or imported into the United States by Dell. “Dell Accused
`
`Products” are Dell Products accused of meeting the claim limitations of a Greenthread Patent in
`
`this suit, including Dell-Intel Accused Products (defined below), the Dell-Micron Accused
`
`Products (defined below), the Dell-WD Accused Products (defined below), and the Dell-Sony
`
`Accused Products (defined below).
`
`
`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
`
`
`
`5
`
`Greenthread Ex 2009, p.5 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 6 of 36
`
`29.
`
`“Sony Products,” as used herein, means products made, used, offered for sale, or
`
`sold within the United States, and/or imported into the United States by Sony. “Sony Accused
`
`Products” are Sony Products accused of meeting the claim limitations of a Greenthread Patent in
`
`this suit, including Dell-Sony Accused Products (defined below).
`
`30.
`
`Exhibit 8 demonstrating how exemplary Dell-Intel Accused Products, Dell-Micron
`
`Accused Products, Dell-WD Accused Products, and Dell-Sony Accused Products and Sony
`
`Accused Products meet the claim limitations of Greenthread Patents are herein incorporated by
`
`reference.
`
`31.
`
`Dell’s online retail store at Dell.com sells, offers for sale, and advertises Accused
`
`Products for sale in this District, including the accused exemplary Dell Alienware M15 R6 laptop
`
`containing the accused exemplary Intel Core i7 11800H and certain Sony Accused Products.8
`
`32.
`
`On information and belief, Dell’s online retail store at Dell.com, from which it sells
`
`Dell Accused Products, is controlled by Dell from Dell’s facilities in this District.
`
`33.
`
`Best Buy is an authorized Dell retailer9 selling and offering for sale Accused
`
`Products10 (including Dell-Intel Accused Products containing the exemplary Intel Core i7
`
`11800H),11 in this District, including at 9607 Research Blvd. Suite 500, Austin, TX 78759.
`
`34.
`
`Intel approves and authorizes sales of Dell Products through Best Buy.12
`
`
`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
`
`
`
`6
`
`Greenthread Ex 2009, p.6 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 7 of 36
`
`35.
`
`Costco is an authorized Dell retailer selling and offering for sale Accused Products
`
`(including Dell-Intel Accused Products containing the exemplary Intel Core i7 11800H)13 in this
`
`District, including at 10401 Research Blvd, Austin, TX 78759.14
`
`36.
`
`Sony authorizes and approves sales in the United States of Sony Accused Products
`
`in this district through among other outlets, Sony.com, playstation.com, Dell.com, Apple.com, and
`
`Best Buy.
`
`37.
`
`Sony has authorized sellers and sales representatives that offer and sell products
`
`pertinent to this Complaint in this District, including, but not limited to, Best Buy (4627 Jack
`
`Kultgen Expressway, Waco, Texas 76706), GameStop (1428 Wooded Acres Drive, Suite 204,
`
`Waco, Texas 76710), and Apple Store (3121 Palm Way, Austin, TX 78758 and 2901 S Capital of
`
`Texas Highway, Austin, Texas 78746).
`
`38.
`
`This Court has personal jurisdiction over Defendants in accordance with the Texas
`
`Long Arm Statute, Tex. Civ. Prac. & Rem. Code § 17.042, because, among other things,
`
`Defendants have contracted with Texas residents to sell Accused Products in Texas (including
`
`Defendants’ agreements for Intel to sell Intel Accused Products to Dell), committed other acts of
`
`infringement in Texas, and recruited Texas residents for employment.
`
`39.
`
`This Court has general personal jurisdiction over Defendants because Dell’s
`
`principal place of business is in this District and Intel claims to be at “home”15 in this District.
`
`40.
`
`This Court has specific personal jurisdiction over Defendants because they have
`
`committed acts within this District giving rise to this action (including acts of infringement) and
`
`
`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
`
`
`
`7
`
`Greenthread Ex 2009, p.7 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 8 of 36
`
`have established minimum contacts with this forum such that the exercise of jurisdiction over
`
`Defendants would not offend traditional notions of fair play and substantial justice.
`
`41.
`
`Venue is proper in this Court for the Dell Defendants pursuant to 28 U.S.C. §§ 1391
`
`and 1400(b) because the Dell Defendants reside in this District, have regular and established places
`
`of business in this district, and have committed acts of infringement in this district.
`
`42.
`
`Defendants Sony Semiconductor Solutions Corporation, Sony Semiconductor
`
`Manufacturing Corporation, Sony Group Corporation, Sony Mobile Communications, Inc. and
`
`Sony Interactive Entertainment Inc. are not residents in the United States and venue is therefore
`
`proper under 28 U.S.C. § 1391(c)(3). Further, Sony has committed acts of infringement in this
`
`district, including by selling Dell-Sony Accused Products to Dell in this District.
`
`43.
`
`Venue is proper for Defendants Sony Interactive Entertainment LLC, Sony
`
`Corporation of America, and Sony Electronics Inc. pursuant to 28 U.S.C. §§ 1391 and 1400(b)
`
`because Sony has a regular and established place of business in this District and has committed
`
`acts of infringement in this District.
`
`44.
`
`Joinder of Defendants is proper under 35 U.S.C. § 299, because Greenthread’s right
`
`to relief arises from the same transactions or occurrences regarding the same Accused Products
`
`(such as Intel’s sale of Intel Accused Products to Dell) and questions of fact common to all
`
`Defendants will arise in this action.
`
`THE GREENTHREAD PATENTS
`
`45.
`
`On April 16, 2013, the U.S. Patent and Trademark Office duly and legally issued
`
`U.S. Patent No. 8,421,195 (“the ’195 Patent”), entitled “Semiconductor Devices with Graded
`
`Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed January
`
`
`
`8
`
`Greenthread Ex 2009, p.8 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 9 of 36
`
`12, 2007. The ’195 Patent claims priority from U.S. Patent Application No. 10/934,915,16 filed on
`
`September 3, 2004. A true and correct copy of the ’195 Patent is attached hereto as Exhibit 1 and
`
`incorporated herein by reference.
`
`46.
`
`On November 17, 2015, the U.S. Patent and Trademark Office duly and legally
`
`issued U.S. Patent No. 9,190,502 (“the ’502 Patent”), entitled “Semiconductor Devices with
`
`Graded Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed
`
`October 16, 2014. The ’502 Patent claims priority from U.S. Patent Application No. 10/934,915,17
`
`filed on September 3, 2004. A true and correct copy of the ’502 Patent is attached hereto as Exhibit
`
`2 and incorporated herein by reference.
`
`47.
`
`On December 17, 2019, the U.S. Patent and Trademark Office duly and legally
`
`issued U.S. Patent No. 10,510,842 (“the ’842 Patent”), entitled “Semiconductor Devices with
`
`Graded Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed
`
`on May 9, 2017. The ’842 Patent claims priority from U.S. Patent Application No. 10/934,915,18
`
`filed on September 3, 2004. A true and correct copy of the ’842 Patent is attached hereto as Exhibit
`
`3 and incorporated herein by reference.
`
`48. On August 4, 2020, the U.S. Patent and Trademark Office duly and legally issued
`
`U.S. Patent No. 10,734,481 (“the ’481 Patent”), entitled “Semiconductor Devices with Graded
`
`Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed on
`
`December 17, 2019. The ’481 Patent claims priority from U.S. Patent Application No.
`
`10/934,915,19 filed on September 3, 2004. A true and correct copy of the ’481Patent is attached
`
`
`16 Pub. No. US 2006/0049464.
`17 Pub. No. US 2006/0049464.
`18 Pub. No. US 2006/0049464.
`19 Pub. No. US 2006/0049464.
`
`
`
`9
`
`Greenthread Ex 2009, p.9 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 10 of 36
`
`hereto as Exhibit 4 and incorporated herein by reference.
`
`49.
`
`On September 14, 2021, the U.S. Patent and Trademark Office duly and legally
`
`issued U.S. Patent No. 11,121,222 (“the ’222 Patent”), entitled “Semiconductor Devices with
`
`Graded Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed
`
`on July 27, 2020. The ’222 Patent claims priority from U.S. Patent Application No. 10/934,915,20
`
`filed on September 3, 2004. A true and correct copy of the ’222 Patent is attached hereto as Exhibit
`
`5 and incorporated herein by reference.
`
`50.
`
`On April 26, 2022, the U.S. Patent and Trademark Office duly and legally issued
`
`U.S. Patent No. 11,316,014 (“the ‘014 Patent”), entitled “Semiconductor Devices with Graded
`
`Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed on July 9,
`
`2021. The ‘014 Patent claims priority from U.S. Patent Application No. 10/934,915,21 filed on
`
`September 3, 2004. A true and correct copy of the ‘014 Patent is attached hereto as Exhibit 6 and
`
`incorporated herein by reference.
`
`51.
`
`The ’195, ’502, ’842, ’481, ’222, and ’014 Patents are collectively referred to as
`
`the “Greenthread Patents.”
`
`52.
`
`Greenthread exclusively owns all rights, title, and interest in the Greenthread
`
`Patents necessary to bring this action, including the right to recover past and future damages.
`
`Certain of the Greenthread Patents were previously owned by Dr. G.R. Mohan Rao (“Dr. Rao”).
`
`On April 27, 2015, Dr. Rao assigned to Greenthread the then-issued Greenthread Patents and all
`
`related “continuations, continuations-in-part and extensions of said Applications and Patents and
`
`any pending applications or issued patents that directly claim or are amended to claim priority to
`
`
`20 Pub. No. US 2006/0049464.
`21 Pub. No. US 2006/0049464.
`
`
`
`10
`
`Greenthread Ex 2009, p.10 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 11 of 36
`
`any of the Applications or Patents.” Dr. Rao’s assignment was recorded with the U.S. Patent and
`
`Trademark Office on May 13, 2015, and again on July 22, 2021, and is attached hereto as Exhibit
`
`7. Greenthread has therefore owned all rights to the Greenthread Patents necessary to bring this
`
`action throughout the period of Dell’s and Intel’s infringement and still owns those rights to the
`
`Greenthread Patents.
`
`53.
`
`54.
`
`Dell and Intel are not currently licensed to practice the Greenthread Patents.
`
`The Greenthread Patents are valid and enforceable.
`
`FACTUAL BACKGROUND
`
`55.
`
`Dr. G.R. Mohan Rao (“Dr. Rao”), the sole inventor of the Greenthread Patents, has
`
`been an innovator in the semiconductor industry since the 1960s. He is a named inventor on more
`
`than 100 Patents worldwide and authored numerous technical publications over the last 50 years.
`
`56.
`
`In September 1968, Dr. Rao received a Ph.D. in physics with a specialization in
`
`electronics from Andhra University in Waltair, India. He then traveled to the United States to
`
`attend a graduate program in physics at the University of Cincinnati.
`
`57.
`
`After learning of an opportunity to work with Professor William Carr of Southern
`
`Methodist University (“SMU”), Dr. Rao transferred to SMU where he earned a Ph.D in Electrical
`
`Engineering. While there, he worked in the SMU laboratory with Jack Kilby of Texas Instruments
`
`(a pioneering electrical engineer who would later receive a Nobel Prize for his work), on metal-
`
`oxide-silicon transistors (“MOS devices”), which are used for switching and amplifying electronic
`
`signals in electronic devices. MOS devices form the basis of modern electronics and are the most
`
`widely used semiconductor devices in the world. The U.S. Patent and Trademark Office has called
`
`this device a “groundbreaking invention that transformed life and culture around the world.”22 Dr.
`
`
`22 https://www.uspto.gov/about-us/news-updates/remarks-director-iancu-2019-international-
`intellectual-property-conference
`
`
`
`11
`
`Greenthread Ex 2009, p.11 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 12 of 36
`
`Rao built these devices from scratch while a graduate student at SMU.
`
`58.
`
`Through his mentor, Jack Kilby, Dr. Rao interviewed with—and was ultimately
`
`hired by—Texas Instruments to continue his work on MOS devices in 1972. Dr. Rao worked at
`
`Texas Instruments for the next twenty-two years, rising from an engineer to a Senior Fellow. At
`
`that time, Texas Instruments had only 12 Senior Fellows out of approximately 20,000 engineers.
`
`Eventually, Dr. Rao moved into a management position at Texas Instruments, ultimately becoming
`
`a Senior Vice President in 1985.
`
`59.
`
`At Texas Instruments, Dr. Rao received his first patent while working in a process
`
`and product engineering capacity to solve a production problem with Texas Instruments’ 4-kilobit
`
`RAM product. That patent was merely the beginning of Dr. Rao’s long inventive career. Indeed,
`
`from the late 1970s through the mid-1980s, Dr. Rao worked on or managed projects relating to
`
`Texas Instruments’ 64kb RAM, 256Kb RAM, 1Mb RAM, 4 Mb RAM, EEPROM, SRAM, and
`
`microcontrollers. For that work, Dr. Rao received numerous additional U.S. Patents.
`
`60.
`
`The USPTO was not the only organization to recognize Dr. Rao’s achievements.
`
`Some of Dr. Rao’s work at Texas Instruments was so remarkable that it has been credited in
`
`multiple exhibits in the National Museum of American History at the Smithsonian Institution.23
`
`For example, the Smithsonian has displayed Texas Instruments’ experimental 1-megabit CMOS
`
`DRAM, produced in April 1985 under Dr. Rao’s leadership, and credited Dr. Rao for the
`
`achievement.24
`
`
`23 http://smithsonianchips.si.edu/texas/wafer.htm
`24 http://smithsonianchips.si.edu/texas/t_360.htm
`
`
`
`12
`
`Greenthread Ex 2009, p.12 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 13 of 36
`
`
`In 1994, Dr. Rao left Texas Instruments for Cirrus Logic. During his two-year
`
`61.
`
`tenure at Cirrus Logic, he received more U.S. Patents relating to his work on integrated graphics
`
`controllers and memory.
`
`62.
`
`In 1996, Dr. Rao started a company called Silicon Aquarius. Through a relationship
`
`between Silicon Aquarius and Matsushita, Dr. Rao led a design team in working on a 256Mb
`
`DRAM chip. After Silicon Aquarius ceased operations, Dr. Rao did consulting work for a number
`
`of different consulting companies and devoted much of his free time to thinking about various
`
`challenges and problems with which the semiconductor industry had struggled for years.
`
`63.
`
`In 2003, Dr. Rao and Philip John founded Greenthread to continue Dr. Rao’s
`
`pioneering work. A focal point of Dr. Rao’s research was poor refresh time and the related
`
`problem of how to deal with and control the movement of both wanted and unwanted carriers in
`
`semiconductor devices, including memory and logic devices. Dr. Rao realized that graded dopants
`
`
`
`13
`
`Greenthread Ex 2009, p.13 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 14 of 36
`
`could be used to create a “drift layer” and other structures to facilitate the movement—in an
`
`upward or downward direction, as appropriate—of carriers from the semiconductor surfaces down
`
`into the substrate and vice versa. It was Dr. Rao’s work on this problem that culminated in the
`
`Greenthread Patents.
`
`INTEL’S INFRINGEMENT
`
`64.
`
`Intel has directly infringed, and continues to infringe, one or more claims of each
`
`of the Greenthread Patents through making, using, offering to sell, selling within the United States,
`
`and/or importing into the United States semiconductor products that practice the claimed
`
`inventions, including Intel Accused CPUs and Intel Accused Flash Memory Products (“Intel
`
`Accused Products”).
`
`A. Intel Accused CPUs
`The Intel Accused CPUs include all CPUs designed or manufactured (in whole or
`65.
`
`in part) by Intel, including Intel’s 12th generation of semiconductors labeled as “Alder Lake,”
`
`Intel’s 11th generation of semiconductors labeled as “Tiger Lake,” and Intel’s 10th generation of
`
`semiconductors labeled as “Comet Lake.” An exemplary list of Intel Accused CPUs is identified
`
`in Exhibit 8.
`
`66.
`
`As shown in Exhibit 8 the Intel Core i7 11800H CPU meets each and every element
`
`of at least one claim of the Greenthread Patents.
`
`67.
`
`Upon information and belief, Intel fabricates CPUs 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, the Intel Accused CPUs are in relevant part substantially similar to the exemplary Intel
`
`Core i7 11800H, in particular with regard to the manner in which the exemplary Intel Core i7
`
`
`
`14
`
`Greenthread Ex 2009, p.14 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 15 of 36
`
`11800H includes and utilizes regions with graded dopant concentrations. Exhibit 8 is thus
`
`illustrative of the manner in which each of the Intel Accused CPUs infringes.
`
`68.
`
`Greenthread reserves the right to amend its list of Intel Accused Products, including
`
`based on information learned in discovery.
`
`B. Intel Accused Flash Memory Products
`Intel Accused Flash Memory Products include all flash memory products designed
`69.
`
`or manufactured (in whole or in part) by Intel. Flash memory products include solid state drives
`
`(“SSDs”), microSD/SD cards, and thumb drives.
`
`70.
`
`As shown in Exhibit 8 the Micron 16 nm node NAND flash memory meets each
`
`and every element of at least one claim of the Greenthread Patents.
`
`71.
`
`The exemplary Micron 16 nm node NAND flash memory analyzed in Exhibit 8
`
`bears Intel Die markings and was manufactured by Intel.
`
`72.
`
`Upon information and belief, Intel designs and/or fabricates flash memory products
`
`
`
`
`
`15
`
`Greenthread Ex 2009, p.15 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 16 of 36
`
`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.
`
`73.
`
`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 8, in particular with regard to the manner in which the exemplary flash memory
`
`product includes and utilizes regions with graded dopant concentrations. Exhibit 8 is thus
`
`illustrative of the manner in which each of the Intel Accused Flash Memory Products.
`
`74.
`
`Greenthread reserves the right to amend its list of Intel Accused Products, including
`
`based on information learned in discovery.
`
`SONY’S INFRINGEMENT
`
`75.
`
`Greenthread incorporates by reference the preceding paragraphs as though fully set
`
`forth herein. Greenthread further incorporates by reference Exhibit 8, which further details Sony’s
`
`infringement for each category of Accused Products identified below. As described below Sony
`
`infringes the Greenthread Patents by making, using, offering to sell, selling within the United
`
`States, and/or importing into the United States the Sony Accused Products, and or inducing others
`
`to do the same. Sony does so willfully.
`
`76.
`
`Sony Accused Products include all Sony Products containing or comprising Sony
`
`Accused Transistors (“Sony Accused Transistor Products”) or Sony Accused Image Sensors
`
`(“Sony Accused Image Sensor Products”). Sony Accused Transistors include all Sony Products
`
`containing or comprising transistors designed or manufactured (in whole or in part) by Sony or its
`
`affiliates regardless of how such products are branded. Sony Accused Image Sensors include all
`
`Sony Products containing or comprising image sensors designed or manufactured (in whole or in
`
`
`
`16
`
`Greenthread Ex 2009, p.16 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 17 of 36
`
`part) by Sony or its affiliates regardless of how such products are branded.
`
`77.
`
`As shown in Exhibit 8, an exemplary Sony image sensor meets each and every
`
`element of at least one claim of certain of the Greenthread Patents.
`
`78.
`
`As shown in Exhibit 8, an exemplary Sony transistor meets each and every element
`
`of at least one claim of the Greenthread Patents.
`
`79.
`
`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 part substantially
`
`similar to the exemplary image sensor shown in Exhibit 8, in particular with regard to the manner
`
`in which the exemplary image sensor includes and utilizes regions with graded dopant
`
`concentrations. Exhibit 8 is thus illustrative of the manner in which Dell-Sony Accused Products
`
`meet the claim limitations of the Greenthread Patents.
`
`80.
`
`As shown in Exhibit 8 Sony Accused Image Sensor Products contain Sony Accused
`
`Transistors. Therefore, Sony Accused Image Sensor Products are also Sony Accused Transistor
`
`Products and practice each and every claim element of the Greenthread Patents based on their use
`
`of Sony Accused Transistors.
`
`81.
`
`Upon information and belief, Sony fabricates and designs transistors 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 transistors are in relevant part substantially
`
`similar to the exemplary transistors shown in Exhibit 8, in particular with regard to the manner in
`
`which the exemplary transistors includes and utilizes regions with graded dopant concentrations.
`
`
`
`17
`
`Greenthread Ex 2009, p.17 of 36
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 6:22-cv-00105-ADA Document 120 Filed 01/23/23 Page 18 of 36
`
`Exhibit 8 is thus illustrat