Case 2:23-cv-00212-JRG Document 1 Filed 05/10/23 Page 1 of 24 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`
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`GREENTHREAD, LLC
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`Plaintiff,
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`vs.
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`
`
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`Civil Action No. 2:23-cv-212
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`
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`OMNIVISION TECHNOLOGIES INC.,
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`JURY TRIAL DEMANDED
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`Defendant.
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`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff Greenthread, LLC (“Greenthread” or “Plaintiff”) files this Original Complaint
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`against OmniVision Technologies Inc., (“OmniVision” or “Defendant”) and hereby alleges as
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`follows:
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`THE NATURE OF THE ACTION
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`1.
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`This is a patent infringement action. Two related actions are pending in this court
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`for infringement of the same patents: Greenthread, LLC v. OSRAM GMBH et al., 23-cv-00179-
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`JRG (E.D. Tex.) and Greenthread, LLC v Texas Instruments Incorporated, 23-cv-00157-JRG
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`(E.D. Tex.). This Court has already construed the claims of the patents-in-suit and/or patents of
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`the same family in Greenthread, LLC v. Samsung Electronics Co., Ltd. et al., 19-cv-00147-JRG
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`(E.D. Tex.). See Dkt. 67.
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`2.
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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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`1
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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, and image sensors; and (2) allowing
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`manufacturers to scale down the feature size of their semiconductor products.
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`3.
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`Defendant has infringed and continues to infringe six 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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`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 1-6, respectively. Defendant has infringed and continue to infringe the Greenthread
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`Patents by making, using, selling, offering for sale, and/or importing into the United States,
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`semiconductor devices with infringing graded dopant regions and/or electronic products
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`containing the same.
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`THE PARTIES
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`4.
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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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`5.
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`Defendant OmniVision Technologies, Inc. is a corporation organized and existing
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`under the laws of Delaware. Defendant may be served with process by serving its registered agent,
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`the Corporation Trust Company, at 1209 Orange Street, Wilmington, Delaware, 19801.
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`6.
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` OmniVision designs and develops digital imaging products for use in mobile
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`phones, security & surveillance, automotive, computing, medical, and emerging applications.
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`OmniVision describes itself as a “global fabless semiconductor organization” who has “enabled
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`smoother human/machine interfacing solutions within the automotive, medical, security &
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`2
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`surveillance, computing, mobile phone, and emerging technology spaces.”1
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`7.
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`8.
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`OmniVision controls the www.ovt.com internet domain.
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`OmniVision designs, tests, imports into the United States, uses, sells, and offers to
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`sell OmniVision Accused Products, which occurs in the United States. OmniVision has employees
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`throughout the United States including responsible for these functions, including in Texas,
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`California, Colorado, Illinois, and Michigan.2
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`9.
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`During Omnivision’s markeing, testing, and quality control, OmniVision uses and
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`sells sample products of the Omnivision Accused Products in the United States.3 Those uses of
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`the OmniVision Accused Products are essential to its ability to make sales to customers world-
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`wide, including in the United States.
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`
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`1 https://www.ovt.com/company/about-us/
`2 https://www.ovt.com/company/contact-us/
`3 https://www.ovt.com/partners/
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`
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`3
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`10.
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`Further, OmniVision partners with United States authorized distributors to sell
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`OmniVision Accused Products in the United States and directs potential U.S. consumers to
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`purchase OmniVision products through these U.S. distributors and “representatives” on its
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`website.4
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`4 See, e.g., https://www.ovt.com/contact-sales/distribution-channels; see also
`https://www.arrow.com/en/manufacturers/omnivision-technologies/view-all
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`4
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`11.
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`OmniVision sells OmniVision Accused Products in the United States through its
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`distributors on OmniVision-branded product pages.
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`
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`12.
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`OmniVision’s U.S.-based employees include personnel responsible for sales of
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`OmniVision Accused Products to the U.S. automotive industry.
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`13.
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`OmniVision maintains an office in this district at 1255 W. 15th Street, Suite 370
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`Plano, TX 75075-4216. On information and belief, OmniVision uses its Plano office to serve and
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`make infringing sales of the Accused Products to its customer Texas Instruments Inc. (“Texas
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`Instruments”) in this district.5
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`5
`https://www.ti.com/about-ti/company/ti-at-a-glance/manufacturing/richardson.html#more-
`information
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`
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`5
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`14.
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`Texas Instruments incorporates OmniVision Accused Products into its products,
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`including, on information and belief at Texas Instruments facilities in this district.
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`15.
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`For example, Texas Instruments markets an “Automotive 1.3-MP Low-Cost
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`Camera Module Reference Design With YUV422, PMIC, FPD-Link III, and POC” which includes
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`6
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`an OmniVision Accused Product, a “1.3-MP OX01F10 image sensor from Omnivision.”6
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`16.
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`For example, Texas Instruments also markets a “Low-Power Wireless Camera
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`Reference Design for Extended Battery Life” stating that it includes an OmniVision Accused
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`Product: “This design utilizes the OmniVision OA7000 to enable secured live video streaming
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`with a resolution of up to 1080p at 48 FPS (1920 × 1080).”7
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`6 https://www.ti.com/lit/ug/tidubf0/tidubf0.pdf?ts=1683552290038
`7https://www.ti.com/lit/ug/tiduez4/tiduez4.pdf?ts=1683652725026&ref_url=https%253A%252F
`%252Fwww.google.com%252F
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`7
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`17.
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`For example, Texas Instruments also markets a “ADAS 8-Channel Sensor Fusion
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`Hub Reference Design With Two 4-Gbps Quad Deserializers” which is “built around … an
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`OmniVision OV2775 imager,” which is an OmniVision Accused Product.
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`SUBJECT MATTER JURISDICTION
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`18.
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`This action arises under the patent laws of the United States, namely 35 U.S.C.
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`§§ 271, 281, and 284-285, among others.
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`19.
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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 AND VENUE
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`20.
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`This Court has specific personal jurisdiction over Defendant because it has
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`committed acts within this District giving rise to this action (including acts of infringement) and
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`has established minimum contacts with this forum such that the exercise of jurisdiction over
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`Defendant would not offend traditional notions of fair play and substantial justice. Such acts
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`include selling, offering to sell, demonstrating, and marketing OmniVision Accused Products to
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`Texas Instruments in this district.
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`21.
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`Venue is proper under 28 U.S.C. §§ 1391(b) and 1400(b), because OmniVision has
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`a regular and established place of business in this district, including at 1255 W. 15th Street, Suite
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`370 Plano, TX 75075-4216 and has committed acts of infringement in this district, including sales
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`to Texas Instruments.
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`8
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`22.
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`This Court has personal jurisdiction over OmniVision 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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`OmniVision has (1) committed acts of infringement in Texas, including, on information and belief,
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`selling, offering to sell, and demonstrating OmniVision Accused Products in Texas, including to
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`Texas Instrument, and (2) recruited Texas residents for employment, including at OmniVision’s
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`facility in Plano Texas.
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`23.
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`“OmniVision Accused Products” are products accused of meeting the claim
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`limitations of a Greenthread Patent in this suit. OmniVision designs, manufactures, sells, and uses
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`semiconductor devices containing transistors and other structures that infringe the Greenthread
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`Patents in the United States.
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`24.
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`The infringing structures within semiconductor devices identified in Exhibit 8 have
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`application, not only in the product identified in Exhibit 8 (OV24A1Q), but in many types of
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`devices designed and manufactured by OmniVision, including image sensors, ASICs,
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`CameraCubeChip®, LCOS, power management, touch & display, OVMed® ISP, and OVMed®
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`cable module devices.8 To obtain the benefits of the claimed technology, on information and
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`belief, OmniVision incorporates the infringing structures similar to those described in Exhibit 8
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`into transistors in its other products, including ASICs, CameraCubeChip®, LCOS, power
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`management, touch & display, OVMed® ISP, and OVMed® cable module devices. The
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`infringement described in Exhibit 8 is therefore exemplary of infringement by transistors in other
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`OmniVision products.
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`25.
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`Exhibit 8 demonstrates how exemplary OmniVision Accused Products meet the
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`claim limitations of Greenthread Patents and is herein incorporated by reference.
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`8 https://www.ovt.com/company/about-us/
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`9
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`THE GREENTHREAD PATENTS
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`26.
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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. 10/934,915,9 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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`27.
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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. 10/934,915,10
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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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`28.
`
`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. 10/934,915,11
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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.
`
`29.
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`On August 4, 2020, the U.S. Patent and Trademark Office duly and legally issued
`
`
`9 Pub. No. US 2006/0049464.
`10 Pub. No. US 2006/0049464.
`11 Pub. No. US 2006/0049464.
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`
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`10
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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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`10/934,915,12 filed on September 3, 2004. A true and correct copy of the ’481 Patent is attached
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`hereto as Exhibit 4 and incorporated herein by reference.
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`30.
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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. 10/934,915,13
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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.
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`31.
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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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`2021. The ’014 Patent claims priority from U.S. Patent Application No. 10/934,915,14 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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`32.
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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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`33.
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`Greenthread exclusively owns all rights, title, and interest in the Greenthread
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`12 Pub. No. US 2006/0049464.
`13 Pub. No. US 2006/0049464.
`14 Pub. No. US 2006/0049464.
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`11
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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 Defendant’s infringement and still owns those rights to the
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`Greenthread Patents.
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`34.
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`35.
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`Defendant is 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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`36.
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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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`37.
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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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`38.
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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.”15 Dr.
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`Rao built these devices from scratch while a graduate student at SMU.
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`39.
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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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`40.
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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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`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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`41.
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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.16
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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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`15 https://www.uspto.gov/about-us/news-updates/remarks-director-iancu-2019-international-
`lectual-property-conference
`16 http://smithsonianchips.si.edu/texas/wafer.htm
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`achievement.17
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`In 1994, Dr. Rao left Texas Instruments for Cirrus Logic. During his two-year
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`42.
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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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`43.
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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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`44.
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`In 2003, Dr. Rao and Philip John founded Greenthread to continue Dr. Rao’s
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`17 http://smithsonianchips.si.edu/texas/t_360.htm
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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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`45.
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`Dr. Rao resides in this district.
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`OMNIVISION’S INFRINGEMENT
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`46.
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`OmniVision has directly infringed, and continues to infringe, one or more claims
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`of each of the Greenthread Patents through making, using, offering to sell, selling within the United
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`States, and/or importing into the United States semiconductor products, including OV24A1Q, that
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`practice the claimed inventions (i.e., the OmniVision Accused Products). A non-exhaustive,
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`exemplary list of the types or categories of products or devices that infringe are further identified
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`in Exhibit 8.
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`47.
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`Further, in concert with its authorized distributors and customers, OmniVision
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`causes or induces infringing accused products to be made, used, offered to be sold, sold within the
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`United States, and/or imported into the United States. Omnivision has obtained knowledge of
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`Greenthread’s patents and its infringement at least through the filing of this Complaint.
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`48.
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`As shown in Exhibit 8, the exemplary OmniVision Accused Product, OV24A1Q,
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`meets each and every element of at least one claim of the Greenthread Patents.
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`49.
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`Upon information and belief, OmniVision fabricates and designs the OmniVision
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`Accused Products using similar designs according to a limited number of processes, many or all
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`15
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`of which utilize substantially similar process steps, including process steps for creating regions
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`with graded dopant concentrations, because the invention would have application in those
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`categories of products, for example by improving switching time in transistors in the OmniVision
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`Accused Products. Upon information and belief, the OmniVision Accused Products are in relevant
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`part substantially similar to the exemplary OV24A1Q shown in Exhibit 8, particularly with regard
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`to the manner in which the exemplary OV24A1Q includes and utilizes regions with graded dopant
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`concentrations. Exhibit 8 is thus illustrative of the manner in which the OmniVision Accused
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`Products meet the claim limitations of the Greenthread Patents.18
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`
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`COUNT I: INFRINGEMENT OF U.S. PATENT NO. 8,421,195
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`50.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein.
`
`51.
`
`The following allegations are based on publicly available information and a
`
`
`18 This Court already interpreted and adopted Greenthread’s claim construction in Greenthread,
`LLC v. Samsung Electronics Co., Ltd. et al., Case No. 2:19-cv-00147-JRG (E.D. Tex.). See Dkt.
`67. Multiple other courts have also upheld Greenthread’s construction of the Greenthread Patents
`in related matters. In Greenthread, LLC v. Intel Corp., et al., Case No. 6:22-cv-00105-ADA (W.D.
`Tex.), the Western District of Texas similarly issued a preliminary claim construction order
`adopting Greenthread’s construction. See Dkt. 36-21 in Greenthread, LLC v. Intel Corp., Case No.
`3:22-cv-02001-JR (attaching as an exhibit the Western District of Texas’s preliminary claim
`construction order in a status update before the District of Oregon). The claims in this matter
`against Intel were ultimately severed and transferred to Oregon, and the District of Oregon adopted
`the Western District of Texas’ preliminary claim construction. See Dkt. 44 (“The Court also finds
`that the WDTX’s preliminary constructions and summary judgment rulings are neither legally
`incorrect nor factually distinguishable. As a result, the Court adopts the WDTX’s preliminary
`constructions and summary judgment rulings as its own. . .”). The Western District of Texas also
`denied Defendants’ motions to dismiss and for summary judgment on similar grounds. See Dkt.
`36-22 in Greenthread, LLC v. Intel Corp., Case no. 3:22-cv-02001-JR (attaching as an exhibit the
`Western District of Texas’ denial of Defendants’ motion for summary judgment); Dkt. 110 in
`Greenthread LLC v. Intel Corp., Case No. 6:22-cv-00105-ADA (W.D. Tex.). The District of
`Oregon similarly adopted these rulings. See Dkt. 44 in Greenthread, LLC v. Intel Corp., Case no.
`3:22-cv-02001-JR.
`
`
`
`16
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`Greenthread Ex 2027, p.16 of 24
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`Case 2:23-cv-00212-JRG Document 1 Filed 05/10/23 Page 17 of 24 PageID #: 17
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`reasonable investigation of the structure and operation of the OmniVision Accused Products.
`
`Greenthread reserves the right to modify this description, including, for example, on the basis of
`
`information about the OmniVision Accused Products that it obtains during discovery.
`
`52.
`
`Defendant’s infringement has damaged and continues to damage Greenthread in an
`
`amount yet to be determined, of at least a reasonable royalty.
`
`53.
`
`As alleged above and in Exhibit 8, the products analyzed in Exhibit 8 meet each
`
`and every one of the claim limitations of at least one claim of the ’195 Patent.
`
`54.
`
`As alleged above, the products analyzed in Exhibit 8 are exemplary of the
`
`OmniVision Accused Products.
`
`55.
`
`As alleged above, Defendant has infringed and continue to infringe at least one
`
`claim of the ’195 Patent by making, using, offering to sell, selling within the United States, and/or
`
`importing into the United States OmniVision Accused Products.
`
`56.
`
`As alleged above, Defendant induces infringement of at least one claim of the ’195
`
`Patent by designing and marketing infringing products for sale, use, and importation into the
`
`United States.
`
`57.
`
`Defendant’s infringement has damaged and continues to damage Greenthread in an
`
`amount yet to be determined, of at least a reasonable royalty.
`
`COUNT II: INFRINGEMENT OF U.S. PATENT NO. 9,190,502
`
`
`
`58.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein.
`
`59.
`
`The following allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the OmniVision Accused Products.
`
`Greenthread reserves the right to modify this description, including, for example, on the basis of
`
`
`
`17
`
`Greenthread Ex 2027, p.17 of 24
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`Case 2:23-cv-00212-JRG Document 1 Filed 05/10/23 Page 18 of 24 PageID #: 18
`
`information about the OmniVision Accused Products that it obtains during discovery.
`
`60.
`
`As alleged above and in Exhibit 8, the products analyzed in Exhibit 8 meet each
`
`and every one of the claim limitations of at least one claim of the ’502 Patent.
`
`61.
`
`As alleged above, the products analyzed in Exhibit 8 are exemplary of the
`
`OmniVision Accused Products.
`
`62.
`
`As alleged above, Defendant has infringed and continue to infringe at least one
`
`claim of the ’502 Patent by making, using, offering to sell, selling within the United States, and/or
`
`importing into the United States OmniVision Accused Products.
`
`63.
`
`As alleged above, Defendant induces infringement of at least one claim of the ’502
`
`Patent by designing and marketing infringing products for sale, use, and importation into the
`
`United States.
`
`64.
`
`Defendant’s infringement has damaged and continues to damage Greenthread in an
`
`amount yet to be determined, of at least a reasonable royalty.
`
`COUNT III: INFRINGEMENT OF U.S. PATENT NO. 10,510,842
`
`65.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein.
`
`66.
`
`The following allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the OmniVision Accused Products.
`
`Greenthread reserves the right to modify this description, including, for example, on the basis of
`
`information about the OmniVision Accused Products that it obtains during discovery.
`
`67.
`
`As alleged above and in Exhibits 8, the products analyzed in Exhibit 8 meet each
`
`and every one of the claim limitations of at least one claim of the ’842 Patent.
`
`68.
`
`As alleged above, the products analyzed in Exhibit 8 are exemplary of the
`
`
`
`18
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`Greenthread Ex 2027, p.18 of 24
`Cirrus Logic, et. al. v. Greenthread
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`

`

`Case 2:23-cv-00212-JRG Document 1 Filed 05/10/23 Page 19 of 24 PageID #: 19
`
`OmniVision Accused Products.
`
`69.
`
`As alleged above, Defendant has infringed and continue to infringe at least one
`
`claim of the ’842 Patent by making, using, offering to sell, selling within the United States, and/or
`
`importing into the United States OmniVision Accused Products.
`
`70.
`
`As alleged above, Defendant induces infringement of at least one claim of the ’842
`
`Patent by designing and marketing infringing products for sale, use, and importation into the
`
`United States.
`
`71.
`
`Defendant’s infringement has damaged and continues to damage Greenthread in an
`
`amount yet to be determined, of at least a reasonable royalty.
`
`COUNT IV: INFRINGEMENT OF U.S. PATENT NO. 10,734,481
`
`72.
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein.
`
`73.
`
`The following allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the OmniVision Accused Products.
`
`Greenthread reserves the right to modify this description, including, for example, on the basis of
`
`information about the OmniVision Accused Products that it obtains during discovery.
`
`74.
`
`As alleged above and in Exhibits 8, the products analyzed in Exhibit 8 meet each
`
`and every one of the claim limitations of at least one claim of the ’481 Patent.
`
`75.
`
`As alleged above, the products analyzed in Exhibit 8 are exemplary of the
`
`OmniVision Accused Products.
`
`76.
`
`As alleged above, Defendant has infringed and continue to infringe at least one
`
`claim of the ’481 Patent by making, using, offering to sell, selling within the United States, and/or
`
`importing into the United States OmniVision Accused Products.
`
`
`
`19
`
`Greenthread Ex 2027, p.19 of 24
`Cirrus Logic, et. al. v. Greenthread
`
`

`

`Case 2:23-cv-00212-JRG Document 1 Filed 05/10/23 Page 20 of 24 PageID #: 20
`
`77.
`
`As alleged above, Defendant induces infringement of at least one claim of the ’481
`
`Patent by designing and marketing infringing products for sale, use, and importation into the
`
`United States.
`
`78.
`
`Defendant’s infringement has damaged and continues to damage Greenthread in an
`
`amount yet to be determined, of at least a reasonable royalty.
`
`COUNT V: INFRINGEMENT OF U.S. PATENT NO. 11,121,222
`
`Greenthread incorporates by reference and re-alleges all of the foregoing
`
`79.
`
`paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein.
`
`80.
`
`The following allegations are based on publicly available information and a
`
`reasonable investigation of the structure and operation of the OmniVision Accused Products.
`
`Greenthread reserves the right to modify this description, inc