Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 1 of 60 Page ID #:1
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`KRAMER ALBERTI LIM
`& TONKOVICH LLP
`Robert F. Kramer (SBN 181706)
`rkramer@krameralberti.com
`David Alberti (SBN 220625)
`dalberti@krameralberti.com
`Sal Lim (SBN 211836)
`slim@krameralberti.com
`Russell S. Tonkovich (SBN 233280)
`rtonkovich@krameralberti.com
`577 Airport Blvd, Suite 250
`Burlingame, CA. 94010
`Tel: 650 825-4300/Fax: 650 460-8443
`
`Attorneys for Plaintiff
`Polaris PowerLED Technologies, LLC
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`POLARIS POWERLED
`TECHNOLOGIES, LLC,
`Plaintiff,
`v.
`WESTERN DIGITAL CORPORATION,
`WESTERN DIGITAL TECHNOLOGIES,
`INC., NEWEGG, INC., AVNET, INC.,
`ZONES, LLC, and PRIVATE LABEL PC,
`LLC,
`
`Case No. 2:24-cv-02864
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`DEMAND FOR JURY TRIAL
`
`Defendants.
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Ex.1015 / Page 1 of 60
`Sandisk Technologies, Inc. et al
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`

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`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 2 of 60 Page ID #:2
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`Plaintiff Polaris PowerLED Technologies, LLC (“Plaintiff” or “Polaris”)
`brings this patent infringement action against Defendants Western Digital
`Corporation; Western Digital Technologies, Inc.; Newegg, Inc.; Avnet, Inc.; Zones,
`LLC; and Private Label PC, LLC (collectively, “Defendants”) as follows:
`NATURE OF THE ACTION
`1.
`This is a civil action for infringement of U.S. Patent Nos. 8,554,968
`(“the ’968 Patent”), 9,183,085 (“the ’085 Patent”), and 8,601,346 (“the ’346 Patent”)
`(collectively, “Asserted Patents”), and under the patent laws of the United States, 35
`U.S.C. § 1 et seq.
`2.
`The technology in this case involves flash memory. Flash memory is
`used in, among other things, computing, gaming, data storage, and e-commerce. The
`ability of solid-state flash memory to hold electric charges without moving parts has
`revolutionized how information is stored and has resulted in great improvements over
`older memory technologies. These electrical charges, held in miniscule transistors,
`are used to read, store, and write enormous amounts of information in small,
`lightweight memory products that have transformed the daily lives of consumers.
`3.
`Defendants’ infringing devices are its solid-state drive (“SSD”)
`products (“the Accused Products” or “the infringing devices”).
`4. Western Digital is among the largest manufacturers of memory products
`in the United States.
`5.
`Plaintiff brings this patent infringement action to protect its valuable
`patented technology specifically relating to (1) nonvolatile memory controllers
`(NVMCs) and SSDs; (2) interrupt techniques used in NVMCs and SSDs; (3) how
`NVMCs and SSDs adaptively select among error correction coding (ECC) schemes;
`and (4) how NVMCs and SSDs generate parity data using a distributed processing
`technique.
`6.
`The Defendants control, participate in the commission of, and have a
`direct financial interest in the infringing acts set forth herein.
`1
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
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`
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`Ex.1015 / Page 2 of 60
`Sandisk Technologies, Inc. et al
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`

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`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 3 of 60 Page ID #:3
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`THE PARTIES
`Polaris
`7.
`Polaris is a California limited liability company having its address at
`5150 E. Pacific Coast Highway, Suite 200, Long Beach, California 90804.
`Western Digital
`8.
`As used in this Complaint, Defendants Western Digital Corporation and
`Western Digital Technologies, Inc. are collectively referred to as “Western Digital.”
`9.
`On information and belief, Defendant Western Digital Corporation is a
`Delaware corporation having offices in this District at 3355 Michelson Drive, Suite
`100, Irvine, California 92612. Western Digital Corporation is registered with the
`California Secretary of State to do business in California and can be served through
`its registered agent, CSC - Lawyers Incorporating Service, 2710 Gateway Oaks
`Drive, Sacramento, California 95833.
`10. On information and belief, Defendant Western Digital Technologies,
`Inc. is a subsidiary of Western Digital Corporation. Western Digital Technologies,
`Inc. is a Delaware corporation having offices in this District at 3355 Michelson Drive,
`Suite 100, Irvine, California 92612. Western Digital Technologies, Inc. is registered
`with the California Secretary of State to do business in California and can be served
`through its registered agent, CSC - Lawyers Incorporating Service, 2710 Gateway
`Oaks Drive, Sacramento, California 95833.
`Newegg
`11. On information and belief, Defendant Newegg, Inc. (“Newegg”) is a
`corporation formed under the laws of Delaware, with its principal place of business
`at 17560 Rowland Street, City of Industry, California 91748, which is located in this
`District.
`12. Western Digital advertises Newegg as a “preferred Western Digital
`authorized partner.” See https://www.westerndigital.com/company/distributors.
`13. On information and belief, Newegg sells and offers for sale the Accused
`
`2
`COMPLAINT FOR PATENT INFRINGEMENT
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`Ex.1015 / Page 3 of 60
`Sandisk Technologies, Inc. et al
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`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 4 of 60 Page ID #:4
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`Products. On information and belief, Newegg provides services that help customers
`in this District build computers that contain the Accused Products, including
`providing
`a
`service
`called
`“PC Builder” on
`its website.
` See
`https://www.newegg.com/tools/custom-pc-builder.
`Avnet
`14. On information and belief, Defendant Avnet, Inc. (“Avnet”) is a
`corporation formed under the laws of New York, with offices at 21155 Califa Street,
`Woodland Hills, California 91367, which is located in this District. Avnet is
`registered with the California Secretary of State to do business in California and can
`be served through its registered agent, CSC - Lawyers Incorporating Service, 2710
`Gateway Oaks Drive, Sacramento, California 95833.
`15. Western Digital advertises Avnet as a “preferred Western Digital
`authorized partner.” See https://www.westerndigital.com/company/distributors.
`16. On information and belief, Avnet sells and offers for sale the Accused
`Products. On information and belief, Avnet provides services that help customers in
`this District implement infringing functionality in the Accused Products. For
`instance, Zones describes itself as follows: “As a global technology solutions
`company, our ecosystem enables us to help professional engineers, entrepreneurs and
`startups take their tech projects from idea to design and from prototype to production.
`...With this end-to-end approach, we help reduce time, cost and complexities of
`bringing products to market. Avnet’s culture was founded on new ideas and emerging
`technology. With more than 15,000 employees globally, we support business for our
`customers in 140 countries across North America, Europe and Asia. That’s why
`customers around the world turn to Avnet – for our know-how, integrity, experience
`and global reach. Our engineers are on the front lines of innovation, supported by
`sales, supply-chain, design-chain and service teams with deep expertise – making
`Avnet the go-to guide for innovators who set the pace for technological change.” See
`https://news.avnet.com/about-us/default.aspx.
`
`3
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
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`
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`Ex.1015 / Page 4 of 60
`Sandisk Technologies, Inc. et al
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`

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`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 5 of 60 Page ID #:5
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`Zones
`17. On information and belief, Defendant Zones, LLC (“Zones”) is a
`corporation formed under the laws of the State of Washington, with offices at 13915
`Cerritos Corporate Drive, Cerritos, California 90703, which is located in this District.
`Zones is registered with the California Secretary of State to do business in California
`and can be served through its registered agent, CSC - Lawyers Incorporating Service,
`2710 Gateway Oaks Drive, Sacramento, California 95833.
`18. Western Digital advertises Zones as a “preferred Western Digital
`authorized partner.” See https://www.westerndigital.com/company/distributors.
`19. On information and belief, Zones sells and offers for sale the Accused
`Products. On information and belief, Zones provides services that help customers in
`this District implement infringing functionality in the Accused Products. For
`instance, Zones describes itself as follows: “We’re a global provider of
`comprehensive IT services and solutions, reaching 100-plus countries and employing
`2,000-plus people worldwide. ... We help organizations of all sizes succeed with
`custom IT services and solutions for business, healthcare, government, and
`education, plus market verticals like retail, utilities, and financial services, to name a
`few. ... We architect solutions that simplify the complex and meet your individual
`business
`needs
`and
`goals.”
`
`See
`https://www.zones.com/site/statics/static_page.html?name=about-us.
`PLPC
`20. On information and belief, Defendant Private Label PC, LLC (“PLPC”)
`is a corporation formed under the laws of the State of California with its principal
`place of business at 748 Epperson Drive, City of Industry, California 91748, which
`is located in this District. PLPC is registered with the California Secretary of State
`to do business in California and can be served through its registered agent, Jonathan
`Wang, 748 Epperson Drive, City of Industry, California 91748.
`21. Western Digital advertises PLPC as a “preferred Western Digital
`
`4
`COMPLAINT FOR PATENT INFRINGEMENT
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`
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`Ex.1015 / Page 5 of 60
`Sandisk Technologies, Inc. et al
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`

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`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 6 of 60 Page ID #:6
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`authorized partner.” See https://www.westerndigital.com/company/distributors.
`22. On information and belief, PLPC sells and offers for sale the Accused
`Products. On information and belief, PLPC provides services that help customers in
`this District implement infringing functionality in the Accused Products. For
`instance, PLPC describes itself as follows: “PLPC delivers the most efficient
`technology solutions to the Gaming, Cloud, HPC, Security & Surveillance, and
`Consumer Electronics markets. PLPC distributes technology products from many of
`the world’s leading manufacturers and provides solutions to value-added resellers,
`DMR, retailers, and thousands of integrators for PC, surveillance, platform enterprise
`in the U.S., and Latin America. PLPC has successfully penetrated 18 countries in
`Latin America with in-country sales support. As part of their value-added services,
`PLPC provides a variety of integration, including product lifecycle support, contract
`design, and assembly. In addition, PLPC provides a wide range of financial options
`to ensure that our partners always have the resources in place to win business.” See
`https://www.plpc.com/company (emphasis added).
`JURISDICTION AND VENUE
`23. Plaintiff incorporates by reference and re-alleges the foregoing
`paragraphs as fully set forth herein.
`24. This action arises under the patent laws of the United States, Title 35 of
`the United States Code. Accordingly, this Court has subject matter jurisdiction under
`28 U.S.C. §§ 1331 and 1338(a).
`
`Western Digital
`25. On information and belief, Western Digital transacts and conducts
`business in this District and the State of California and is subject to the personal
`jurisdiction of this Court. On information and belief, Western Digital has minimum
`contacts within the State of California and this District and has purposefully availed
`itself of the privileges of conducting business in the State of California and in this
`District. Polaris’ causes of action arise directly from Western Digital’s business
`
`5
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`
`
`
`Ex.1015 / Page 6 of 60
`Sandisk Technologies, Inc. et al
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`

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`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 7 of 60 Page ID #:7
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`contacts and other activities in the State of California and in this District.
`26. On information and belief, Western Digital has committed acts of
`infringement within this District and the State of California by, inter alia, making,
`importing, using, selling, and/or offering for sale Accused Products that infringe one
`or more claims of the Asserted Patents. More specifically, Western Digital, directly
`and/or through intermediaries or agents, makes, imports, uses, sells, ships,
`distributes, offers for sale, advertises, and/or otherwise promotes infringing Accused
`Products in the United States, the State of California, and this District.
`27. Venue is proper in this District under 28 U.S.C. §§ 1391(b), (c) and
`1400(b), including based on Western Digital’s physical presence in this District
`and/or Western Digital’s transaction of business in this District directly and/or
`through its affiliates and customers and/or acts of patent infringement in this District.
`Newegg
`28. On information and belief, Newegg, Inc. (“Newegg”) transacts and
`conducts business in this District and the State of California and is subject to the
`personal jurisdiction of this Court. On information and belief, Newegg has minimum
`contacts within the State of California and this District and has purposefully availed
`itself of the privileges of conducting business in the State of California and in this
`District. Polaris’ causes of action arise directly from Newegg’s business contacts and
`other activities in the State of California and in this District.
`29. On information and belief, Newegg has committed acts of infringement
`within this District and the State of California by, inter alia, making, importing,
`using, selling, and/or offering for sale Accused Products that infringe one or more
`claims of the Asserted Patents. More specifically, on information and belief, Newegg,
`directly and/or through intermediaries or agents, makes, imports, uses, sells, ships,
`distributes, offers for sale, advertises, and/or otherwise promotes infringing Accused
`Products in the United States, the State of California, and this District.
`30. Venue is proper in this District under 28 U.S.C. §§ 1391(b), (c) and
`
`6
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
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`
`
`Ex.1015 / Page 7 of 60
`Sandisk Technologies, Inc. et al
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`

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`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 8 of 60 Page ID #:8
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`1400(b), including based on Newegg’s physical presence and the location of its
`offices and headquarters in this District and/or Newegg’s transaction of business in
`this District directly and/or through its affiliates and customers and/or acts of patent
`infringement in this District.
`
`Avnet
`31. On information and belief, Avnet transacts and conducts business in this
`District and the State of California and is subject to the personal jurisdiction of this
`Court. On information and belief, Avnet has minimum contacts within the State of
`California and this District and has purposefully availed itself of the privileges of
`conducting business in the State of California and in this District. Polaris’ causes of
`action arise directly from Avnet’s business contacts and other activities in the State
`of California and in this District.
`32. On information and belief, Avnet has committed acts of infringement
`within this District and the State of California by, inter alia, making, importing,
`using, selling, and/or offering for sale Accused Products that infringe one or more
`claims of the Asserted Patents. More specifically, on information and belief, Avnet,
`directly and/or through intermediaries or agents, makes, imports, uses, sells, ships,
`distributes, offers for sale, advertises, and/or otherwise promotes infringing Accused
`Products in the United States, the State of California, and this District.
`33. Venue is proper in this District under 28 U.S.C. §§ 1391(b), (c) and
`1400(b), including based on Avnet’s physical presence in this District and/or Avnet’s
`transaction of business in this District directly and/or through its affiliates and
`customers and/or acts of patent infringement in this District.
`Zones
`34. On information and belief, Zones transacts and conducts business in this
`District and the State of California and is subject to the personal jurisdiction of this
`Court. On information and belief, Zones has minimum contacts within the State of
`California and this District and has purposefully availed itself of the privileges of
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`7
`COMPLAINT FOR PATENT INFRINGEMENT
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`Ex.1015 / Page 8 of 60
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`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 9 of 60 Page ID #:9
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`conducting business in the State of California and in this District. Polaris’ causes of
`action arise directly from Zones’ business contacts and other activities in the State of
`California and in this District.
`35. On information and belief, Zones has committed acts of infringement
`within this District and the State of California by, inter alia, making, importing,
`using, selling, and/or offering for sale Accused Products that infringe one or more
`claims of the Asserted Patents. More specifically, on information and belief, Zones,
`directly and/or through intermediaries or agents, makes, imports, uses, sells, ships,
`distributes, offers for sale, advertises, and/or otherwise promotes infringing Accused
`Products in the United States, the State of California, and this District.
`36. Venue is proper in this District under 28 U.S.C. §§ 1391(b), (c) and
`1400(b), including based on Zones’ physical presence in this District and/or Zones’
`transaction of business in this District directly and/or through its affiliates and
`customers and/or acts of patent infringement in this District.
`PLPC
`37. On information and belief, PLPC transacts and conducts business in this
`District and the State of California and is subject to the personal jurisdiction of this
`Court. On information and belief, PLPC has minimum contacts within the State of
`California and this District and has purposefully availed itself of the privileges of
`conducting business in the State of California and in this District. Polaris’ causes of
`action arise directly from PLPC’s business contacts and other activities in the State
`of California and in this District.
`38. On information and belief, PLPC has committed acts of infringement
`within this District and the State of California by, inter alia, making, importing,
`using, selling, and/or offering for sale Accused Products that infringe one or more
`claims of the Asserted Patents. More specifically, on information and belief, PLPC,
`directly and/or through intermediaries or agents, makes, imports, uses, sells, ships,
`distributes, offers for sale, advertises, and/or otherwise promotes infringing Accused
`
`8
`COMPLAINT FOR PATENT INFRINGEMENT
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`Ex.1015 / Page 9 of 60
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`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 10 of 60 Page ID #:10
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`Products in the United States, the State of California, and this District.
`39. Venue is proper in this District under 28 U.S.C. §§ 1391(b), (c) and
`1400(b), including based on PLPC’s physical presence and the location of its
`headquarters in this District and/or PLPC’s transaction of business in this District
`directly and/or through its affiliates and customers and/or acts of patent infringement
`in this District.
`
`PATENTS-IN-SUIT
`40. Plaintiff owns the entire right, title, and interest in U.S. Patent No.
`8,554,968 titled “Interrupt Technique for a Nonvolatile Memory Controller,”
`including the right to assert all causes of action arising under said patent and to seek
`damages and all other remedies for the infringement thereof. The ’968 Patent issued
`on October 8, 2013 to inventors Peter Z. Onufryk, Jayesh Patel and Ihab Jaser from
`the U.S. Patent Application No. 13/052,388 filed on March 21, 2011. A true and
`correct copy of the ’968 Patent is attached as Exhibit A to this Complaint.
`41. Plaintiff owns the entire right, title, and interest in U.S. Patent No.
`9,183,085 titled “Systems and Methods for Adaptively Selecting from among a
`Plurality of Error Correction Coding Schemes in a Flash Drive for Robustness and
`Low Latency,” including the right to assert all causes of action arising under said
`patent and to seek damages and all other remedies for the infringement thereof. The
`’085 Patent issued on November 10, 2015, to inventor Philip L. Northcott from the
`U.S. Patent Application No. 13/477,600, filed on May 22, 2012. A true and correct
`copy of the ’085 Patent is attached as Exhibit B to this Complaint.
`42. Plaintiff owns the entire right, title, and interest in U.S. Patent No.
`8,601,346 titled “System and Method for Generating Parity Data in a Nonvolatile
`Memory Controller by Using a Distributed Processing Technique,” including the
`right to assert all causes of action arising under said patent and to seek damages and
`all other remedies for the infringement thereof. The ’346 Patent issued on December
`3, 2013, to inventors Peter Z. Onufryk and Inna Levit from the U.S. Patent
`
`9
`COMPLAINT FOR PATENT INFRINGEMENT
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`Ex.1015 / Page 10 of 60
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`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 11 of 60 Page ID #:11
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`Application 13/052,835, filed on March 21, 2011. A true and correct copy of the ’346
`Patent is attached as Exhibit C to this Complaint.
`’968 PATENT BACKGROUND
`43. The ’968 Patent relates generally to improvements to nonvolatile
`memory controllers, including the processing of memory commands and the
`generation of a completion status for such commands. The inventive nonvolatile
`memory controller transmits the completion status to a host processing unit for
`storage in a completion queue of the host processing unit. An interrupt manager in
`the nonvolatile memory controller determines whether the completion queue contains
`an unprocessed completion status and generates an interrupt message packet. The
`nonvolatile memory controller transmits the interrupt message packet to the host
`processing unit for triggering an interrupt in the host processing unit and alerting the
`host processing unit to the unprocessed completion status.
`’085 PATENT BACKGROUND
`44. The ’085 Patent relates generally to disclosed techniques providing
`relatively low uncorrectable bit error rates (BER) for flash memory; low write
`amplification; long life, fast and efficient retrieval; and efficient storage density such
`that a solid-state drive (SSD) or flash drive can be implemented using relatively
`inexpensive MLC flash for enterprise storage application.
`’346 PATENT BACKGROUND
`45. The ’346 Patent relates generally to a nonvolatile memory controller
`performing a data-stripe operation by processing a collection of commands. The
`collection of commands includes data update commands and a parity write command.
`The nonvolatile memory controller includes a number of command processing units,
`each of which receives a command in the collection of commands. Each of the
`command processing units receiving a data update command requests a data block
`from a controller memory; receives the data block from the controller memory
`through a data path in response to the request; and writes the data block to a
`
`10
`COMPLAINT FOR PATENT INFRINGEMENT
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`Ex.1015 / Page 11 of 60
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`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 12 of 60 Page ID #:12
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`nonvolatile memory device.
`
`COUNT I
`(INFRINGEMENT OF U.S. PATENT NO. 8,554,968)
`46. Plaintiff incorporates by reference and re-alleges the foregoing
`paragraphs as fully set forth herein.
`47. Defendants have directly infringed, and continue to directly infringe,
`one or more claims of the ’968 Patent, including at least claim 1 of the ’968 Patent,
`literally and/or under the doctrine of equivalents, by or through making, using,
`offering for sale, selling within the United States and/or importing into the United
`States its SSD products that support NVMe.
`48. Claim 1 of the ’968 Patent, for example, reads as follows:
`1. A nonvolatile memory controller for alerting a host
`processing unit to an unprocessed completion status
`contained in a completion queue of the host processing
`unit, the nonvolatile memory controller comprising:
`an interrupt manager configured to generate a completion
`queue state for indicating the occurrence of a completion
`queue event associated with the completion queue,
`generate an interrupt vector state based on the completion
`queue state, determine the completion queue of the host
`processing unit contains an unprocessed completion status
`based on the interrupt vector state, and generate an
`interrupt message packet for triggering an interrupt in the
`host processing unit to alert the host processing unit of the
`unprocessed completion status in the completion queue,
`and wherein the completion queue state includes a doorbell
`update status indicating whether the host processing unit
`has performed a doorbell update event in which the host
`processing unit updates a head pointer stored in the
`nonvolatile memory controller for the completion queue.
`
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`11
`COMPLAINT FOR PATENT INFRINGEMENT
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`Ex.1015 / Page 12 of 60
`Sandisk Technologies, Inc. et al
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`

`

`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 13 of 60 Page ID #:13
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`49. Defendants make, use, sell, offer for sale and import SSD products that
`support the NVMe standard and that include a nonvolatile memory controller
`configured for alerting a host processing unit to an unprocessed completion status
`contained in a completion queue of the host processing unit. For example, as shown
`below, WD Black-branded SSDs, which are used for gaming consoles and gaming
`PCs, Blue- and Green-branded SSDs, which are used for everyday PCs, Red-branded
`SSDs, which are used for Network Attached Storage (NAS), and Gold- and Ultrastar
`SSDs , which are used for data centers, all support NVMe:
`
`
`WD_BLACK SN770 NVMe SSD, Western Digital (Jan. 2022),
`https://documents.westerndigital.com/content/dam/doc-
`library/en_us/assets/public/western-digital/product/internal-drives/wd-black-
`ssd/product-brief-wd-black-sn770-nvme-ssd.pdf [hereinafter “WD_BLACK SN770
`NVMe SSD”].
`
`
`50. The image below shows the benefits and improvements of NVMe over
`SATA:
`
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`12
`COMPLAINT FOR PATENT INFRINGEMENT
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`Ex.1015 / Page 13 of 60
`Sandisk Technologies, Inc. et al
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`

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`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 14 of 60 Page ID #:14
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`
`Internal SSD, Western Digital, https://www.westerndigital.com/solutions/internal-
`ssd (last visited Jan. 2, 2024) [hereinafter “Internal SSD”].
`
`51. The following describes how NVMe functions:
`
`
`NVM Express, Inc., NVM Express Base Specification, Revision 1.4, (June 10,
`2019), https://nvmexpress.org/wp-content/uploads/NVM-Express-1_4-2019.06.10-
`Ratified.pdf [hereinafter “NVM Express Specification”].
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Ex.1015 / Page 14 of 60
`Sandisk Technologies, Inc. et al
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`

`

`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 15 of 60 Page ID #:15
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`
` Express Specification at 274.
`
`
`52. Defendants’ SSD products with NVMe support include an interrupt
`manager configured to generate a complete queue state for indicating occurrence of
`a completion queue event associated with the completion queue, as shown below:
`
`
`NVM Express Specification at 14.
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`
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`NVM Express Specification at 283.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Ex.1015 / Page 15 of 60
`Sandisk Technologies, Inc. et al
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`

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`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 16 of 60 Page ID #:16
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`NVM Express Specification at 284.
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`53. Defendants’ SSD products with NVMe support include an interrupt
`manager configured to generate an interrupt vector state based on the complete queue
`state, which is shown below:
`
`
`NVM Express Specification at 102.
`
`
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`NVM Express Specification at 283.
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`15
`COMPLAINT FOR PATENT INFRINGEMENT
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`Ex.1015 / Page 16 of 60
`Sandisk Technologies, Inc. et al
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`

`

`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 17 of 60 Page ID #:17
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`NVM Express Specification at 284.
`
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`54. The Accused Products with NVMe support include an interrupt manager
`configured to determine whether the completion queue of the host processing unit
`contains an unprocessed completion state based on the interrupt vector state. The
`interrupt manager is further configured to generate an interrupt message packet for
`triggering an interrupt in the host processing unit to alert the host processing unit of
`the unprocessed completion status in the completion queue. This is shown in the
`images below:
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`16
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Ex.1015 / Page 17 of 60
`Sandisk Technologies, Inc. et al
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`

`

`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 18 of 60 Page ID #:18
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`NVM Express Specification at 283-284.
`
`
`55. The nonvolatile memory controller, which generates an MSI-X
`interrupt, is transmitted as a PCIe message packet. This is demonstrated in the quote
`below:
`
`NVMe, which connects to your laptop or desktop PC via
`the PCIe® interface, can hit speeds as high as 7.5GB per
`second. Compare this to SATA, which typically tops out at
`500MB per second.
`
`Internal SSD.
`
`PCI Express Base Specification Revision 2.1 (March 4, 2009), [hereinafter “PCIe
`v2.1”].
`
`
`PCIe v2.1 at 31.
`
`
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`PCIe v2.1 at 33.
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`17
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Ex.1015 / Page 18 of 60
`Sandisk Technologies, Inc. et al
`
`

`

`Case 2:24-cv-02864-ODW-MAR Document 1 Filed 04/09/24 Page 19 of 60 Page ID #:19
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`56. The image below shows a completion queue state includes a doorbell
`
`update status indicating whether the host processing unit has performed a doorbell
`
`update event in which the host processing unit updates a head pointer stored in the
`
`nonvolatile memory controller for the completion queue.
`
`
`NVM Express Specification at 283-284.
`57. Defendants have directly infringed, and continue to infringe, the claims
`of the ’968 Patent in the United States, by making, using, offering for sale, selling,
`and/or importing the Accused Products in violation of 35 U.S.C. § 271(a). For
`example, Defendants provide SSD products configured with the hardware and
`software that satisfy the limitations of at least claim 1. Defendants further directly
`infringe the ’968 Patent when its SSD products with NVMe are installed and operated
`
`18
`COMPLAINT FOR PAT