Case 2:17-cv-00676-RWS-RSP Document 1 Filed 09/29/17 Page 1 of 25 PageID #: 1
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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`GODO KAISHA IP BRIDGE 1,
`
`
`
`Plaintiff,
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`Case No. 2:17-cv-00676
`
`v.
`
`INTEL CORPORATION,
`
`
`
`Defendant.
`
` JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`Plaintiff Godo Kaisha IP Bridge 1 (“IP Bridge” or “Plaintiff”) brings this Complaint for
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`Patent Infringement (“Complaint”) against Intel Corporation (“Intel” or “Defendant”). Plaintiff
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`alleges as follows:
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`NATURE OF THE ACTION
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`This is an action brought by IP Bridge against Intel for infringement of U.S. Patent
`
`1.
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`Nos. 6,197,696 (“the ’696 Patent”), RE41,980 (“the RE’980 Patent”), 7,279,727 (“the ’727
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`Patent”), 6,709,950 (“the ’950 Patent”), 6,967,409 (“the ’409 Patent”), 6,346,736 (“the ’736
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`Patent”), 7,800,165 (“the ’165 Patent”), 6,387,824 (“the ’824 Patent”), and 6,602,802 (“the ’802
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`Patent”) (collectively, “the Asserted Patents”).
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`2.
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`Two of the Asserted Patents, the ’696 Patent and the RE’980 Patent previously were
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`asserted by IP Bridge in the Marshall Division of the Eastern District of Texas in Godo Kaisha IP
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`Bridge 1 v. Broadcom Ltd., et al., case no. 2:16-cv-00134 (E.D. Tex.) (the “Broadcom Action”).
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`

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`Case 2:17-cv-00676-RWS-RSP Document 1 Filed 09/29/17 Page 2 of 25 PageID #: 2
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`THE PARTIES
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`3.
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`Plaintiff IP Bridge is a Japanese entity with its principal place of business located
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`at c/o Sakura Sogo Jimusho, 1-11 Kanda Jimbocho, Chiyoda-ku, Tokyo, 101-0051, Japan. IP
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`Bridge owns the Asserted Patents.
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`4.
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`Upon information and belief, Defendant Intel is a Delaware corporation with its
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`principal place of business at 2200 Mission College Boulevard, Santa Clara, California 95054.
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`JURISDICTION AND VENUE
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`5.
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`This is an action arising under the patent laws of the United States. Accordingly,
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`this Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 (federal question) and
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`1338(a) (action arising under an Act of Congress relating to patents).
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`6.
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`This Court has general and specific personal jurisdiction over Intel at least in part
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`because Intel is present and/or transacts and conducts business in, and with residents of, the State
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`of Texas and this judicial District. IP Bridge’s causes of action arise, at least in part, from Intel’s
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`contacts with and activities in the State of Texas and this judicial District. Upon information and
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`belief, Intel has committed acts of infringement within the State of Texas and this judicial District
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`by, inter alia, directly and/or indirectly making, selling, offering for sale, importing, and/or using
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`products that infringe one or more claims of the Asserted Patents. Intel, directly and/or through
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`intermediaries, uses, sells, ships, distributes, offers for sale, and/or advertises or otherwise
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`promotes its products in the State of Texas and this judicial District. Also, Intel has a number of
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`subsidiaries that upon information and belief are involved in making, selling, offering for sale,
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`and/or importing into the U.S., Intel’s semiconductor products and that on information and belief
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`Intel directs and controls, including Intel Americas, Inc.
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`7.
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`Venue is proper pursuant to 28 U.S.C. § 1400(b) because Intel “has committed acts
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`of infringement and has a regular and established place of business” in this judicial District.
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`COMPLAINT FOR PATENT INFRINGEMENT – Page 2
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`Indeed, Intel regularly conducts and solicits business in, engages in other persistent courses of
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`conduct in, and/or derives substantial revenue from goods and services provided to, residents of
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`the State of Texas and this judicial District. For example, Intel makes numerous external
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`representations of its presence in the State of Texas and, more particularly, this District, by listing
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`a Plano address (5000 Headquarters Dr.) on its U.S. offices webpage and posting online job listings
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`for positions in Plano. Additionally, Intel advertises its significant operations in Texas on a
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`dedicated section of its website entitled “Intel in Texas,” wherein Intel states, “Intel has more than
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`2,300
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`employees
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`in Austin
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`and
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`Plano.”
`
`
`
`See
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`Intel
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`in Texas,
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`Intel,
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`https://www.intel.com/content/www/us/en/corporate-responsibility/intel-in-texas.html
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`(last
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`visited Sept. 21, 2017). Further, upon information and belief, Intel has an office in Richardson,
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`Texas located at 3400 Waterview Parkway, within this judicial District, where Intel offers direct
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`sales support consisting of Field Sales Engineers, Field Application Engineers and Inside Sales
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`Teams for Intel’s field-programmable gate array products. Upon information and belief, Intel also
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`benefits from its presence in this judicial District both directly and via the presence of third party
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`distributors in Plano and elsewhere in this judicial District. Intel also has availed itself of the
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`benefits and protections of the State’s laws by filing suit in this judicial District.
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`8.
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`Furthermore, upon information and belief, Intel has purposefully and voluntarily
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`placed one or more infringing products into the stream of commerce with the expectation that they
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`will be purchased and/or used by residents of this judicial District and/or incorporated into
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`downstream products purchased by consumers in this judicial District, including by directly and
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`indirectly working with distributors, and other entities located in the State of Texas, to ensure its
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`products reach the State of Texas and this judicial District.
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`COMPLAINT FOR PATENT INFRINGEMENT – Page 3
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`9.
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`Upon information and belief, Intel has official distributors located in Plano, Texas;
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`Richardson, Texas; Irving, Texas; Austin, Texas; and Coppell, Texas. More particularly, Arrow
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`Electronics (Electronic Components division) and SYNNEX Corporation, which are Intel
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`Authorized Distributors, have offices in Plano, Texas and Richardson, Texas, respectively.
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`10.
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`In addition, Intel maintains highly interactive and commercial websites, accessible
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`to residents of the State of Texas and this judicial District, through which Intel promotes and
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`facilitates sales of its products and services, including products that infringe the Asserted Patents.
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`11.
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`Upon information and belief, Intel sells its products directly to customers via its
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`website at https://www.intel.com/buy/us/en/. Intel’s website includes a link titled “How to Buy,”
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`which directs consumers in the United States, including those in the State of Texas and this judicial
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`District, to purchase Intel products either directly from the website or through Intel Technology
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`Providers, Intel Authorized Distributors, and/or Intel Approved Suppliers. Intel’s website also
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`includes a submission form that allows customers to input information in order to obtain technical
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`or sales support from Intel.
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`12.
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`Further, Intel is registered to do business in Texas as Intel Corporation and Intel
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`Semiconductor (US) LLC.
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`INTEL’S INFRINGING PRODUCTS AND ACTIVITIES
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`13.
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`IP Bridge realleges and incorporates by reference the allegations of paragraphs 1-
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`12 of this Complaint.
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`14.
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`Intel is a global manufacturer and supplier of semiconductor components and
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`products for use in consumer and enterprise products, systems, and services. Intel designs, makes,
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`uses, sells, offers for sale, imports into the United States, and provides support for semiconductor
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`chips, such as products with the part name or number i5-3550, E89459, QX9650, M 5Y70, and
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`GT3e G82494, and other semiconductor products that have similar structures, features, or
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`COMPLAINT FOR PATENT INFRINGEMENT – Page 4
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`functionalities, and/or are made by similar manufacturing processes, as the aforementioned
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`products, including but not limited to Intel’s 14nm, 22nm, 32nm, and 45nm process node
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`semiconductor chips and products (collectively, “Accused Semiconductor Products”).
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`15.
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`The Accused Semiconductor Products are integrated into devices made, used, sold,
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`offered for sale, and/or imported into the United States, by, among others, Intel, original equipment
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`manufacturers, original design manufacturers, distributors, and other third parties. Intel’s Accused
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`Semiconductor Products are essential, non-trivial components of the products into which they are
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`integrated. For example, the Core i5-3550 processor powers desktops such as the Dell OptiPlex
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`7010.
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`16.
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`Upon information and belief, on Feb. 17, 2017, Intel filed with the United States
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`Securities and Exchange Commission a Form 10-K. Relevant portions of the Form 10-K are
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`attached hereto as Exhibit A.
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`17.
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` Intel’s Form 10-K states, “Our products are sold through sales offices throughout
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`the world.” Upon information and belief, said sales offices are located throughout the United
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`States, including within the State of Texas and this judicial District.
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`18.
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`Additionally, Intel’s Form 10-K states, “We sell our products primarily to OEMs
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`and ODMs[,]” but also sell to “other manufacturers and service providers… who buy our products
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`through distributor, reseller, retail, and OEM channels throughout the world.” Upon information
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`and belief, Intel sells its products to customers in the United States, including within the State of
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`Texas and this judicial District.
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`19.
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`Upon information and belief, Intel maintains a website that advertises the Accused
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`Semiconductor Products, including identifying the applications for which the accused devices can
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`be used and pricing for the Accused Semiconductor Products, as well as directions on how to
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`COMPLAINT FOR PATENT INFRINGEMENT – Page 5
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`purchase the Accused Semiconductor Products, whether through the Intel Shop, Intel Technology
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`Providers, Intel Authorized Distributors, or Intel Approved Suppliers. In addition, the website
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`contains a hyperlink displaying “Email for Sales Inquiries” leading to a form for directly
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`contacting Intel Customer Support regarding sales inquiries. Upon information and belief, Intel
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`fields such sales inquiries from within the State of Texas and this judicial District, and provides
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`responses to such inquiries within the State of Texas and this judicial District.
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`20.
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`Upon information and belief, Intel’s sales, marketing, and manufacturing activities
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`in the United States, including within the State of Texas and this judicial District, directly
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`contributed to Intel’s net revenue in the United States (based on the billing location of the
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`customer), which, according to Intel’s Form 10-K, was $12,957,000,000 as of December 31, 2016.
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`FIRST CLAIM FOR RELIEF
`INFRINGEMENT OF U.S. PATENT NO. 6,197,696
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`IP Bridge realleges and incorporates by reference the allegations of paragraphs 1-
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`21.
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`20 of this Complaint.
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`22.
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`On March 6, 2001, the United States Patent and Trademark Office (“USPTO”) duly
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`and legally issued the ’696 Patent, entitled “Method for Forming Interconnection Structure.” A
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`copy of the ’696 Patent is attached hereto as Exhibit B.
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`23.
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`IP Bridge owns by assignment the entire right, title, and interest in and to the ’696
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`Patent, including the right to sue and recover damages, including damages for past infringement.
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`24.
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`On information and belief, Intel has had knowledge of the ’696 Patent and its
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`infringement thereof at least by virtue of the filing of this Complaint in this action. In addition, on
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`information and belief, Intel had knowledge of the ’696 patent, which was asserted in the
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`Broadcom Action, as a result of Intel’s knowledge of and participation (via at least the provision
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`of third-party discovery) in the Broadcom Action.
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`COMPLAINT FOR PATENT INFRINGEMENT – Page 6
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`25.
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`Intel has infringed and is infringing, directly and/or indirectly, either literally or
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`under the doctrine of equivalents, at least claims 13 and 15 of the ’696 Patent in violation of at
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`least 35 U.S.C. § 271(a), (b), and/or (g), by making, having made, using, selling, offering for sale,
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`and/or importing into the United States, Intel’s i5-3550 and M 5Y70 semiconductor products, and
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`each and every product Intel makes and/or has made incorporating the same or equivalent structure
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`or made using the same or equivalent processes, including without limitation Intel’s 14nm and
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`22nm process node semiconductor products made using the patented process of at least claims 13
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`and 15 of the ’696 Patent, which products are not materially changed by subsequent processes and
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`do not become a trivial and nonessential component of another product (“the ’696 Accused
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`Products”). For example, on information and belief, with respect to the ’696 Accused Products,
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`Intel has infringed at least claim 13 of the ’696 Patent because the steps to manufacture such
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`products comprise the steps of, inter alia, forming a first insulating film over lower-level metal
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`interconnects; forming a second insulating film, having a different composition than that of the
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`first insulating film, over the first insulating film; forming a third insulating film, having a different
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`composition than that of the second insulating film, over the second insulating film; forming a thin
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`film over the third insulating film; forming a first resist pattern on the thin film, the first resist
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`pattern having openings for forming wiring grooves; etching the thin film using the first resist
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`pattern as a mask, thereby forming a mask pattern out of the thin film to have the openings for
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`forming wiring grooves; removing the first resist pattern and then forming a second resist pattern
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`on the third insulating film and the mask pattern, the second resist pattern having openings for
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`forming contact holes; dry-etching the third insulating film using the second resist pattern and the
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`mask pattern as a mask, thereby patterning the third insulating film to have the openings for
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`forming contact holes; dry-etching the second insulating film using the patterned third insulating
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`COMPLAINT FOR PATENT INFRINGEMENT – Page 7
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`film as a mask, thereby patterning the second insulating film to have the openings for forming
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`contact holes; dry-etching the patterned third insulating film and the first insulating film using the
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`mask pattern and the patterned second insulating film as respective masks, thereby forming wiring
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`grooves and contact holes in the patterned third insulating film and the first insulating film,
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`respectively; and filling in the wiring grooves and the contact holes with a metal film, thereby
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`forming upper-level metal interconnects and contacts connecting the lower- and upper-level metal
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`interconnects together.
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`26.
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`Intel’s actions alleged herein have actively induced and/or are continuing to
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`actively induce infringement of at least claims 13 and 15 of the ’696 Patent by actively encouraging
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`acts of direct infringement (for example, using, selling, offering for sale, and importing into the
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`United States the ’696 Accused Products), and Intel knows (or believes that there is a high
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`probability but is taking deliberate steps to avoid knowing) that it is inducing infringement by
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`encouraging and instructing third parties, including OEMs, ODMs, distributors, and other third
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`party customers, to use, import into the United States, and/or sell or offer for sale, the ’696 Accused
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`Products and products that incorporate the ’696 Accused Products. For example, Intel’s product
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`literature for the ’696 Accused Products instructs and encourages Intel’s customers and other third
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`parties to integrate the ’696 Accused Products into products sold, offered for sale, and/or imported
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`into the United States.
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`27.
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`Intel’s infringement of the ’696 Patent is willful and deliberate, entitling IP Bridge
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`to enhanced damages and attorneys’ fees.
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`28.
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`IP Bridge is entitled to recover from Intel all damages IP Bridge has sustained as a
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`result of Intel’s infringement of the ’696 Patent, including without limitation not less than a
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`reasonable royalty.
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`COMPLAINT FOR PATENT INFRINGEMENT – Page 8
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`SECOND CLAIM FOR RELIEF
`INFRINGEMENT OF U.S. PATENT NO. RE41,980
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`IP Bridge realleges and incorporates paragraphs 1-28 of this Complaint.
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`On December 7, 2010, the USPTO duly and legally issued the RE’980 Patent,
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`29.
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`30.
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`entitled “Semiconductor Interconnect Formed Over an Insulation and Having Moisture Resistant
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`Material.” A copy of the RE’980 Patent is attached hereto as Exhibit C.
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`31.
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`The Patent Trial and Appeal Board has on four (4) occasions denied institution of
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`inter partes review proceedings, determining in three instances that there was not a reasonable
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`likelihood that the petitioner would prevail with respect to any challenged claim of the petition,
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`and in the fourth instance that the same prior art and substantially the same arguments were
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`presented previously.
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`32.
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`IP Bridge owns by assignment the entire right, title, and interest in and to the
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`RE’980 Patent, including the right to sue and recover damages, including damages for past
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`infringement.
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`33.
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`Intel has had knowledge of the RE’980 Patent and its infringement thereof since at
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`least about December 17, 2014, when IP Bridge notified Intel of the RE’980 Patent and Intel’s
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`infringement thereof. In addition, on information and belief, Intel had knowledge of the RE’980
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`patent, which was asserted in the Broadcom Action, as a result of Intel’s knowledge of and
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`participation (via at least the provision of third-party discovery) in the Broadcom Action.
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`34.
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`Intel infringed, either direct or indirectly, literally or under the doctrine of
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`equivalents, at least claims 18, 19, 30-36, and 47-51 of the RE’980 Patent in violation of at least
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`35 U.S.C. § 271(a) and/or (b) by making, having made, using, selling, offering for sale, and/or
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`importing into the United States, Intel’s i5-3550, E89459, QX9650, and M 5Y70 semiconductor
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`products, and each and every product Intel makes and/or has made incorporating the same or
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`COMPLAINT FOR PATENT INFRINGEMENT – Page 9
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`equivalent processes and/or structures, including without limitation Intel’s 14nm, 22nm, 32nm,
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`and 45nm process node semiconductor products that meet every limitation of at least the above-
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`identified claims (“the RE’980 Accused Products”). For example, on information and belief, the
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`RE’980 Accused Products meet each and every limitation of claim 35 of the RE’980 Patent
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`because they comprise a semiconductor substrate bearing semiconductor elements; an interlayer
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`insulating film formed on said semiconductor substrate; a metal wire layer including plural metal
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`wires formed on said interlayer insulating film; a surface protecting film including a first dielectric
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`film with a small dielectric constant for filling at least a part of areas among said metal wires in
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`said metal wire layer and a second dielectric film with a higher moisture absorption preventing
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`function than said first dielectric film for covering said metal wire layer and said first dielectric
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`film, said second dielectric film having a function of suppressing moisture absorption of said first
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`dielectric film; an opening for a bonding pad formed in said surface protecting film; and a bonding
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`pad formed in said opening for obtaining external electrical connection, wherein said bonding pad
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`covers said opening and said second dielectric film of said surface protecting film completely
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`covers said first dielectric film so as not to expose said first dielectric film, all of which are arranged
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`in the manner recited in the above-identified claim.
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`35.
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`Intel’s actions alleged herein actively induced infringement of at least claims 18,
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`19, 30-36, and 47-51 of the RE’980 Patent by actively encouraging acts of direct infringement,
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`and Intel knew (or believed that there was a high probability but took deliberate steps to avoid
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`knowing) that it was inducing infringement by encouraging and instructing third parties, including
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`OEMs, ODMs, distributors, and other third party customers, to make, use, sell, offer for sale,
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`and/or import into the United States the RE’980 Accused Products and products that incorporate
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`the RE’980 Accused Products. For example, Intel’s product literature for the RE’980 Accused
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`COMPLAINT FOR PATENT INFRINGEMENT – Page 10
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`Products instructs and encourages Intel’s customers and other third parties to integrate the RE’980
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`Accused Products into products sold, offered for sale, and/or imported into the United States.
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`36.
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`Intel’s infringement of the RE’980 Patent was willful and deliberate, entitling IP
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`Bridge to enhanced damages and attorneys’ fees.
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`37.
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`IP Bridge is entitled to recover from Intel all damages IP Bridge has sustained as a
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`result of Intel’s infringement of the RE’980 Patent, including without limitation not less than a
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`reasonable royalty.
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`THIRD CLAIM FOR RELIEF
`INFRINGEMENT OF U.S. PATENT NO. 7,279,727
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`IP Bridge realleges and incorporates paragraphs 1-37 of this Complaint.
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`On October 9, 2007, the USPTO duly and legally issued the ’727 Patent, entitled
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`38.
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`39.
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`“Semiconductor Device.” A copy of the ’727 Patent is attached hereto as Exhibit D.
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`40.
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`IP Bridge owns by assignment the entire right, title, and interest in and to the ’727
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`Patent, including the right to sue and recover damages, including damages for past infringement.
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`41.
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`On information and belief, Intel has had knowledge of the ’727 Patent and its
`
`infringement thereof at least by virtue of the filing of the Complaint in this action.
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`42.
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`Intel has infringed and is infringing, directly and/or indirectly, either literally or
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`under the doctrine of equivalents, at least claims 1, 5, 10, and 11 of the ’727 Patent in violation of
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`at least 35 U.S.C. § 271(a) and/or (b) by making, having made, using, selling, offering for sale,
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`and/or importing into the United States, Intel’s i5-3550, E89459, QX9650, and M 5Y70
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`semiconductor products, and each and every product Intel makes and/or has made incorporating
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`the same or equivalent processes and/or structures, including without limitation Intel’s 14nm,
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`22nm, 32nm, and 45nm process node products that meet every limitation of at least the above-
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`identified claims (“the ’727 Accused Products”). For example, on information and belief, the ’727
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`COMPLAINT FOR PATENT INFRINGEMENT – Page 11
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`Accused Products meet each and every limitation of at least claim 1 of the ’727 Patent because
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`they comprise a semiconductor substrate; a diffusion region which is formed in the semiconductor
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`substrate and serves as a region for the formation of a MIS transistor; an element isolation region
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`surrounding the diffusion region; at least one gate conductor film which is formed across the
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`diffusion region and the element isolation region, includes a gate electrode part located on the
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`diffusion region and a gate interconnect part located on the element isolation region, and has a
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`constant dimension in a gate length direction; an interlayer insulating film covering the gate
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`electrode part; and a gate contact which passes through the interlayer insulating film, is connected
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`to the gate interconnect part, and has a dimension in the gate length direction larger than the gate
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`interconnect part, all of which are arranged in the manner recited in the above-identified claim.
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`43.
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`Intel’s actions alleged herein have actively induced and/or are continuing to
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`actively induce infringement of at least claims 1, 5, 10, and 11 of the ’727 Patent by actively
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`encouraging acts of direct infringement, and Intel knows (or believes that there is a high probability
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`but is taking deliberate steps to avoid knowing) that it is inducing infringement by encouraging
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`and instructing third parties, including OEMs, ODMs, distributors, and other third party customers,
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`to make, use, sell, offer for sale, and/or import into the United States the ’727 Accused Products
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`and products that incorporate the ’727 Accused Products. For example, Intel’s product literature
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`for the ’727 Accused Products instructs and encourages Intel’s customers and other third parties
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`to integrate the ’727 Accused Products into products sold, offered for sale, and/or imported into
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`the United States.
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`44.
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`Intel’s infringement of the ’727 Patent is willful and deliberate, entitling IP Bridge
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`to enhanced damages and attorneys’ fees.
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`COMPLAINT FOR PATENT INFRINGEMENT – Page 12
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`45.
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`IP Bridge is entitled to recover from Intel all damages IP Bridge has sustained as a
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`result of Intel’s infringement of the ’727 Patent, including without limitation not less than a
`
`reasonable royalty.
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`FOURTH CLAIM FOR RELIEF
`INFRINGEMENT OF U.S. PATENT NO. 6,709,950
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`IP Bridge realleges and incorporates paragraphs 1-45 of this Complaint.
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`On March 23, 2004, the USPTO duly and legally issued the ’950 Patent, entitled
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`46.
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`47.
`
`“Semiconductor Device and Method of Manufacturing the Same.” A copy of the ’950 Patent is
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`attached hereto as Exhibit E.
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`48.
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`IP Bridge owns by assignment the entire right, title, and interest in and to the ’950
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`Patent, including the right to sue and recover damages, including damages for past infringement.
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`49.
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`On information and belief, Intel has had knowledge of the ’950 Patent and its
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`infringement thereof at least by virtue of the filing of the Complaint in this action.
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`50.
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`Intel infringed, either literally or under the doctrine of equivalents, at least claims
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`17-19, 21, and 22 of the ’950 Patent in violation of at least 35 U.S.C. § 271(a) and/or (g), by
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`making, having made, using, selling, offering for sale, and/or importing into the United States,
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`Intel’s QX9650 semiconductor product, and each and every product Intel makes and/or has made
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`incorporating the same or equivalent structure or made using the same or equivalent processes,
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`including without limitation Intel’s 45nm process node semiconductor products made using the
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`patented process of at least claims 17-19, 21, and 22 of the ‘950 Patent, which products are not
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`materially changed by subsequent processes and do not become a trivial and nonessential
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`component of another product (“the ’950 Accused Products”). For example, on information and
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`belief, with respect to the ’950 Accused Products, Intel has infringed at least claim 17 of the ’950
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`Patent because the steps to manufacture such products comprised the steps of, inter alia, a first
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`COMPLAINT FOR PATENT INFRINGEMENT – Page 13
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`Case 2:17-cv-00676-RWS-RSP Document 1 Filed 09/29/17 Page 14 of 25 PageID #: 14
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`step of forming a trench isolation on a semiconductor substrate, the trench isolation having a top
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`surface at a higher level than a surface of the semiconductor substrate; a second step of forming a
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`gate insulating film on an active area surrounded by the trench isolation on the semiconductor
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`substrate; a third step of forming a gate electrode on the gate insulating film; after the third step, a
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`fourth step of forming a laminated film made of a lower film and an upper film on the entire surface
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`of the semiconductor substrate on which the trench isolation having a top surface at a higher level
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`than a surface of the semiconductor substrate is formed; a fifth step of forming an interlayer
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`insulating film on the upper film; a sixth step of selectively removing the interlayer film and the
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`laminated film and forming a hole; and a seventh step of forming a buried conductive layer by
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`filling the hole with a conductive material, wherein the upper film is made of an insulating material
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`having high etching selectivity against the interlayer insulating film in dry etching.
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`51.
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`IP Bridge is entitled to recover from Intel all damages IP Bridge has sustained as a
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`result of Intel’s infringement of the ’950 Patent, including without limitation not less than a
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`reasonable royalty.
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`FIFTH CLAIM FOR RELIEF
`INFRINGEMENT OF U.S. PATENT NO. 6,967,409
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`IP Bridge realleges and incorporates paragraphs 1-51 of this Complaint.
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`On November 22, 2005, the USPTO duly and legally issued the ’409 Patent,
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`52.
`
`53.
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`entitled “Semiconductor Device and Method of Manufacturing the Same.” A copy of the ’409
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`Patent is attached hereto as Exhibit F.
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`54.
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`IP Bridge owns by assignment the entire right, title, and interest in and to the ’409
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`Patent, including the right to sue and recover damages, including damages for past infringement.
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`55.
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`On information and belief, Intel has had knowledge of the ’409 Patent and its
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`infringement thereof at least by virtue of the filing of the Complaint in this action.
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`COMPLAINT FOR PATENT INFRINGEMENT – Page 14
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`Case 2:17-cv-00676-RWS-RSP Document 1 Filed 09/29/17 Page 15 of 25 PageID #: 15
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`56.
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`Intel infringed, either literally or under the doctrine of equivalents, at least claims
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`1, 2, 6-8, 12, 18, 25, 26, 28, 29, 44, 45, 47, 48, 49, 51, 52, 53, 59, 60, 64, 75, 76, 78, and 79 of the
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`’409 Patent in violation of at least 35 U.S.C. § 271(a) by making, having made, using, selling,
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`offering for sale, and/or importing into the United States, Intel’s i5-3550 semiconductor product,
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`and each and every product Intel makes and/or has made incorporating the same or equivalent
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`processes and/or structures, including without limitation Intel’s 22nm process node products that
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`meet every limitation of at least the above-identified claims (“the ’409 Accused Products”). For
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`example, on information and belief, the ’409 Accused Products meet each and every limitation of
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`at least claim 1 of the ’409 Patent because they comprise an isolation for surrounding an active
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`region of a substrate; an interconnection formed on the isolation; an insulating film formed on a
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`top surface of the interconnection; a hole formed on an area including at least part of the active
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`region, at least part of the isolation and at least part of the interconnection; a conductive layer
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`formed in the hole; and an interconnection member formed on, and connected to, the conductive
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`layer; wherein the active region and the interconnection are connected to the conductive layer, and
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`wherein at least part of a top surface of the isolation that is connected to the conductive layer is at
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`a lower level than a top surface of the isolation that is provided below the interconnection, all of
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`which are arranged in the manner recited in the above-identified claim.
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`57.
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`IP Bridge is entitled to recover from Intel all damages IP Bridge has sustained as a
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`result of Intel’s infringement of the ’409 Patent, including without limitation not less than a
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`reasonable royalty.
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`SIXTH CLAIM FOR RELIEF
`INFRINGEMENT OF U.S. PATENT NO. 6,346,736
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`IP Bridge realleges and incorporates paragraphs 1-57 of this Complaint.
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`58.
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`COMPLAINT FOR PATENT INFRINGEMENT – Page 15
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`Case 2:17-cv-00676-RWS-RSP Document 1 Filed 09/29/17 Page 16 of 25 PageID #: 16
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`59.
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`On February 12, 2002, the USPTO duly and legally issued the ’736 Patent, entitled
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`“Trench Isolated Semiconductor Device.” A copy of the ’736 Patent is attached hereto as Exhibit
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`G.
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`60.
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`IP Bridge owns by assignment the entire right, title, and interest in and to the ’736
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`Patent, including the right to sue and recover damages, including damages for past infringement.
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`61.
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`On information and belief, Intel has had knowledge of the ’736 Patent and its
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`infringement thereof at least by virtue of the filing of the Complaint in this action.
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`62.
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`Intel has infringed and is infringing,