`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`
`Civil Action No.: 6:20-cv-1211
`
`JURY TRIAL DEMANDED
`
`PATENT CASE
`
`
`Ocean Semiconductor LLC,
`
`
`
`v.
`
`NVIDIA Corporation,
`
`
`
`
`
`
`
`
`
`
`
`Plaintiff
`
`Defendant.
`
`
`
`
`CASE READINESS STATUS REPORT
`
`Plaintiff Ocean Semiconductor LLC (“Ocean”) and Defendant NVIDIA Corporation
`
`(“NVIDIA”) hereby provide the following status report in advance of the initial Case
`
`Management Conference (CMC).
`
`FILING AND EXTENSIONS
`
`Plaintiff’s Complaint (Dkt. 1) was filed on December 31, 2020. There has been one
`
`extension for a total of forty-five days.
`
`RESPONSE TO THE COMPLAINT
`
`NVIDIA responded to the Complaint with its Rule 12(b)(6) Motion to Dismiss Claims
`
`Under the ‘538, ‘305, and ‘248 Patents Because They Are Not Cognizable Under 35 U.S.C. §
`
`271(g) (“Motion to Dismiss”) (Dkt. 13) and Answer to Complaint for Patent Infringement (Dkt.
`
`14) on March 12, 2021.
`
`1
`
`
`
`Case 6:20-cv-01211-ADA Document 23 Filed 05/05/21 Page 2 of 4
`
`PENDING MOTIONS
`
`Currently pending before this Court are NVIDIA’s Motion to Dismiss (Dkt. 13) and
`
`Ocean’s Motion for Leave to File Sur-Reply In Opposition to NVIDIA Corporation’s Motion to
`
`Dismiss for Failure to State a Claim (Dkt. 19).
`
`RELATED CASES IN THIS JUDICIAL DISTRICT
`
`1. Ocean Semiconductor LLC v Mediatek Inc. and Mediatek USA Inc., Civil Action No.
`
`6:20-cv-1210-ADA (W.D. Tex.)
`
`2. Ocean Semiconductor LLC v. NXP Semiconductors N.V., NXP B.V. and NXP USA, Inc.,
`
`Civil Action No.: 6:20-cv-1212-ADA (W.D. Tex.)
`
`3. Ocean Semiconductor LLC v. Renesas Electronics Corporation and Renesas Electronics
`
`America, Inc., Civil Action No.: 6:20-cv-1213-ADA (W.D. Tex.)
`
`4. Ocean Semiconductor LLC v. Silicon Laboratories Inc., Civil Action No.: 6:20-cv-1214-
`
`ADA (W.D. Tex.)
`
`5. Ocean Semiconductor LLC v. STMicroelectronics, Inc., Civil Action No.: 6:20-cv-1215-
`
`ADA (W.D. Tex.)
`
`6. Ocean Semiconductor LLC v. Western Digital Technologies, Inc., Civil Action No.: 6:20-
`
`cv-1216-ADA (W.D. Tex.)
`
`IPR, CBM, AND OTHER PGR FILINGS
`
`Defendant Western Digital Technologies (“WDT”) in Ocean Semiconductor LLC v.
`
`Western Digital Technologies (Civil Action No.: 6:20-cv-1216-ADA) has filed an inter partes
`
`review petition (IPR2021-00864) on April 29, 2021, challenging the validity of one of eight
`
`patents asserted against WDT, U.S. Patent No. 6,660,651. That patent has also been asserted in
`
`this action.
`
`NUMBER OF ASSERTED PATENTS AND CLAIMS
`
`2
`
`
`
`Case 6:20-cv-01211-ADA Document 23 Filed 05/05/21 Page 3 of 4
`
`In the Complaint, Plaintiff has identified nine patents and a total of nine claims as being
`
`infringed by NVIDIA. Plaintiff will set forth all asserted patents and claims in its preliminary
`
`infringement contentions.
`
`APPOINTMENT OF TECHNICAL ADVISER
`
`The parties do not intend to request, nor anticipate a need for, a technical adviser at this
`
`juncture.
`
`MEET AND CONFER STATUS
`
`Plaintiff and Defendant met and conferred.
`
`The parties have no pre-Markman issues to raise at the case management conference
`
`other than those already identified in the pending motions (Dkt. 13 and Dkt. 19).
`
`
`
`
`
`3
`
`
`
`Case 6:20-cv-01211-ADA Document 23 Filed 05/05/21 Page 4 of 4
`
`Respectfully Submitted,
`
` /s/ Andrew D. Holmes
`Scott L. Cole
`Texas Bar No. 00790481
`scottcole@quinnemanuel.com
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`5209 Spanish Oaks Club Blvd
`Austin, TX 78738
`737 667 6100 – Telephone
`737 667 6110 – Facsimile
`
`Sean Pak (pro hac vice)
`seanpak@quinnemanuel.com
`Andrew D. Holmes (pro hac vice)
`drewholmes@quinnemanuel.com
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`50 California Street, 22nd Floor
`San Francisco, California 94111
`415.875.6600 – Telephone
`415.875.6700 – Facsimile
`
`ATTORNEYS FOR DEFENDANT
`NVIDIA CORPORATION
`
`
`
`
`Dated: May 5, 2021
`
`/s/ Alex Chan
`Timothy Devlin
`tdevlin@devlinlawfirm.com
`Henrik D. Parker
`hparker@devlinlawfirm.com
`Alex Chan
`State Bar No. 24108051
`achan@devlinlawfirm.com
`DEVLIN LAW FIRM LLC
`1526 Gilpin Avenue
`Wilmington, Delaware 19806
`Telephone: (302) 449-9010
`Facsimile: (302) 353-4251
`
`Attorneys for Plaintiff,
`Ocean Semiconductor LLC
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on May 5, 2021, a true and correct copy of the above and foregoing
`
`document has been served on all counsel of record via the Court’s CM/ECF system.
`
`
`
`
`
`/s/ Alex Chan
`Alex Chan
`
`
`
`4
`
`
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