Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 1 of 70
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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Ocean Semiconductor LLC,
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`Plaintiff
`
`v.
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`Renesas Electronics Corporation and Renesas
`Electronics America, Inc. (“Renesas”)
`
`Defendant.
`
`Civil Action No.: 6:20-cv-1213
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`JURY TRIAL DEMANDED
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`PATENT CASE
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff Ocean Semiconductor LLC (“Ocean Semiconductor” or “Plaintiff”) files this
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`Complaint against Renesas Electronics Corporation (“Renesas Electronics”) and Renesas
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`Electronics America, Inc. (“Renesas America”) (collectively “Renesas” or “Defendants”), seeking
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`damages and other relief for patent infringement, and alleges with knowledge to its own acts, and
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`on information and belief as to other matters, as follows:
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`NATURE OF THE ACTION
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`1.
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`This is an action for patent infringement arising under the Patent Laws of the
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`United States, 35 U.S.C. § 1 et seq.
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`THE PARTIES
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 2 of 70
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`2.
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`Plaintiff Ocean Semiconductor is a limited liability company organized and
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`existing under the laws of the State of Delaware, and its registered agent for service of process in
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`Delaware is Rita Carnevale, 717 N. Union Street, Wilmington, DE 19805.
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`3.
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`On information and belief, Renesas Electronics is a corporation organized under
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`the laws of Japan, with its principal place of business at Toyosu Foresia, 3-2-24 Toyosu, Koto-
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`ku, Tokyo 135-0061, Japan, and at 900 S. Capital of Texas Hwy, Las Cimas IV, Austin, TX
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`78746.
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`4.
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`On information and belief, Renesas America is a Delaware corporation with a
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`principal place of business at 1001 Murphy Ranch Road, Milpitas, CA 95035. On information
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`and belief, Renesas America may be served through its registered agent, Corporation Service
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`Company, 251 Little Falls Drive, Wilmington, DE 19808.
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`5.
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`On information and belief, Renesas sells, offers to sell, and/or uses products and
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`services throughout the United States, including in this judicial District, and introduces
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`infringing products and services into the stream of commerce knowing that they would be sold
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`and/or used in this judicial District and elsewhere in the United States.
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`6.
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`Plaintiff Ocean Semiconductor is the assignee and owner of the patents at issue in
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`this action: U.S. Patents Nos. 6,660,651, 6,907,305, 6,725,402, 6,968,248, 7,080,330, 6,836,691,
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`and 8,676,538 (collectively, the “Asserted Patents”). Ocean Semiconductor holds all substantial
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`rights, title, and interest in the Asserted Patents, including the exclusive right to sue Renesas for
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`infringement and recover damages, including damages for past infringement.
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`7.
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`Plaintiff Ocean Semiconductor seeks monetary damages and prejudgment interest
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`for Defendant’s past and ongoing direct and indirect infringement of the Asserted Patents.
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 3 of 70
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`8.
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`Defendants are semiconductor companies that design, develop, sell, offer to sell,
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`and import into the United States semiconductor products in the communications, internet of
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`things, automotive, computer, and consumer electronics industry (“Accused Products”).
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`9.
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`Renesas, which has its own regular and established place of business in the United
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`States (including a facility in Austin, Texas), produces or contracts with third-party
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`semiconductor fabricators or foundries (“Renesas Foundry Partners”) that own, operate, or
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`control semiconductor fabrication plants (“fabs”) within and/or outside of the United States
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`(“International Facilities”) to produce the Accused Products. One such Renesas Foundry Partner
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`is Taiwan Semiconductor Manufacturing Company Ltd. (“TSMC”). TSMC has a contractual
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`partnership with Renesas to design, develop, or manufacture semiconductor products including
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`integrated circuits for Renesas. See, e.g., “Renesas Electronics and TSMC Announce 28nm
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`MCU Collaboration for Next-Generation Green and Autonomous Vehicles,” available at
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`https://www.renesas.com/cn/en/about/press-center/news/2016/news20160901.html (last accessed
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`October 27, 2020); see also “TSMC to make automotive chips for Renesas,” available at
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`https://asia.nikkei.com/Asia300/TSMC-to-make-automotive-chips-for-Renesas (last accessed
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`October 27, 2020).
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`10.
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`On information and belief, Renesas (directly or through one or more of its
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`Foundry Partners such as TSMC) also has a contractual relationship with Applied Materials, Inc.
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`(“Applied Materials”) (see e.g., Applied Materials’ job posting for “TSMC F15 E3 project,”
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`available at
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`http://www.mse.ntu.edu.tw/attachments/article/154/AMT_Summer%20Student%20Program_Job
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`%20Post_2013.pdf (last accessed October 12, 2020)) and PDF Solutions Inc. (“PDF Solutions”)
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`(e.g., “Taiwan Semiconductor Manufacturing Company adopts PDF Solutions yield
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 4 of 70
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`improvement technology,” available at https://www.edn.com/taiwan-semiconductor-
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`manufacturing-company-adopts-pdf-solutions-yield-improvement-technology/ (last accessed
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`Oct. 12, 2020); see also “Exensio: Big Data in the Fab,” available at
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`https://semiwiki.com/eda/4351-exensio-big-data-in-the-fab/ (last accessed Oct. 12, 2020); see
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`also Renesas’ job posting hiring “Product Engineer-Intern” with “Exensio” knowledge, available
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`at https://jobs.renesas.com/job/San-Jose-Product-Engineer-Intern-CA-95101/613809601/ (Oct.
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`12, 2020)), and one or more of the Renesas Foundry Partners (e.g., TSMC) employ Applied
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`Materials’ semiconductor fabrication or manufacturing equipment, platforms, and/or framework,
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`including Applied Materials’ E3 system, including the E3 factory advanced/automation process
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`control (“APC”) hardware and/or software (collectively, “E3 system”), PDF Solutions’ Exensio
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`hardware and/or software (collectively, “Exensio system”), and/or other in-house or third-party
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`advanced/automation process control system and platform hardware and/or software (e.g., with
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`similar technical and functional features) to design, develop, and/or manufacture Defendant
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`Renesas’s semiconductor devices, including integrated circuits.
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`11.
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`Upon information and belief, TSMC employs Applied Materials’ and/or PDF
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`Solutions’ semiconductor fabrication or manufacturing equipment, platforms, and/or framework
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`(e.g., Applied Materials’ E3 system and/or PDF Solutions’ Exensio system) at its manufacturing
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`facilities. Applied Materials has received supplier awards and recognition from TSMC. See,
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`e.g., “TSMC Recognizes Outstanding Suppliers at Supply Chain Management Forum,” available
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`at https://pr.tsmc.com/english/news/1873 (last accessed October 12, 2020). On information and
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`belief, TSMC also employs PDF Solutions’ Exensio system at TSMC’s manufacturing facilities.
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`12.
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`On information and belief, Renesas (directly or through its Renesas Foundry
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`Partners such as TSMC) employs Applied Materials’ E3 system and/or PDF Solutions’ Exensio
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 5 of 70
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`system to develop or manufacture one or more systems, products, and/or devices for importation
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`into the United States for use, sale, and/or offer for sale in this District and throughout the United
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`States, including, but not limited to, microcontrollers and microprocessors (e.g., RL78 Family of
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`8/16-bit Ultra-Low Energy MCUs, RX Family of 32-bit High Power Efficiency MCUs, RH850
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`Family, RZ Family of 64-Bit & 32-Bit Arm-Based High-End MPUs, V850 Family, 78K Family,
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`R8C Family, M16C Family (R32C / M32C / M16C), M32R Family, H8/S/SX Family, 720
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`Family, 740 Family, SuperH RISC engine Family, H8 Super Low Power, PLC MCU, Renesas
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`RA Family of 32-bit MCUs with Arm Cortex-M Core, RE Family, QzROM (740/720 Family),
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`M16C (M32C/M16C) Family, R8C Family, 7700 Family, and SuperH RISC engine Family and
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`MCUs with Arm Cortex-M Core Implemented on Silicon on Thin Buried Oxide (SOTB)),
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`amplifiers and buffers (e.g., CA3XXX, CA5XXX, EL2XXX, EL4XXX, EL5XXX, EL8XXX,
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`HA-2XXX, HA-5XXX, HFA11XX, ICL7XXX, ISL28XXX, ISL55XXX, ISL59XXX,
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`READ23XXXSP, and UPCXXXXXX), analog products (e.g., switches and multiplexers), clocks
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`and timing products (e.g., application-specific clocks, clock distribution, clock generation, and
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`crystal oscillators), interface & connectivity products (e.g., wireless modules, switches and hubs,
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`and wireless modules), audio and video products (e.g., ISL54XXX), automotive products (e.g.,
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`Automotive System-on-Chip (SOC), Ambient Light Sensors, Analog ICs, Car Audio ICs,
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`Battery Management Systems, CAN Transceivers, Discrete/Power MOFETs for Automotive,
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`Display ICs, Intelligent Power Devices, Interface ICs, LSI for Automotive, Microcontrollers
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`(RH850), Microcontrollers (RL78/F1x), Power Management (e.g., Power Management ICs for
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`RH850, Power Supply ICs for R-Car, Switches & Multiplexers, Video ICs, Discrete Power
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`Devices, regulators, MOSFETs and Motor Drivers, PMICs, and wireless power devices), ICs for
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`Communications and Mobile Devices (e.g., SH-MobileR, SH-MobileR2, EMMA Mobile, SH-
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 6 of 70
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`Mobile MT1, and R-Mobile A1), sensor products (e.g., flow sensors, gas sensors, humidity
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`sensors, light & proximity sensors, position sensors, sensor signal conditioners, and optical
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`sensors such as ISL76671), data converters (e.g., HI-565A, HI-565A/883, and HI5XXX), ICs for
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`Industrial Automation (R-IN) (e.g. R-IN32M3, R-IN32M4-CL2, TPS-1, EC-1, R-IN32M4-CL3,
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`and R-IN32M3), ICs for Motor Driver/Actuator Driver, Interface devices (e.g., Bus Buffers, RS-
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`485, RS-422, RS-232, Signal Integrity ICs, Dual Protocol RS-485, RS-232 Transceivers, and
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`Industrial Network Transceivers), Legacy MCUs (e.g., 80C/82C Microprocessors &
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`Peripherals), memory (e.g., ultra-fast Quad Data Rate SRAMs, SRAMs, EEPROM & PROM,
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`MRAMS, FIFO products, interface products, and standard logic), Optoelectronics, power
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`management devices (e.g., RAJ240XXXDNP), RF products (e.g., modulators, demodulators,
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`transistor arrays, beamformers, mixers, switches, attenuators, VGAs, synthesizers and PLLs),
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`Renesas USB Power Delivery Family (e.g., Renesas USB Power Delivery Family Features and
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`U30 Group), Secure MCUs (e.g., AE-5 Series and RS-4 Series), Smart Analog devices (e.g.,
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`Smart Analog IC101, IC300, IC301, IC500, IC501, and IC502), and space and harsh
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`environment devices (e.g., µPD720115, µPD720201, µPD720202, µPD720210, µPD720211,
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`M66291, R8A66593, and R8A66597), products manufactured at 28nm and 40nm technology
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`node by TSMC for Renesas such as eFlash and MCUs, microprocessors, sensors, radars, power
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`efficiency systems, electronic control units, and automotive products, and similar systems,
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`products, devices, and integrated circuits (“Renesas APC Products”).
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`13.
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`On information and belief, Renesas (directly or through its Renesas Foundry
`
`Partners such as TSMC) uses Applied Materials’ E3 system and/or PDF Solutions’ Exensio
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`system to design, develop, or manufacture the Renesas APC Products for importation into the
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`United States for use, sale, and/or offer for sale in this district and throughout the United States.
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 7 of 70
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`14.
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`On information and belief, Renesas (directly and/or through its Renesas Foundry
`
`Partners) has a contractual relationship with ASML Holding N.V. and/or its subsidiaries
`
`(“ASML”) (see, e.g., LinkedIn Profile for Spencer Lin, Operation Manager at ASML, available
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`at https://www.linkedin.com/in/spencer-lin-a48a0082/ (last visited Oct. 12, 2020); LinkedIn
`
`Profile for Leo Li, Product Engineer at ASML, available at https://www.linkedin.com/in/leo-li-
`
`74222754/ (last visited Oct. 12, 2020); LinkedIn Profile for Tsung Ming C., Applicant Engineer
`
`at ASML, available at https://www.linkedin.com/in/tsung-ming-c-49b4b77/ (last visited Oct. 12,
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`2020); LinkedIn Profile for Vince Liu, Product Manager at ASML, available at
`
`https://www.linkedin.com/in/vince-liu-4820b149/ (last visited Oct. 12, 2020); and LinkedIn
`
`Profile for Henry Yeh, Applicant Engineer at ASML, available at
`
`https://www.linkedin.com/in/heavyyeh/ (last visited Oct. 12, 2020)), and that Renesas, and/or
`
`one or more of the Renesas Foundry Partners (e.g., TSMC), employs ASML’s semiconductor
`
`fabrication or manufacturing equipment and/or platforms (e.g., ASML’s TWINSCAN system
`
`hardware and software or “TWINSCAN”) to design, develop, and/or manufacture Defendant
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`Renesas’s semiconductor products and devices, such as microcontrollers and microprocessors
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`(e.g., RL78 Family of 8/16-bit Ultra-Low Energy MCUs, RX Family of 32-bit High Power
`
`Efficiency MCUs, RH850 Family, RZ Family of 64-Bit & 32-Bit Arm-Based High-End MPUs,
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`V850 Family, 78K Family, R8C Family, M16C Family (R32C / M32C / M16C), M32R Family,
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`H8/S/SX Family, 720 Family, 740 Family, SuperH RISC engine Family, H8 Super Low Power,
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`PLC MCU, Renesas RA Family of 32-bit MCUs with Arm Cortex-M Core, RE Family, QzROM
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`(740/720 Family), M16C (M32C/M16C) Family, R8C Family, 7700 Family, and SuperH RISC
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`engine Family and MCUs with Arm Cortex-M Core Implemented on Silicon on Thin Buried
`
`Oxide (SOTB)), amplifiers and buffers (e.g., CA3XXX, CA5XXX, EL2XXX, EL4XXX,
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 8 of 70
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`EL5XXX, EL8XXX, HA-2XXX, HA-5XXX, HFA11XX, ICL7XXX, ISL28XXX, ISL55XXX,
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`ISL59XXX, READ23XXXSP, and UPCXXXXXX), analog products (e.g., switches and
`
`multiplexers), clocks and timing products (e.g., application-specific clocks, clock distribution,
`
`clock generation, and crystal oscillators), interface & connectivity products (e.g., wireless
`
`modules, switches and hubs, and wireless modules), audio and video products (e.g., ISL54XXX),
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`automotive products (e.g., Automotive System-on-Chip (SOC), Ambient Light Sensors, Analog
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`ICs, Car Audio ICs, Battery Management Systems, CAN Transceivers, Discrete/Power MOFETs
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`for Automotive, Display ICs, Intelligent Power Devices, Interface ICs, LSI for Automotive,
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`Microcontrollers (RH850), Microcontrollers (RL78/F1x), Power Management (e.g., Power
`
`Management ICs for RH850, Power Supply ICs for R-Car, Switches & Multiplexers, Video ICs,
`
`Discrete Power Devices, regulators, MOSFETs and Motor Drivers, PMICs, and wireless power
`
`devices), ICs for Communications and Mobile Devices (e.g., SH-MobileR, SH-MobileR2,
`
`EMMA Mobile, SH-Mobile MT1, and R-Mobile A1), sensor products (e.g., flow sensors, gas
`
`sensors, humidity sensors, light & proximity sensors, position sensors, sensor signal
`
`conditioners, and optical sensors such as ISL76671), data converters (e.g., HI-565A, HI-
`
`565A/883, and HI5XXX), ICs for Industrial Automation (R-IN) (e.g. R-IN32M3, R-IN32M4-
`
`CL2, TPS-1, EC-1, R-IN32M4-CL3, and R-IN32M3), ICs for Motor Driver/Actuator Driver,
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`Interface devices (e.g., Bus Buffers, RS-485, RS-422, RS-232, Signal Integrity ICs, Dual
`
`Protocol RS-485, RS-232 Transceivers, and Industrial Network Transceivers), Legacy MCUs
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`(e.g., 80C/82C Microprocessors & Peripherals), memory (e.g., ultra-fast Quad Data Rate
`
`SRAMs, SRAMs, EEPROM & PROM, MRAMS, FIFO products, interface products, and
`
`standard logic), Optoelectronics, power management devices (e.g., RAJ240XXXDNP), RF
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`products (e.g., modulators, demodulators, transistor arrays, beamformers, mixers, switches,
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 9 of 70
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`attenuators, VGAs, synthesizers and PLLs), Renesas USB Power Delivery Family (e.g., Renesas
`
`USB Power Delivery Family Features and U30 Group), Secure MCUs (e.g., AE-5 Series and
`
`RS-4 Series), Smart Analog devices (e.g., Smart Analog IC101, IC300, IC301, IC500, IC501,
`
`and IC502), and space and harsh environment devices (e.g., µPD720115, µPD720201,
`
`µPD720202, µPD720210, µPD720211, M66291, R8A66593, and R8A66597), products
`
`manufactured at 28nm and 40nm technology node by TSMC for Renesas such as eFlash and
`
`MCUs, microprocessors, sensors, radars, power efficiency systems, electronic control units, and
`
`automotive products, and similar systems, products, devices, and integrated circuits (“Renesas
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`TWINSCAN Products”). See, e.g., “BRIEF-Taiwan’s UMC orders equipment from ASML for
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`T$657 mln,” available at https://www.reuters.com/article/umc-corp-asml-holding-brief/brief-
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`taiwans-umc-orders-equipment-from-asml-for-t657-mln-idUSS7N0P700I20140728 (last
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`accessed October 12, 2020); see also “UMC buys equipment from ASML,” available at
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`https://www.digitimes.com/news/a20160621PM200.html (last accessed October 12, 2020); see
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`also “ASML apparently beats Nikon for UMC’s huge 300-mm scanner order,” available at
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`https://www.eetimes.com/asml-apparently-beats-nikon-for-umcs-huge-300-mm-scanner-order/
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`(last accessed October 12, 2020); see also “ASML shares gain after reports of large TSMC
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`order,” available at https://seekingalpha.com/news/3636158-asml-shares-gain-after-reports-of-
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`large-tsmc-order (last visited Oct. 12, 2020); see also “ASML’s NXE Platform Performance,”
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`available at http://euvlsymposium.lbl.gov/pdf/2013/pres/RudyPeeters.pdf (last visited Oct. 12,
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`2020).
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`15.
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`On information and belief, Renesas (directly or through its Renesas Foundry
`
`Partners such as TSMC) uses ASML’s TWINSCAN platform and/or its software to design,
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 10 of 70
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`develop, or manufacture the Renesas TWINSCAN Products for importation into the United
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`States for use, sale, and/or offer for sale in this district and throughout the United States.
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`16.
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`On information and belief, Renesas (directly and/or through its Renesas Foundry
`
`Partners such as TSMC) has a contractual relationship with ASML and/or its subsidiaries (see,
`
`e.g., LinkedIn Profile for Spencer Lin, Operation Manager at ASML, available at
`
`https://www.linkedin.com/in/spencer-lin-a48a0082/ (last visited Oct. 12, 2020); LinkedIn Profile
`
`for Leo Li, Product Engineer at ASML, available at https://www.linkedin.com/in/leo-li-
`
`74222754/ (last visited Oct. 12, 2020); LinkedIn Profile for Tsung Ming C., Applicant Engineer
`
`at ASML, available at https://www.linkedin.com/in/tsung-ming-c-49b4b77/ (last visited Oct. 12,
`
`2020); LinkedIn Profile for Vince Liu, Product Manager at ASML, available at
`
`https://www.linkedin.com/in/vince-liu-4820b149/ (last visited Oct. 12, 2020); and LinkedIn
`
`Profile for Henry Yeh, Applicant Engineer at ASML, available at
`
`https://www.linkedin.com/in/heavyyeh/ (last visited Oct. 12, 2020)), and that Renesas, and/or
`
`one or more of the Renesas Foundry Partners (e.g., TSMC), employs ASML’s metrology and
`
`inspection systems (e.g., ASML’s YieldStar metrology and inspection system hardware and
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`software or “YieldStar system”) to design, develop, and/or manufacture Defendant Renesas’s
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`semiconductor products and devices, such as microcontrollers and microprocessors (e.g., RL78
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`Family of 8/16-bit Ultra-Low Energy MCUs, RX Family of 32-bit High Power Efficiency
`
`MCUs, RH850 Family, RZ Family of 64-Bit & 32-Bit Arm-Based High-End MPUs, V850
`
`Family, 78K Family, R8C Family, M16C Family (R32C / M32C / M16C), M32R Family,
`
`H8/S/SX Family, 720 Family, 740 Family, SuperH RISC engine Family, H8 Super Low Power,
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`PLC MCU, Renesas RA Family of 32-bit MCUs with Arm Cortex-M Core, RE Family, QzROM
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`(740/720 Family), M16C (M32C/M16C) Family, R8C Family, 7700 Family, and SuperH RISC
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 11 of 70
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`engine Family and MCUs with Arm Cortex-M Core Implemented on Silicon on Thin Buried
`
`Oxide (SOTB)), amplifiers and buffers (e.g., CA3XXX, CA5XXX, EL2XXX, EL4XXX,
`
`EL5XXX, EL8XXX, HA-2XXX, HA-5XXX, HFA11XX, ICL7XXX, ISL28XXX, ISL55XXX,
`
`ISL59XXX, READ23XXXSP, and UPCXXXXXX), analog products (e.g., switches and
`
`multiplexers), clocks and timing products (e.g., application-specific clocks, clock distribution,
`
`clock generation, and crystal oscillators), interface & connectivity products (e.g., wireless
`
`modules, switches and hubs, and wireless modules), audio and video products (e.g., ISL54XXX),
`
`automotive products (e.g., Automotive System-on-Chip (SOC), Ambient Light Sensors, Analog
`
`ICs, Car Audio ICs, Battery Management Systems, CAN Transceivers, Discrete/Power MOFETs
`
`for Automotive, Display ICs, Intelligent Power Devices, Interface ICs, LSI for Automotive,
`
`Microcontrollers (RH850), Microcontrollers (RL78/F1x), Power Management (e.g., Power
`
`Management ICs for RH850, Power Supply ICs for R-Car, Switches & Multiplexers, Video ICs,
`
`Discrete Power Devices, regulators, MOSFETs and Motor Drivers, PMICs, and wireless power
`
`devices), ICs for Communications and Mobile Devices (e.g., SH-MobileR, SH-MobileR2,
`
`EMMA Mobile, SH-Mobile MT1, and R-Mobile A1), sensor products (e.g., flow sensors, gas
`
`sensors, humidity sensors, light & proximity sensors, position sensors, sensor signal
`
`conditioners, and optical sensors such as ISL76671), data converters (e.g., HI-565A, HI-
`
`565A/883, and HI5XXX), ICs for Industrial Automation (R-IN) (e.g. R-IN32M3, R-IN32M4-
`
`CL2, TPS-1, EC-1, R-IN32M4-CL3, and R-IN32M3), ICs for Motor Driver/Actuator Driver,
`
`Interface devices (e.g., Bus Buffers, RS-485, RS-422, RS-232, Signal Integrity ICs, Dual
`
`Protocol RS-485, RS-232 Transceivers, and Industrial Network Transceivers), Legacy MCUs
`
`(e.g., 80C/82C Microprocessors & Peripherals), memory (e.g., ultra-fast Quad Data Rate
`
`SRAMs, SRAMs, EEPROM & PROM, MRAMS, FIFO products, interface products, and
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 12 of 70
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`standard logic), Optoelectronics, power management devices (e.g., RAJ240XXXDNP), RF
`
`products (e.g., modulators, demodulators, transistor arrays, beamformers, mixers, switches,
`
`attenuators, VGAs, synthesizers and PLLs), Renesas USB Power Delivery Family (e.g., Renesas
`
`USB Power Delivery Family Features and U30 Group), Secure MCUs (e.g., AE-5 Series and
`
`RS-4 Series), Smart Analog devices (e.g., Smart Analog IC101, IC300, IC301, IC500, IC501,
`
`and IC502), and space and harsh environment devices (e.g., µPD720115, µPD720201,
`
`µPD720202, µPD720210, µPD720211, M66291, R8A66593, and R8A66597), products
`
`manufactured at 28nm and 40nm technology node by TSMC for Renesas such as eFlash and
`
`MCUs, microprocessors, sensors, radars, power efficiency systems, electronic control units, and
`
`automotive products, and similar systems, products, devices, and integrated circuits (“Renesas
`
`YieldStar Products”). See, e.g., “BRIEF-Taiwan’s UMC orders equipment from ASML for
`
`T$657 mln,” available at https://www.reuters.com/article/umc-corp-asml-holding-brief/brief-
`
`taiwans-umc-orders-equipment-from-asml-for-t657-mln-idUSS7N0P700I20140728 (last
`
`accessed October 12, 2020); see also “UMC buys equipment from ASML,” available at
`
`https://www.digitimes.com/news/a20160621PM200.html (last accessed October 12, 2020); see
`
`also “ASML apparently beats Nikon for UMC’s huge 300-mm scanner order,” available at
`
`https://www.eetimes.com/asml-apparently-beats-nikon-for-umcs-huge-300-mm-scanner-order/
`
`(last accessed October 12, 2020); see also “ASML shares gain after reports of large TSMC
`
`order,” available at https://seekingalpha.com/news/3636158-asml-shares-gain-after-reports-of-
`
`large-tsmc-order (last visited Oct. 12, 2020); see also “ASML’s NXE Platform Performance,”
`
`available at http://euvlsymposium.lbl.gov/pdf/2013/pres/RudyPeeters.pdf (last visited Oct. 12,
`
`2020).
`
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 13 of 70
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`17.
`
`On information and belief, Renesas (directly or through its Renesas Foundry
`
`Partners such as TSMC) uses ASML’s YieldStar platform and/or its software to design, develop,
`
`or manufacture the Renesas YieldStar Products for importation into the United States for use,
`
`sale, and/or offer for sale in this district and throughout the United States.
`
`18.
`
`On information and belief, Defendant Renesas, directly and/or through one or
`
`more of the Renesas Foundry Partners (e.g., TSMC), employs camLine’s semiconductor
`
`fabrication or manufacturing solutions, including camLine’s LineWorks production automation
`
`solution (e.g., LineWorks eCap and LineWorks PULSE modules) (collectively, “LineWorks
`
`system”) and/or other in-house or third-party scheduling and dispatching platform hardware
`
`and/or software (e.g., with similar technical and functional features) to design, develop, and/or
`
`manufacture Defendant Renesas’s semiconductor devices, including integrated circuits. See,
`
`e.g., “Agile and Intelligent Operations,” available at
`
`https://www.tsmc.com/english/dedicatedFoundry/manufacturing/intelligent_operations.htm (last
`
`accessed Oct. 12, 2020); see also “Manufacturing Excellence,” available at
`
`https://www.tsmc.com/download/ir/annualReports/2012/english/e_5_3.html (last accessed Oct.
`
`12, 2020).
`
`19.
`
`Upon information and belief, TSMC employs camLine’s LineWorks system at
`
`TSMC’s manufacturing facilities. See, e.g., “LineWorks Product,” available at https://www.all-
`
`electronics.de/wp-
`
`content/uploads/migrated/document/97654/infodirectccamlineproductcatalog.pdf (last accessed
`
`Oct. 12, 2020) (“Customers … > TSMC”).
`
`20.
`
`On information and belief, Defendant Renesas (directly or through its Renesas
`
`Foundry Partners such as TSMC) employs camLine’s LineWorks system and/or other in-house
`
`
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`13
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 14 of 70
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`or third-party scheduling and dispatching platform hardware and/or software (e.g., with similar
`
`technical and functional features) at TSMC’s manufacturing facilities. On information and
`
`belief, Defendant Renesas employs similar in-house or proprietary scheduling and dispatching
`
`platform (with technical and functional features similar to camLine’s LineWorks system) at its
`
`own manufacturing facilities.
`
`21.
`
`On information and belief, Defendant Renesas (directly or through its Renesas
`
`Foundry Partners such as TSMC) employs camLine’s LineWorks system and/or other similar
`
`Renesas proprietary or third-party scheduling and dispatching platform hardware and/or software
`
`(e.g., with similar technical and functional features) to design, develop or manufacture one or
`
`more systems, products, and/or devices for importation into the United States for use, sale,
`
`and/or offer for sale in this District and throughout the United States, including, but not limited
`
`to, semiconductor products and devices, such as microcontrollers and microprocessors (e.g.,
`
`RL78 Family of 8/16-bit Ultra-Low Energy MCUs, RX Family of 32-bit High Power Efficiency
`
`MCUs, RH850 Family, RZ Family of 64-Bit & 32-Bit Arm-Based High-End MPUs, V850
`
`Family, 78K Family, R8C Family, M16C Family (R32C / M32C / M16C), M32R Family,
`
`H8/S/SX Family, 720 Family, 740 Family, SuperH RISC engine Family, H8 Super Low Power,
`
`PLC MCU, Renesas RA Family of 32-bit MCUs with Arm Cortex-M Core, RE Family, QzROM
`
`(740/720 Family), M16C (M32C/M16C) Family, R8C Family, 7700 Family, and SuperH RISC
`
`engine Family and MCUs with Arm Cortex-M Core Implemented on Silicon on Thin Buried
`
`Oxide (SOTB)), amplifiers and buffers (e.g., CA3XXX, CA5XXX, EL2XXX, EL4XXX,
`
`EL5XXX, EL8XXX, HA-2XXX, HA-5XXX, HFA11XX, ICL7XXX, ISL28XXX, ISL55XXX,
`
`ISL59XXX, READ23XXXSP, and UPCXXXXXX), analog products (e.g., switches and
`
`multiplexers), clocks and timing products (e.g., application-specific clocks, clock distribution,
`
`
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 15 of 70
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`clock generation, and crystal oscillators), interface & connectivity products (e.g., wireless
`
`modules, switches and hubs, and wireless modules), audio and video products (e.g., ISL54XXX),
`
`automotive products (e.g., Automotive System-on-Chip (SOC), Ambient Light Sensors, Analog
`
`ICs, Car Audio ICs, Battery Management Systems, CAN Transceivers, Discrete/Power MOFETs
`
`for Automotive, Display ICs, Intelligent Power Devices, Interface ICs, LSI for Automotive,
`
`Microcontrollers (RH850), Microcontrollers (RL78/F1x), Power Management (e.g., Power
`
`Management ICs for RH850, Power Supply ICs for R-Car, Switches & Multiplexers, Video ICs,
`
`Discrete Power Devices, regulators, MOSFETs and Motor Drivers, PMICs, and wireless power
`
`devices), ICs for Communications and Mobile Devices (e.g., SH-MobileR, SH-MobileR2,
`
`EMMA Mobile, SH-Mobile MT1, and R-Mobile A1), sensor products (e.g., flow sensors, gas
`
`sensors, humidity sensors, light & proximity sensors, position sensors, sensor signal
`
`conditioners, and optical sensors such as ISL76671), data converters (e.g., HI-565A, HI-
`
`565A/883, and HI5XXX), ICs for Industrial Automation (R-IN) (e.g. R-IN32M3, R-IN32M4-
`
`CL2, TPS-1, EC-1, R-IN32M4-CL3, and R-IN32M3), ICs for Motor Driver/Actuator Driver,
`
`Interface devices (e.g., Bus Buffers, RS-485, RS-422, RS-232, Signal Integrity ICs, Dual
`
`Protocol RS-485, RS-232 Transceivers, and Industrial Network Transceivers), Legacy MCUs
`
`(e.g., 80C/82C Microprocessors & Peripherals), memory (e.g., ultra-fast Quad Data Rate
`
`SRAMs, SRAMs, EEPROM & PROM, MRAMS, FIFO products, interface products, and
`
`standard logic), Optoelectronics, power management devices (e.g., RAJ240XXXDNP), RF
`
`products (e.g., modulators, demodulators, transistor arrays, beamformers, mixers, switches,
`
`attenuators, VGAs, synthesizers and PLLs), Renesas USB Power Delivery Family (e.g., Renesas
`
`USB Power Delivery Family Features and U30 Group), Secure MCUs (e.g., AE-5 Series and
`
`RS-4 Series), Smart Analog devices (e.g., Smart Analog IC101, IC300, IC301, IC500, IC501,
`
`
`
`15
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 16 of 70
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`and IC502), and space and harsh environment devices (e.g., µPD720115, µPD720201,
`
`µPD720202, µPD720210, µPD720211, M66291, R8A66593, and R8A66597), products
`
`manufactured at 28nm and 40nm technology node by TSMC for Renesas such as eFlash and
`
`MCUs, microprocessors, sensors, radars, power efficiency systems, electronic control units, and
`
`automotive products, and similar systems, products, devices, and integrated circuits (“Renesas
`
`Scheduling Products”).
`
`22.
`
`On information and belief, Defendant Renesas (directly or through its Renesas
`
`Foundry Partners such as TSMC) uses camLine’s LineWorks system and/or other Renesas in-
`
`house or third-party scheduling and dispatching platform hardware and/or software (e.g., with
`
`similar technical and functional features) to design, develop, or manufacture the Renesas
`
`Scheduling Products for importation into the United States for use, sale, and/or offer for sale in
`
`this district and throughout the United States.
`
`23.
`
`Defendant Renesas works with third parties to design and/or develop third party
`
`products, such as internet of things products, communications products, automotive products,
`
`computing products, and embedded products that include one or more Renesas APC Products,
`
`Renesas TWINSCAN Products, Renasas YieldStar Products, and/or Renesas Scheduling
`
`Products (“Third Party Products”). For example, on information and belief, Renesas is the
`
`world’s largest supplier of automotive microprocessors. Renesas assists third parties from the
`
`automotive industry, directly or through others, to import the Third Party Products into the
`
`United States and offer to sell, and sell, such Third Party Products in the United States.
`
`JURISDICTION AND VENUE
`
`24.
`
`This is an action for patent infringement arising under the patent laws of the
`
`United States, 35 U.S.C. § 1, et seq.
`
`
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`16
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`Case 6:20-cv-01213-ADA Document 1 Filed 12/31/20 Page 17 of 70
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`25.
`
`26.
`
`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
`
`Renesas is subject to this Court’s general and specific personal jurisdiction
`
`because Renesas has sufficient minimum contacts within the State of Texas and this District,
`
`pursuant to due process and/or the Texas Long Arm Statute, Tex. Civ. Prac. & Rem. Code §
`
`17.042. On information and belief, Renesas contracted with one or more Texas residents in this
`
`District and one or both parties performed the contract at least in part in the State of Texas and
`
`this District; Renesas committed the tort of patent infringement in State of Texas and this
`
`District; Ren