Case 6:20-cv-01214-ADA Document 61 Filed 03/11/22 Page 1 of 6
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`CLERK, U.S. DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
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`BY: ________________________________
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`FILED
`
`DEPUTY
`
`March 11, 2022
`
`lad
`
`
`
`CLERK, U.S. DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`
`BY: ________________________________
`
`FILED
`
`DEPUTY
`
`March 11, 2022
`
`lad
`
`
`
`Case 6:20-cv-01214-ADA Document 61 Filed 03/11/22 Page 2 of 6
`Case 6:20-cv-01214-ADA Document 61 Filed 03/11/22 Page 2 of 6
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`Plaintiff
`
`Vv.
`
`Renesas Electronics Corporation and Renesas
`Electronics America,Inc.,
`
`Defendants.
`
`
`
`Ocean Semiconductor LLC,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ocean Semiconductor LLC,
`
`Plaintiff
`
`v.
`
`Silicon Laboratories Inc.,
`
`Defendant.
`
`Ocean Semiconductor LLC,
`
`Plaintiff
`
`v.
`
`STMicroelectronics,Inc.,
`
`Defendant.
`
`Civil Action No.: 6:20-cv-1213-ADA
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`JURY TRIAL DEMANDED
`
`PATENT CASE
`
`Civil Action No.: 6:20-cv-1214-ADA
`
`JURY TRIAL DEMANDED
`
`PATENT CASE
`
`Civil Action No.: 6:20-cv-1215-ADA
`
`JURY TRIAL DEMANDED
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`PATENT CASE
`
`
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`Case 6:20-cv-01214-ADA Document 61 Filed 03/11/22 Page 3 of 6
`Case 6:20-cv-01214-ADA Document 61 Filed 03/11/22 Page 3 of 6
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`Plaintiff
`
`v.
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`
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`Ocean Semiconductor LLC,
`
`
`
`Western Digital Technologies, Inc.
`
`
`
`Civil Action No.: 6:20-cv-1216-ADA
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`JURY TRIAL DEMANDED
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`PATENT CASE
`
`Defendant.
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`TO THE APPROPRIATE CENTRAL AUTHORITYOF JAPAN:
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`The United States District Court for the Western District of Texas presents its
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`compliments to the appropriate Central Authority of Japan, and requestsjudicial assistance to
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`obtain evidence to be used in a civil proceeding before this Court in the above-captioned matters.
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`The Court requests the assistance described herein as necessary in the interests ofjustice.
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`I. REQUEST
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`The Court requests that the appropriate Central Authority ofJapan compe! production of
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`documents andtestimony ofa representative or representatives from the following corporate
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`entity:
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`Kioxia Corporation
`3-1-21, Shibaura, Minato-ku
`Tokyo 108-0023
`Japan
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`Kioxia Corporation is represented by:
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`Doug Stewart
`BRACEWELL LLP
`701 Fifth Avenue Suite 6200
`Seattle, WA 98104
`Telephone: (206) 204-6721
`Doug.Stewart@bracewell.com
`
`
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`Case 6:20-cv-01214-ADA Document 61 Filed 03/11/22 Page 4 of 6
`Case 6:20-cv-01214-ADA Document 61 Filed 03/11/22 Page 4 of 6
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`Specifically, the Court requests that Kioxia Corporation (“Kioxia”) produce the
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`documents and things set forth in AttachmentA to this Request and thereafter produce a witness
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`or witnessesto testify regarding the deposition topics set forth in Attachment A. The Court
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`requests that the witness be placed underoath, subject to questioning by counselfor the parties to
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`the above-captioned matters, and that a verbatim transcript of the testimony be taken.
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`The Court understands that the documents and information requested may be of a
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`confidential nature. As such,there is a Protective Orderin this case to protect the confidentiality
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`of any documents produced. A copyofthe Protective Order is appended to Attachment A.
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`If service cannotbe effected at the address indicated above, this Court respectfully
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`requests judicial assistance to effect service by any means permitted under Japaneselaw.
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`This Court further requests that the executed Letters Rogatory and any evidence produced
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`in response be sent directly to counsel for the Requesting Party, Ocean Semiconductor LLC
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`(“Ocean Semiconductor”), at the following address:
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`Alex Chan
`Devlin Law Firm LLC
`1526 Gilpin Avenue
`Wilmington, DE 19806
`achan@devlinlawfirm.com
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`I. FACTS
`
`Plaintiff Ocean Semiconductorhas filed lawsuits against Defendants Mediatek Inc. and
`Mediatek USA Inc. (““Mediatek”), NVIDIA Corporation (“NVIDIA”), NXP USA, Inc. (“NXP”),
`Renesas Electronics Corporation and Renesas Electronics America,Inc. (“Renesas”), Silicon
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`Laboratories Inc. (“Silicon Labs”), STMicroelectronics, Inc. (“STMicro”), and Western Digital
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`Technologies,Inc. (“WD”) (collectively “Defendants”) in the United States District Court for the
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`Western District of Texas as reflected in the caption above. Ocean seeks a judgmentthat
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`Defendants infringe U.S. Patent Nos. 6,660,651, 6,907,305, 6,725,402, 6,968,248, 7,080,330,
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`
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`Case 6:20-cv-01214-ADA Document 61 Filed 03/11/22 Page 5of6
`Case 6:20-cv-01214-ADA Document 61 Filed 03/11/22 Page 5 of 6
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`6,836,691, and 8,676,538 (collectively, the “Asserted Patents”).! Ocean Semiconductor seeks an
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`award of damages from Defendants to compensate for the alleged patent infringement. The
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`technology described and claimed in the Asserted Patents relates to, among other things, the use
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`of a movable waferstage, fault detection, process scheduling, and measurementofcritical
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`dimension and overlay in semiconductor manufacturing.
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`In response to Ocean Semiconductor’s infringement claims, Defendants have asserted
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`defensesthat include noninfringement, patent exhaustion,license, and implied license. The
`documents requested in AttachmentA are critical to Ocean Semiconductor’s ability to
`demonstrate Defendants’ infringementofthe Asserted Patents and to properly and fully respond
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`to Defendants’ defenses.
`|
`III. OFFER OF RECIPROCAL ASSISTANCE
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`The United States District Court for the Western District of Texas is willing to provide
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`similar assistance to the appropriate Central Authority of Japan. See 28 U.S.C.§ 1782.
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`IV. REIMBURSEMENTFOR COSTS
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`This Court, through Plaintiff Ocean Semiconductor, is willing to reimburse the
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`appropriate Central Authority of Japan for costs and expenses incurred in executing these Letters
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`Rogatory.
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`' Ocean also seeks a judgment against NXP and STMicro for infringement of U.S. Patent No.
`6,420,097. However, Oceanis not presently seeking information from Kioxia related to those
`claims.
`
`iii
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`
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`Case 6:20-cv-01214-ADA Document 61 Filed 03/11/22 Page 6 of 6
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`A true copy of the original, I certify.
`Clerk, U.S. District Court
`By___________________________
`Deputy
`
`Leigh Diaz
`
`March 11, 2022
`
`
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