Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 1 of 78
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`Ocean Semiconductor LLC,
`
`Plaintiff
`
`v.
`
`STMicroeletronics, Inc. (“STMicro”),
`
`Defendant.
`
`Civil Action No.: 6:20-cv-1215
`
`JURY TRIAL DEMANDED
`
`PATENT CASE
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Ocean Semiconductor LLC (“Ocean Semiconductor” or “Plaintiff”) files this
`
`Complaint against STMicroelectronics, Inc. (“STMicro” or “Defendant”), seeking damages and
`
`other relief for patent infringement, and alleges with knowledge to its own acts, and on information
`
`and belief as to other matters, as follows:
`
`NATURE OF THE ACTION
`
`1.
`
`This is an action for patent infringement arising under the Patent Laws of the
`
`United States, 35 U.S.C. § 1 et seq.
`
`THE PARTIES
`
`2.
`
`Plaintiff Ocean Semiconductor is a limited liability company organized and
`
`existing under the laws of the State of Delaware, and its registered agent for service of process in
`
`Delaware is Rita Carnevale, 717 N. Union Street, Wilmington, DE 19805.
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 2 of 78
`
`3.
`
`On information and belief, STMicro is a Delaware corporation with a principal
`
`place of business at 8501 North Mo-Pac Expy, Suite 420, Austin, TX 78759. On information
`
`and belief, Defendant may be served through its registered agent, CT Corporation, at 1999 Bryan
`
`St., Suite 900, Dallas, TX 75201.
`
`4.
`
`On information and belief, Defendant STMicro sells, offers to sell, and/or uses
`
`products and services throughout the United States, including in this judicial District, and
`
`introduces infringing products and services into the stream of commerce knowing that they
`
`would be sold and/or used in this judicial District and elsewhere in the United States.
`
`5.
`
`Plaintiff Ocean Semiconductor is the assignee and owner of the patents at issue in
`
`this action: U.S. Patents Nos. 6,660,651, 6,907,305, 6,725,402, 6,968,248, 6,420,097, 7,080,330,
`
`6,836,691, and 8,676,538 (collectively, the “Asserted Patents”). Ocean Semiconductor holds all
`
`substantial rights, title, and interest in the Asserted Patents, including the exclusive right to sue
`
`STMicro for infringement and recover damages, including damages for past infringement.
`
`6.
`
`Plaintiff Ocean Semiconductor seeks monetary damages and prejudgment interest
`
`for Defendant’s past and ongoing direct and indirect infringement of the Asserted Patents.
`
`7.
`
`Defendant STMicro is a semiconductor company that designs, develops, sells,
`
`offers to sell, and imports into the United States semiconductor products in the communications,
`
`internet of things, automotive, computer, and consumer electronics industry (“Accused
`
`Products”).
`
`8.
`
`Defendant STMicro, which has its own design centers in the United States
`
`(including a facility in Austin, Texas), produces or contracts with third-party semiconductor
`
`fabricators or foundries (“STMicro Foundry Partners”) that own, operate, or control
`
`semiconductor fabrication plants (“fabs”) within and/or outside of the United States
`
`
`
`2
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 3 of 78
`
`(“International Facilities”) to produce the Accused Products. One such STMicro Foundry
`
`Partner is Taiwan Semiconductor Manufacturing Company Ltd. (“TSMC”). TSMC has a
`
`contractual partnership with STMicro to design, develop, or manufacture semiconductor
`
`products including integrated circuits for STMicro. See, e.g., “STMicro and TSMC Collaborate
`
`to Accelerate Gallium Nitride Adoption,” available at https://eepower.com/news/stmicro-and-
`
`tsmc-collaborate-to-accelerate-gallium-nitride-adoption/# (last accessed Oct. 12, 2020); see also
`
`“Philips, STMicroelectronics and TSMC take lead in advanced 90-nanometer CMOS process
`
`technologies,” available at https://investors.st.com/news-releases/news-release-details/philips-
`
`stmicroelectronics-and-tsmc-take-lead-advanced-90 (last accessed Oct. 12, 2020).
`
`9.
`
`On information and belief, Defendant STMicro (directly or through one or more
`
`of its Foundry Partners) also has a contractual relationship with United Microelectronics Corp.
`
`(“UMC”). See, e.g., “STMicro, UMC forge technology alliance,” available at
`
`https://www.design-reuse.com/news/3581/stmicro-umc-forge-technology-alliance.html (last
`
`accessed Oct. 12, 2020); see also “STMicro extends foundry deal with UMC,”
`
`https://www.eetimes.com/stmicro-extends-foundry-deal-with-umc/ (last accessed Oct. 12, 2020);
`
`“UMC to Develop 65nm BSI CMOS Image Sensor Process with STMicroelectronics,” available
`
`at https://www.prnewswire.com/news-releases/umc-to-develop-65nm-bsi-cmos-image-sensor-
`
`process-with-stmicroelectronics-168739446.html (last accessed Oct. 12, 2020). UMC has a
`
`contractual partnership with STMicro to design, develop, or manufacture semiconductor
`
`products including integrated circuits for STMicro.
`
`10.
`
`On information and belief, Defendant STMicro (directly or through one or more
`
`of its Foundry Partners such as TSMC and/or UMC) has a contractual relationship with Applied
`
`Materials, Inc. (“Applied Materials”) (see Applied Materials’ job posting for “TSMC F15 E3
`
`
`
`3
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 4 of 78
`
`project,” available at
`
`http://www.mse.ntu.edu.tw/attachments/article/154/AMT_Summer%20Student%20Program_Job
`
`%20Post_2013.pdf (last accessed October 12, 2020) and PDF Solutions Inc. (“PDF Solutions”)
`
`(e.g., “Taiwan Semiconductor Manufacturing Company adopts PDF Solutions yield
`
`improvement technology,” available at https://www.edn.com/taiwan-semiconductor-
`
`manufacturing-company-adopts-pdf-solutions-yield-improvement-technology/ (last accessed
`
`Oct. 12, 2020); see also “Exensio: Big Data in the Fab,” available at
`
`https://semiwiki.com/eda/4351-exensio-big-data-in-the-fab/ (last accessed Oct. 12, 2020)), and
`
`one or more of the STMicro Foundry Partners (e.g., TSMC) employ Applied Materials’
`
`semiconductor fabrication or manufacturing equipment, platforms, and/or framework, including
`
`Applied Materials’ E3 system, including the E3 factory advanced/automation process control
`
`(“APC”) hardware and/or software (collectively, “E3 system”), PDF Solutions’ Exensio
`
`hardware and/or software (collectively, “Exensio system”), and/or other in-house or third-party
`
`advanced/automation process control system and platform hardware and/or software (e.g., with
`
`similar technical and functional features) to design, develop, and/or manufacture Defendant
`
`STMicro’s semiconductor devices, including integrated circuits.
`
`11.
`
`Upon information and belief, TSMC employs Applied Materials’ and/or PDF
`
`Solutions’ semiconductor fabrication or manufacturing equipment, platforms, and/or framework
`
`(e.g., Applied Materials’ E3 system and/or PDF Solutions’ Exensio system) at TSMC’s
`
`manufacturing facilities. Applied Materials has received supplier awards and recognition from
`
`TSMC. See, e.g., “TSMC Recognizes Outstanding Suppliers at Supply Chain Management
`
`Forum,” available at https://pr.tsmc.com/english/news/1873 (last accessed October 12, 2020).
`
`
`
`4
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 5 of 78
`
`12.
`
`TSMC also employs CamLine GmbH’s (“camLine”) semiconductor fabrication or
`
`manufacturing equipment, platforms, and/or framework. On information and belief, STMicro
`
`and TSMC employ 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 advanced/automation process
`
`control system and platform software (e.g., with similar technical and functional features) to
`
`design, develop, and/or manufacture Defendant STMicro’s semiconductor devices, including
`
`integrated circuits (see, e.g., “‘camLine increased our process integrity and reduced tool set-up
`
`times,’ Corporate IT Manufacturing manager, STMicroelectronics,” available at
`
`https://www.camline.com/ (last accessed Oct. 12, 2020)); see also “How to improve more quality
`
`in a fully automated 300mm factory,” at 1, available at https://docplayer.net/56582619-How-to-
`
`improve-more-quality-in-a-fully-automated-300mm-factory.html (last accessed Oct. 12, 2020)
`
`(“In one of its state-of-the-art fully automated 300mm factories, STMicroelectronics is driving
`
`successfully quality improvements with a long camLine partnership using several solutions on
`
`SPC, recipe integrity, and SQM making camLine key software supplier to STMicroelectronics”).
`
`13.
`
`On information and belief, Defendant STMicro (directly or through its Foundry
`
`Partners such as TSMC) employs Applied Materials’ E3 system, PDF Solutions’ Exensio
`
`system, and/or camLine’s LineWorks system 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 semiconductor products and devices, including
`
`advanced driver assistance systems (e.g., STV0991, STV0991, VG5761, STRADA431,
`
`STRADA770M), MEMS and sensor products (e.g., AIS1120SX, AIS1200PS, AIS2120SX,
`
`
`
`5
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 6 of 78
`
`AIS2DW12, AIS328DQ, AIS3624DQ, H3LIS100DL, H3LIS200DL, H3LIS331DL, IIS2DH,
`
`IIS2DLPC, IIS2ICLX, IIS328DQ, IIS3DHHC, IIS3DWB, LIS25BA, LIS2DE12, LIS2DH,
`
`LIS2DH12, LIS2DS12, LIS2DTW12, LIS2DW, LIS2DW12, LIS2HH12, LIS331DLH,
`
`LIS331HH, LIS344ALH, LIS3DH, LIS3DHH, LIS3DSH, LIS3LV02DL, MIS2DH, AIS326DQ,
`
`A3G4250D, AIS1120SX, AIS1200PS, AIS2120SX, AIS2DW12, AIS328DQ, AIS3624DQ,
`
`ASM330LHH, VL53L0X, VL53L1CB, VL53L1X, VL53L3CX, VL6180V1, VL6180X),
`
`microcontrollers (e.g., STM32F410C8, STM32F411RC, STM32F412CE, STM32F412RE,
`
`STM32413RH, STM32F423VH, STM32F439ZG, STM32F446ME, STM32723VC,
`
`STM32F732VE, STM32F767NI, STM32H723VE, STM32H723VG, STM32H23ZE,
`
`STM32H723ZG, STM32H725AE, STM32725AG, STM32725IE, STM32H725IG,
`
`STM32H725RE, STM32H725RG, STM32H725VE, STM32H725VG, STM32H725ZE,
`
`STM32H725ZG, STM32H725ZG, STM32H725ZG, STM32H730AB, STM32730IB,
`
`STM32H730VB, STM32H730ZB, STM32H733VG, STM32H733ZG, STM32H735AG,
`
`STM32H735IG, STM32H735RG, STM32H735VG, STM32H735ZG, STM32F205RB,
`
`STM32F205RB, STM32205RC, STM32F205RE, STM32F205RF, STM32F205RG,
`
`STM32F205VB, STMF205VC, STMF205VE, STM32F205VF, STMF205VG, STM32F205ZC,
`
`STM32F205ZE, STM32F205ZF, STMF205ZG), microprocessors, amplifiers, diodes, rectifiers,
`
`comparators, automotive devices, clocks and timers, converters, set-top boxes ICs, logic ICs,
`
`transceivers, memories, drivers, transistors, switches, voltage regulators, systems-on-chip (SoC),
`
`or similar products for mobile devices, wearables, banking, identification, industrial,
`
`communications, energy, automotive, personal electronics, sensing, cloud, and Internet of Things
`
`applications, and similar systems, products, devices, and integrated circuits (“STMicro APC
`
`Products”).
`
`
`
`6
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 7 of 78
`
`14.
`
`On information and belief, Defendant STMicro (directly or through its STMicro
`
`Foundry Partners) uses Applied Materials’ E3 system, PDF Solutions’ Exensio, and/or camLine
`
`LineWorks system to design, develop, or manufacture the STMicro APC Products for
`
`importation into the United States for use, sale, and/or offer for sale in this district and
`
`throughout the United States.
`
`15.
`
`On information and belief, Defendant STMicro (directly and/or through its
`
`STMicro Foundry Partners such as TSMC and/or UMC) has a contractual relationship with
`
`ASML Holding N.V. and/or its subsidiaries (“ASML”) (see, e.g., “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 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’s NXE Platform Performance,” available at
`
`http://euvlsymposium.lbl.gov/pdf/2013/pres/RudyPeeters.pdf (last visited Oct. 12, 2020); see
`
`also “UMC buys equipment from ASML,” available at
`
`https://www.digitimes.com/news/a20160621PM200.html (last visited Oct. 12, 2020); see also
`
`“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 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
`
`
`
`7
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 8 of 78
`
`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 one or more of the
`
`STMicro Foundry Partners employ 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 STMicro’s semiconductor
`
`products and devices, such as semiconductor products and devices, such as advanced driver
`
`assistance systems (e.g., STV0991, STV0991, VG5761, STRADA431, STRADA770M), MEMS
`
`and sensor products (e.g., AIS1120SX, AIS1200PS, AIS2120SX, AIS2DW12, AIS328DQ,
`
`AIS3624DQ, H3LIS100DL, H3LIS200DL, H3LIS331DL, IIS2DH, IIS2DLPC, IIS2ICLX,
`
`IIS328DQ, IIS3DHHC, IIS3DWB, LIS25BA, LIS2DE12, LIS2DH, LIS2DH12, LIS2DS12,
`
`LIS2DTW12, LIS2DW, LIS2DW12, LIS2HH12, LIS331DLH, LIS331HH, LIS344ALH,
`
`LIS3DH, LIS3DHH, LIS3DSH, LIS3LV02DL, MIS2DH, AIS326DQ, A3G4250D, AIS1120SX,
`
`AIS1200PS, AIS2120SX, AIS2DW12, AIS328DQ, AIS3624DQ, ASM330LHH, VL53L0X,
`
`VL53L1CB, VL53L1X, VL53L3CX, VL6180V1, VL6180X), microcontrollers (e.g.,
`
`STM32F410C8, STM32F411RC, STM32F412CE, STM32F412RE, STM32413RH,
`
`STM32F423VH, STM32F439ZG, STM32F446ME, STM32723VC, STM32F732VE,
`
`STM32F767NI, STM32H723VE, STM32H723VG, STM32H23ZE, STM32H723ZG,
`
`STM32H725AE, STM32725AG, STM32725IE, STM32H725IG, STM32H725RE,
`
`STM32H725RG, STM32H725VE, STM32H725VG, STM32H725ZE, STM32H725ZG,
`
`STM32H725ZG, STM32H725ZG, STM32H730AB, STM32730IB, STM32H730VB,
`
`
`
`8
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 9 of 78
`
`STM32H730ZB, STM32H733VG, STM32H733ZG, STM32H735AG, STM32H735IG,
`
`STM32H735RG, STM32H735VG, STM32H735ZG, STM32F205RB, STM32F205RB,
`
`STM32205RC, STM32F205RE, STM32F205RF, STM32F205RG, STM32F205VB,
`
`STMF205VC, STMF205VE, STM32F205VF, STMF205VG, STM32F205ZC, STM32F205ZE,
`
`STM32F205ZF, STMF205ZG), microprocessors, amplifiers, diodes, rectifiers, comparators,
`
`automotive devices, clocks and timers, converters, set-top boxes ICs, logic ICs, transceivers,
`
`memories, drivers, transistors, switches, voltage regulators, systems-on-chip (SoC), or similar
`
`products for mobile devices, wearables, banking, identification, industrial, communications,
`
`energy, automotive, personal electronics, sensing, cloud, and Internet of Things applications, and
`
`similar systems, products, devices, and integrated circuits (“STMicro TWINSCAN Products”).
`
`16.
`
`On information and belief, Defendant STMicro (directly or through its STMicro
`
`Foundry Partners such as TSMC and/or UMC) uses ASML’s TWINSCAN platform and/or its
`
`software to design, develop, or manufacture the STMicro TWINSCAN Products for importation
`
`into the United States for use, sale, and/or offer for sale in this district and throughout the United
`
`States.
`
`17.
`
`On information and belief, Defendant STMicro (directly and/or through its
`
`STMicro Foundry Partners) has a contractual relationship with ASML and/or its subsidiaries
`
`(see, e.g., “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 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’s NXE
`
`Platform Performance,” available at
`
`
`
`9
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 10 of 78
`
`http://euvlsymposium.lbl.gov/pdf/2013/pres/RudyPeeters.pdf (last visited Oct. 12, 2020); see
`
`also “UMC buys equipment from ASML,” available at
`
`https://www.digitimes.com/news/a20160621PM200.html (last visited Oct. 12, 2020); see also
`
`“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 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 one or more of the
`
`STMicro Foundry Partners (e.g., TSMC and/or UMC) employ ASML’s metrology and
`
`inspection systems (e.g., ASML’s YieldStar metrology and inspection system hardware and
`
`software or “YieldStar system”) to design, develop, and/or manufacture Defendant STMicro’s
`
`semiconductor products and devices, including semiconductor products and devices, such as
`
`advanced driver assistance systems (e.g., STV0991, STV0991, VG5761, STRADA431,
`
`STRADA770M), MEMS and sensor products (e.g., AIS1120SX, AIS1200PS, AIS2120SX,
`
`AIS2DW12, AIS328DQ, AIS3624DQ, H3LIS100DL, H3LIS200DL, H3LIS331DL, IIS2DH,
`
`IIS2DLPC, IIS2ICLX, IIS328DQ, IIS3DHHC, IIS3DWB, LIS25BA, LIS2DE12, LIS2DH,
`
`
`
`10
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 11 of 78
`
`LIS2DH12, LIS2DS12, LIS2DTW12, LIS2DW, LIS2DW12, LIS2HH12, LIS331DLH,
`
`LIS331HH, LIS344ALH, LIS3DH, LIS3DHH, LIS3DSH, LIS3LV02DL, MIS2DH, AIS326DQ,
`
`A3G4250D, AIS1120SX, AIS1200PS, AIS2120SX, AIS2DW12, AIS328DQ, AIS3624DQ,
`
`ASM330LHH, VL53L0X, VL53L1CB, VL53L1X, VL53L3CX, VL6180V1, VL6180X),
`
`microcontrollers (e.g., STM32F410C8, STM32F411RC, STM32F412CE, STM32F412RE,
`
`STM32413RH, STM32F423VH, STM32F439ZG, STM32F446ME, STM32723VC,
`
`STM32F732VE, STM32F767NI, STM32H723VE, STM32H723VG, STM32H23ZE,
`
`STM32H723ZG, STM32H725AE, STM32725AG, STM32725IE, STM32H725IG,
`
`STM32H725RE, STM32H725RG, STM32H725VE, STM32H725VG, STM32H725ZE,
`
`STM32H725ZG, STM32H725ZG, STM32H725ZG, STM32H730AB, STM32730IB,
`
`STM32H730VB, STM32H730ZB, STM32H733VG, STM32H733ZG, STM32H735AG,
`
`STM32H735IG, STM32H735RG, STM32H735VG, STM32H735ZG, STM32F205RB,
`
`STM32F205RB, STM32205RC, STM32F205RE, STM32F205RF, STM32F205RG,
`
`STM32F205VB, STMF205VC, STMF205VE, STM32F205VF, STMF205VG, STM32F205ZC,
`
`STM32F205ZE, STM32F205ZF, STMF205ZG), microprocessors, amplifiers, diodes, rectifiers,
`
`comparators, automotive devices, clocks and timers, converters, set-top boxes ICs, logic ICs,
`
`transceivers, memories, drivers, transistors, switches, voltage regulators, systems-on-chip (SoC),
`
`or similar products for mobile devices, wearables, banking, identification, industrial,
`
`communications, energy, automotive, personal electronics, sensing, cloud, and Internet of Things
`
`applications, and similar systems, products, devices, and integrated circuits (“STMicro YieldStar
`
`Products”).
`
`18.
`
`On information and belief, Defendant STMicro (directly or through its STMicro
`
`Foundry Partners such as TSMC and/or UMC) uses ASML’s YieldStar metrology and inspection
`
`
`
`11
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 12 of 78
`
`system or platform and/or its software to design, develop, or manufacture the STMicro YieldStar
`
`Products for importation into the United States for use, sale, and/or offer for sale in this district
`
`and throughout the United States.
`
`19.
`
`On information and belief, Defendant STMicro, directly and/or through one or
`
`more of the STMicro Foundry Partners (e.g., TSMC), employs its own scheduling and
`
`dispatching platform (i.e., its own proprietary), camLine’s LineWorks systems, and/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 STMicro’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); see also “LineWorks Products,” available at https://www.all-electronics.de/wp-
`
`content/uploads/migrated/document/97654/infodirectccamlineproductcatalog.pdf (last accessed
`
`Oct. 12, 2020); see also “How to improve more quality in a fully automated 300mm factory,”
`
`available at https://docplayer.net/56582619-How-to-improve-more-quality-in-a-fully-automated-
`
`300mm-factory.html (last accessed Oct. 12, 2020).
`
`20.
`
`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”).
`
`
`
`12
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 13 of 78
`
`21.
`
`On information and belief, Defendant STMicro (directly or through its STMicro
`
`Foundry Partners such as TSMC) employs camLine’s LineWorks system at TSMC’s
`
`manufacturing facilities. On information and belief, Defendant STMicro employs camLine’s
`
`LineWorks system and/or similar proprietary scheduling and dispatching platform (with
`
`technical and functional features similar to camLine’s LineWorks system) at STMicro’s own
`
`manufacturing facilities.
`
`22.
`
`On information and belief, Defendant STMicro (directly or through its STMicro
`
`Foundry Partners such as TSMC) employs camLine’s LineWorks system and/or other similar
`
`STMicro 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 advanced driver assistance systems (e.g.,
`
`STV0991, STV0991, VG5761, STRADA431, STRADA770M), MEMS and sensor products
`
`(e.g., AIS1120SX, AIS1200PS, AIS2120SX, AIS2DW12, AIS328DQ, AIS3624DQ,
`
`H3LIS100DL, H3LIS200DL, H3LIS331DL, IIS2DH, IIS2DLPC, IIS2ICLX, IIS328DQ,
`
`IIS3DHHC, IIS3DWB, LIS25BA, LIS2DE12, LIS2DH, LIS2DH12, LIS2DS12, LIS2DTW12,
`
`LIS2DW, LIS2DW12, LIS2HH12, LIS331DLH, LIS331HH, LIS344ALH, LIS3DH, LIS3DHH,
`
`LIS3DSH, LIS3LV02DL, MIS2DH, AIS326DQ, A3G4250D, AIS1120SX, AIS1200PS,
`
`AIS2120SX, AIS2DW12, AIS328DQ, AIS3624DQ, ASM330LHH, VL53L0X, VL53L1CB,
`
`VL53L1X, VL53L3CX, VL6180V1, VL6180X), microcontrollers (e.g., STM32F410C8,
`
`STM32F411RC, STM32F412CE, STM32F412RE, STM32413RH, STM32F423VH,
`
`STM32F439ZG, STM32F446ME, STM32723VC, STM32F732VE, STM32F767NI,
`
`
`
`13
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 14 of 78
`
`STM32H723VE, STM32H723VG, STM32H23ZE, STM32H723ZG, STM32H725AE,
`
`STM32725AG, STM32725IE, STM32H725IG, STM32H725RE, STM32H725RG,
`
`STM32H725VE, STM32H725VG, STM32H725ZE, STM32H725ZG, STM32H725ZG,
`
`STM32H725ZG, STM32H730AB, STM32730IB, STM32H730VB, STM32H730ZB,
`
`STM32H733VG, STM32H733ZG, STM32H735AG, STM32H735IG, STM32H735RG,
`
`STM32H735VG, STM32H735ZG, STM32F205RB, STM32F205RB, STM32205RC,
`
`STM32F205RE, STM32F205RF, STM32F205RG, STM32F205VB, STMF205VC,
`
`STMF205VE, STM32F205VF, STMF205VG, STM32F205ZC, STM32F205ZE,
`
`STM32F205ZF, STMF205ZG), microprocessors, amplifiers, diodes, rectifiers, comparators,
`
`automotive devices, clocks and timers, converters, set-top boxes ICs, logic ICs, transceivers,
`
`memories, drivers, transistors, switches, voltage regulators, systems-on-chip (SoC), or similar
`
`products for mobile devices, wearables, banking, identification, industrial, communications,
`
`energy, automotive, personal electronics, sensing, cloud, and Internet of Things applications, and
`
`similar systems, products, devices, and integrated circuits (“STMicro Scheduling Products”).
`
`23.
`
`On information and belief, Defendant STMicro (directly or through its STMicro
`
`Foundry Partners such as TSMC) uses camLine’s 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, or manufacture the STMicro Scheduling
`
`Products for importation into the United States for use, sale, and/or offer for sale in this district
`
`and throughout the United States. 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”).
`
`
`
`14
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 15 of 78
`
`24.
`
`On information and belief, Defendant STMicro (directly and/or through its
`
`STMicro Foundry Partners) employs the infringing method of forming circuit structures to
`
`design, develop, and/or manufacture Defendant STMicro’s semiconductor products and devices,
`
`such as advanced driver assistance systems (e.g., STV0991, STV0991, VG5761, STRADA431,
`
`STRADA770M), MEMS and sensor products (e.g., AIS1120SX, AIS1200PS, AIS2120SX,
`
`AIS2DW12, AIS328DQ, AIS3624DQ, H3LIS100DL, H3LIS200DL, H3LIS331DL, IIS2DH,
`
`IIS2DLPC, IIS2ICLX, IIS328DQ, IIS3DHHC, IIS3DWB, LIS25BA, LIS2DE12, LIS2DH,
`
`LIS2DH12, LIS2DS12, LIS2DTW12, LIS2DW, LIS2DW12, LIS2HH12, LIS331DLH,
`
`LIS331HH, LIS344ALH, LIS3DH, LIS3DHH, LIS3DSH, LIS3LV02DL, MIS2DH, AIS326DQ,
`
`A3G4250D, AIS1120SX, AIS1200PS, AIS2120SX, AIS2DW12, AIS328DQ, AIS3624DQ,
`
`ASM330LHH, VL53L0X, VL53L1CB, VL53L1X, VL53L3CX, VL6180V1, VL6180X),
`
`microcontrollers (e.g., STM32F410C8, STM32F411RC, STM32F412CE, STM32F412RE,
`
`STM32413RH, STM32F423VH, STM32F439ZG, STM32F446ME, STM32723VC,
`
`STM32F732VE, STM32F767NI, STM32H723VE, STM32H723VG, STM32H23ZE,
`
`STM32H723ZG, STM32H725AE, STM32725AG, STM32725IE, STM32H725IG,
`
`STM32H725RE, STM32H725RG, STM32H725VE, STM32H725VG, STM32H725ZE,
`
`STM32H725ZG, STM32H725ZG, STM32H725ZG, STM32H730AB, STM32730IB,
`
`STM32H730VB, STM32H730ZB, STM32H733VG, STM32H733ZG, STM32H735AG,
`
`STM32H735IG, STM32H735RG, STM32H735VG, STM32H735ZG, STM32F205RB,
`
`STM32F205RB, STM32205RC, STM32F205RE, STM32F205RF, STM32F205RG,
`
`STM32F205VB, STMF205VC, STMF205VE, STM32F205VF, STMF205VG, STM32F205ZC,
`
`STM32F205ZE, STM32F205ZF, STMF205ZG), microprocessors, amplifiers, diodes, rectifiers,
`
`comparators, automotive devices, clocks and timers, converters, set-top boxes ICs, logic ICs,
`
`
`
`15
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 16 of 78
`
`transceivers, memories, drivers, transistors, switches, voltage regulators, systems-on-chip (SoC),
`
`or similar products for mobile devices, wearables, banking, identification, industrial,
`
`communications, energy, automotive, personal electronics, sensing, cloud, and Internet of Things
`
`applications, and similar systems, products, devices, and integrated circuits (“STMicro Sub-
`
`30nm Products”).
`
`25.
`
`On information and belief, Defendant STMicro (directly or through its STMicro
`
`Foundry Partners) uses this infringing method to fabricate or manufacture the STMicro Sub-
`
`30nm Products for importation into the United States for use, sale, and/or offer for sale in this
`
`district and throughout the United States.
`
`26.
`
`Defendant STMicro works with third parties to design and/or develop third party
`
`products, such as semiconductor products and devices, including devices for mobile devices,
`
`wearables, banking, identification, industrial, automotive and Internet of Things applications that
`
`include one or more STMicro APC Products, STMicro Scheduling Products, STMicro
`
`TWINSCAN Products, STMicro YieldStar Products, and/or STMicro Sub 30-nm Products
`
`(“Third Party Products”). STMicro assists third parties, 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
`
`27.
`
`This is an action for patent infringement arising under the patent laws of the
`
`United States, 35 U.S.C. § 1, et seq.
`
`28.
`
`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
`
`
`
`16
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 17 of 78
`
`29.
`
`STMicro is subject to this Court’s general personal jurisdiction at least because
`
`STMicro is a resident of Texas as defined by Texas law. On information and belief, STMicro is
`
`headquartered in Coppell, Texas.
`
`30.
`
`STMicro is additionally subject to this Court’s general and specific personal
`
`jurisdiction because STMicro 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, STMicro 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; STMicro committed the tort of patent infringement in State of Texas
`
`and this District; STMicro purposefully availed itself of the privileges of conducting business in
`
`the State of Texas and in this District; STMicro regularly conducts and solicits business within
`
`the State of Texas and within this District; STMicro recruits residents of the State of Texas and
`
`this District for employment inside or outside the State of Texas; Plaintiff’s causes of action arise
`
`directly from STMicro’s business contacts and other activities in the State of Texas and this
`
`District; and STMicro designs, develops, manufactures, distributes, makes available, imports,
`
`sells and offers to sell products and services throughout the United States, including in this
`
`judicial District, and introduces infringing products and services that into the stream of
`
`commerce knowing that they would be used and sold in this judicial district and elsewhere in the
`
`United States.
`
`31.
`
`Venue is proper in this judicial district under 28 U.S.C. § 1391 and 28 U.S.C. §
`
`1400(b). On information and belief, STMicro has a regular and established place of business in
`
`this District, including at least 8501 North Mo-Pac Expy, Suite 420, Austin, TX 78759.
`
`
`
`17
`
`

`

`
`
`
`
`Case 6:20-cv-01215-ADA Document 1 Filed 12/31/20 Page 18 of 78
`
`32.
`
`Additionally, STMicro—directly or through intermediaries (including
`
`distributors, retailers, and others), subsidiaries, alter egos, and/or agents—ships, distributes,
`
`offers for sale, and/or sells their products in the United States and this Dist