Case 6:22-cv-00466-ADA-DTG Document 37-1 Filed 08/01/22 Page 1 of 48
`Case 6:22-cv-00466-ADA-DTG Document 37-1 Filed 08/01/22 Page 1 of 48
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`EXHIBIT 1
`EXHIBIT 1
`
`

`

`Case 6:22-cv-00466-ADA-DTG Document 37-1 Filed 08/01/22 Page 2 of 48
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`PUBLIC VERSION
`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`
`Before The Honorable Thomas B. Pender
`Administrative Law Judge
`
`
`
`
`
`Investigation No. 337-TA-984
`
`
`In the Matter of
`
`CERTAIN COMPUTING OR GRAPHICS
`SYSTEMS, COMPONENTS THEREOF,
`AND VEHICLES CONTAINING SAME
`
`
`
`JOINT MOTION TO TERMINATE INVESTIGATION AS TO
`RESPONDENT NVIDIA CORPORATION BASED ON SETTLEMENT
`
`
`
`Pursuant to 19 U.S.C. § 1337(c) and Commission Rule 210.21(b), Complainant
`
`Advanced Silicon Technologies LLC (“Advanced Silicon”) and Respondent NVIDIA
`
`Corporation (“NVIDIA”) (collectively, the “Settling Parties”), hereby submit this Joint Motion
`
`to Terminate Investigation 337-TA-984 as to Respondent NVIDIA only, in view of a Settlement
`
`and License Agreement (“Agreement”) between the Settling Parties.
`
`A true and correct copy of the Agreement, redacted to protect the disclosure of
`
`confidential business information subject to the Protective Order (Order No. 1), is attached to
`
`this submission as Public Exhibit A and an unredacted version in attached as Exhibit B.
`
`Contemporaneously with this filing, the Settling Parties are also filing a motion pursuant to
`
`Commission Rule 210.21(a)(1), requesting that the ALJ limit service of the unredacted
`
`agreement to the Settling Parties and Staff.
`
`The Agreement has been executed by the Settling Parties, and is fully effective as
`
`between them. The Agreement contains Confidential Business Information within the meaning
`
`of 19 C.F.R. § 201.6(a), including, but not limited to, license and settlement fee amounts, the
`
`Investigation No. 337-TA-984
`JOINT MOTION TO TERMINATE INVESTIGATION AS TO RESPONDENT NVIDIA CORPORATION BASED ON SETTLEMENT
`1
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`

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`PUBLIC VERSION
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`disclosure of which could impair parties’ ability to enter into settlement agreements. The
`
`Agreement completely resolves the dispute between the Settling Parties in this Investigation.
`
`The Agreement reflects the entire and only agreement between the Settling Parties regarding the
`
`subject matter of this Investigation. The Settling Parties represent that there are no other
`
`agreements, written or oral, express or implied, between the Settling Parties concerning the
`
`subject matter of this Investigation.
`
`The Settling Parties agree that termination of this Investigation on the basis of settlement
`
`as to only NVIDIA does not constitute a determination as to the violation of section 337 of the
`
`Tariff Act of 1930, including as to the merits of the claims or defenses raised during this
`
`Investigation. See 19 C.F.R. § 210.21(b)(2).
`
`In view of the Agreement, there no longer exists a basis upon which to continue this
`
`Investigation as to NVIDIA. Further, termination of this Investigation as to NVIDIA at this
`
`stage of the proceedings poses no threat to the public interest. Indeed, it is in the interest of the
`
`public and administrative economy to grant this motion. Commission policy and the public
`
`interest generally favor settlements, which preserve resources for both the Commission and the
`
`private parties, and motions to terminate based on settlement are routinely granted. See, e.g.,
`
`Certain Communications or Computing Devices and Components Thereof, Inv. No. 337-TA-925,
`
`Order No. 37 (June 5, 2015) (terminating one respondent based on settlement agreement);
`
`Certain Consumer Electronics with Display and Processing Capabilities, Inv. No. 337-TA-884,
`
`Order No. 15 (Aug. 1, 2014) (terminating investigation based on settlement agreements among
`
`complainant, certain respondents, and a third party); Certain Consumer Electronics and Display
`
`Devices and Products Containing Same, Inv. No. 337-TA-836, Order No. 30 at 3 (January 28,
`
`2013) (unreviewed) (terminating investigation based on settlement agreements among
`
`Investigation No. 337-TA-984
`JOINT MOTION TO TERMINATE INVESTIGATION AS TO RESPONDENT NVIDIA CORPORATION BASED ON SETTLEMENT
`2
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`PUBLIC VERSION
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`complainant, remaining respondents, and a third party); Certain Portable Communication
`
`Devices, Inv. No. 337-TA-827, Order No. 15 at 2 (May 31, 2012) (unreviewed) (same) (citation
`
`omitted).1
`
`Moreover, termination of this Investigation as to NVIDIA pursuant to the license and
`
`settlement Agreement will not have any adverse impact on the public health and welfare and/or
`
`competitive conditions in the United States. Accordingly, the Administrative Law Judge is
`
`authorized to issue an initial determination terminating this investigation pursuant to 19 C.F.R. §
`
`210.21(b).
`
`Counsel for the Settling Parties have consulted with the other Respondents and with
`
`Commission Investigative Staff Attorney regarding this motion. The other Respondents
`
`indicated that they will take a position, if any, upon reviewing the motion. Commission
`
`Investigative Attorney will provide the position of the Office of Unfair Import Investigations
`
`after reviewing these papers in more detail.
`
`
`
`For the foregoing reasons, the Settling Parties respectfully request that the Administrative
`
`Law Judge grant this motion and issue an initial determination terminating this Investigation
`
`with respect to NVIDIA only based on the accompanying Agreement.
`
`
`
`
`1 See also Certain Equipment for Telecommunications or Data Communications Networks, Including Routers,
`Switches, and Hubs, and Components Thereof, Inv. No. 337-TA-574, Order No. 27 at 4 (May 24, 2007)
`(“termination of litigation under these circumstances is generally in the public interest as settlement avoids needless
`litigation and conserves public resources”); Certain Semiconductor Chips and Products Containing Same, Inv. No.
`337-TA-753, Order No. 62 at 2-3 (February 22, 2012) (granting joint motion to partially terminate investigation on
`grounds that termination of the investigation based on the settlement agreement would have no adverse impact on
`the public interest); Certain Video Analytics Software, Systems, Components Thereof, and Product Containing
`Same, Inv. No. 337-TA-795, Order No. 19 at 1-2 (February 23, 2012) (granting joint motion to terminate, and noting
`that “[t]he Commission has stated that ‘in the absence of extraordinary circumstances, termination of the
`investigation will be readily granted to a complainant during the prehearing stage of an investigation.’”) (citations
`omitted).
`
`Investigation No. 337-TA-984
`JOINT MOTION TO TERMINATE INVESTIGATION AS TO RESPONDENT NVIDIA CORPORATION BASED ON SETTLEMENT
`3
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`

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`PUBLIC VERSION
`
`Dated: April 27, 2016
`
`
`
`Respectfully submitted,
`
`/s/ Andrew H. DeVoogd
`Michael T. Renaud
`James M. Wodarski
`Andrew H. DeVoogd
`Adam A. Rizk
`MINTZ, LEVIN, COHN, FERRIS, GLOVSKY
` AND POPEO, P.C.
`One Financial Center
`Boston, MA 02110
`Phone: (617) 542-6000
`Fax: (617) 542-2241
`
`Aarti Shah
`MINTZ, LEVIN, COHN, FERRIS, GLOVSKY
` AND POPEO, P.C.
`701 Pennsylvania Avenue NW
`Suite 900
`Washington, DC 20004
`Phone: (202) 434-7300
`Fax: (202) 434-7400
`Email: ASTITC984@mintz.com
`Counsel for Complainant
`Advanced Silicon Technologies LLC
`
`
`
`
`/s/ Bert C. Reiser
`Maximilian A. Grant
`Bert C. Reiser
`LATHAM & WATKINS LLP
`555 Eleventh Street, NW, Suite 1000
`Washington, DC 20004
`Telephone:
`(202) 637-2200
`Charles H. Sanders
`LATHAM & WATKINS LLP
`John Hancock Tower, 27th Floor
`200 Clarendon Street
`Boston, MA 02116
`Telephone:
`(617) 948-6000
`Michael A. David
`LATHAM & WATKINS LLP
`885 Third Avenue
`New York, NY 10022
`Telephone:
`(212) 906-2968
`Email:
`NVIDIAITCAST.LWTEAM@lw.com
`Counsel for Respondent
`NVIDIA Corporation
`
`Investigation No. 337-TA-984
`JOINT MOTION TO TERMINATE INVESTIGATION AS TO RESPONDENT NVIDIA CORPORATION BASED ON SETTLEMENT
`4
`
`

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`Case 6:22-cv-00466-ADA-DTG Document 37-1 Filed 08/01/22 Page 6 of 48
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`PUBLIC VERSION
`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`
`Before The Honorable Thomas B. Pender
`Administrative Law Judge
`
`
`
`
`
`Investigation No. 337-TA-984
`
`
`In the Matter of
`
`CERTAIN COMPUTING OR GRAPHICS
`SYSTEMS, COMPONENTS THEREOF,
`AND VEHICLES CONTAINING SAME
`
`
`
`APPENDIX OF EXHIBITS ACCOMPANYING THE
`JOINT MOTION TO TERMINATE INVESTIGATION AS TO
`RESPONDENT NVIDIA BASED ON SETTLEMENT
`
`
`Exhibit No.
`Public Exhibit A
`
`Document Description
`Public Version of the Patent License and Settlement Agreement
`between Advanced Silicon Technologies LLC and NVIDIA
`Corporation
`
`Highly Confidential
`Exhibit B
`
`Highly Confidential and Unredacted Version of the Patent License
`and Settlement Agreement between Advanced Silicon Technologies
`LLC and NVIDIA Corporation
`
`
`
`
`
`
`
`Investigation No. 337-TA-984
`JOINT MOTION TO TERMINATE INVESTIGATION AS TO RESPONDENT NVIDIA CORPORATION BASED ON SETTLEMENT
`
`
`

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`Case 6:22-cv-00466-ADA-DTG Document 37-1 Filed 08/01/22 Page 7 of 48
`Case 6:22-cv-00466-ADA-DTG Document 37-1 Filed 08/01/22 Page 7 of 48
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`
`
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`PUBLIC EXHIBIT A
`PUBLIC EXHIBIT A
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`

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`Case 6:22-cv-00466-ADA-DTG Document 37-1 Filed 08/01/22 Page 8 of 48
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`SETTLEMENT AND LICENSE AGREEMENT
`
`This Settlement and License Agreement (“Agreement”) is made as of April 22,
`2016 (“Effective Date”) between NVIDIA Corporation, a California corporation
`(“NVIDIA”) and Advanced Silicon Technologies LLC (“AST”), a Delaware limited
`liability corporation. As used herein, “Party” refers to either AST or NVIDIA, and
`“Parties” refers to AST and NVIDIA collectively.
`
`WHEREAS, NVIDIA desires to acquire a non-exclusive license and covenant
`not to sue
`, and to resolve any disputes related thereto;
`
`WHEREAS, the United States International Trade Commission (“ITC”)
`instituted Investigation No. 337-TA-984 against NVIDIA and others on January 28,
`2016, based upon a Complaint filed by AST on December 28, 2015 (the
`“Investigation”), and whereas AST also brought suit against NVIDIA in Advanced
`Silicon Technologies LLC v. NVIDIA Corporation, Civil Action No. 15-cv-1177-RGA
`(the “District Court Action”, filed December 21, 2015) (the Investigation and the
`District Court Action, collectively, the “Lawsuits”); and
`
`WHEREAS the Parties now desire to settle the Lawsuits and enter into this
`agreement providing for a full, final, complete and global settlement of the Lawsuits and
`for certain releases, licenses and covenants not to sue, all on the terms and conditions
`set forth herein.
`
`NOW, THEREFORE, in consideration of the above premises and the mutual
`covenants contained herein and other good and valuable consideration, the receipt and
`sufficiency of which are hereby acknowledged, the Parties, intending to be legally
`bound, hereby agree as follows:
`
`1.0
`
`DEFINITIONS.
`
`“Affiliate” means, with respect to a person, corporation or other entity, any
`other person, corporation or entity that directly or indirectly controls, is controlled by,
`or is under common control with such corporation or entity. For purposes of this
`definition, “control” means the ownership, directly or indirectly, of fifty percent (50%)
`or more of the voting equity of such entity, but such person, corporation or other entity
`shall be an Affiliate only for as long as such control exists.
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`“Claims” has the meaning set forth in Section 2.3.
`
` means any suit, action or proceeding in any
`jurisdiction or forum, including civil courts, administrative agencies such as the Patent
`Trial and Appeals Board, and/or alternative dispute resolution such as arbitration,
`anywhere in the world, except for a suit, action or proceeding brought or commenced
`(i) to address or in response to an alleged material breach of this Agreement or (ii) as
`otherwise permitted by the last sentence of Section 2.7 ((i) and (ii), collectively,
`)).
`
`“Excluded Fields of Use” means any field of use other than the Licensed Field
`of Use, including the
`
`“Excluded NVIDIA Product” means any product, product line, service, device,
`system, component, hardware, semiconductor chip, chipset, software, any combination
`of the foregoing or other offering that is designed, branded, made, used, sold, offered
`for sale, leased, purchased, licensed, imported, exported, supplied or otherwise provided
`by or for NVIDIA or an NVIDIA Affiliate within the Excluded Fields of Use (defined
`above).
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`“NVIDIA Released Person” has the meaning set forth in Section 2.2.1.
`
`2.0
`
`LICENSE, COVENANT, RELEASE, AND DISPUTES.
`
`2.1
`
`2.2
`
`Covenants.
`
`2.2.1
`
`2.2.2
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`2.2.3
`
`2.3
`
`Unknown Claims. AST, having specific intent to release the identified
`2.4
`potential claims described in the foregoing Sections 2.1, 2.2 and 2.3, whether known or
`unknown, does hereby acknowledge and expressly waive the provisions of Section 1542
`of the California Civil Code (and similar provisions in other jurisdictions, whether by
`statute or common law), which provides:
`
`“A general release does not extend to claims which the creditor
`does not know or suspect to exist in his or her favor at the time
`of executing the release, which if known by him or her, must
`have materially affected his settlement with debtor.”
`
`2.5
`
`Dismissals.
`
`2.5.1 Termination of the Investigation. AST shall file a motion to
`terminate the Investigation with the International Trade Commission, as and to the
`extent it relates to NVIDIA and its Affiliates, substantially in the form attached hereto
`as Exhibit B
`
`2.5.2 Dismissal of the District Court Action. AST shall dismiss all
`claims brought in the District Court Action with prejudice
` by filing a stipulation or notice of
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`dismissal substantially in the form attached hereto as Exhibit C, or in such other form as
`required for approval by the Court to effectuate the dismissal.
`
`2.5.3 No Admissions. NVIDIA makes no admission of infringement or
`liability, or the validity of any AST Patent, by the negotiation, execution, or
`performance of this Agreement.
`
`2.6
`
`2.7
`
`3.0
`
`CONSIDERATION.
`
`3.1
`
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`
`4.2
`
`it has the
`Due Authorization. Each Party warrants and represents that
`4]
`full power and authority to enter into this Agreement and to performits obligations
`hereunder and consummate the transactions contemplated herein.
`
`4.0 WARRANTIES.
`
`Patents. AST represents and warrants to NVIDIAthat Exhibit A lists (i)
`4.3
`each and every patent and patent applicationin all jurisdictions worldwide that are, as
`
`Page6 RI,cL EMECNACHE AGREEMENT
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`DC4300133.8
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`Case 6:22-cv-00466-ADA-DTG Document 37-1 Filed 08/01/22 Page 14 of 48
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`of the date of this Agreement, that are owned by AST or its Affiliates, or to which
`AST or its Affiliates has a right to assert a claim of infringement or to grant licenses.
`
`5.0
`
`TERM AND TERMINATION.
`
`Term. This Agreement shall not be binding on the Parties until it has
`5.1
`been signed below by both Parties, at which time it shall be deemed effective as of its
`Effective Date.
`
`5.2
`
`6.0
`
`ASSIGNABILITY.
`
`6.1
`Assignment. Neither party may grant or assign any rights or delegate
`any duties under this Agreement to any third party without the prior written consent of
`the other, and any attempted assignment without such consent shall be null and void.
`Notwithstanding the foregoing, either Party may (i) assign rights under this Agreement
`to any of its Affiliates and (ii) assign rights under this Agreement to (a) an acquirer of
`all or substantially all of the equity or assets of its business to which this Agreement
`relates or (b) the surviving entity in any merger, consolidation, equity exchange, or
`reorganization of its business to which this Agreement relates.
`
`Rights Run with Patents. All license rights and covenants contained
`6.2
`herein shall run with the AST Patents and shall be binding on any successors-in-interest
`or assigns thereof. AST shall not assign, or grant any right under, any AST Patent to
`any other party unless such assignment or grant is subject to all of the terms and
`conditions of this Agreement applying to the AST Patents.
`
`Inurement. This Agreement shall be binding upon, inure to the benefit of
`6.3
`and be enforceable by the Parties and their permitted successors and assigns.
`
`Null Assignments. Any attempted assignment or grant in contravention
`6.4
`of Sections 6.1-6.3 shall be null and void.
`
`7.0
`
`CONFIDENTIALITY.
`
`7.1
`Non-disclosure. The terms of this Agreement and all correspondence
`relating to this Agreement are confidential. The Parties shall keep terms and particulars
`of this Agreement confidential and no Party shall now or hereafter disclose such terms
`
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`and particulars to any third party except:
`
`Press Release. Following termination of the Investigation as to NVIDIA,
`7.2
`either Party may issue a press release stating that (a) AST and NVIDIA have resolved
`the dispute between them and (2) the Lawsuits as to NVIDIA have been terminated and
`dismissed. NVIDIA may make any statement it deems appropriate to satisfy its various
`public reporting obligations.
`
`7.3
`
`8.0
`
`NOTICES.
`
`Delivery. All notices required or permitted to be given hereunder shall
`8.1
`be in writing and shall be deemed delivered (i) upon receipt if delivered by hand, (ii) the
`next business day after being sent by prepaid, nationally-recognized, overnight air
`courier, (iii) five (5) business days after being sent by registered or certified airmail,
`return receipt required, postage prepaid, or (iv) upon transmittal when transmitted by
`confirmed facsimile (provided that such notice is followed by notice pursuant to any of
`(i) – (iii) above).
`
`8.2
`
`Address. All notices shall be addressed as follows:
`
`For NVIDIA:
`
`With a copy (which shall not
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`constitute notice) to:
`
`For Advanced Silicon
`Technologies LLC:
`
`With a copy (which shall not
`constitute notice) to:
`
`9.0
`
`MISCELLANEOUS.
`
`Third Party Infringement Actions. AST has no obligation hereunder to
`9.1
`institute any action or suit against any third party for infringement of any of the AST
`Patents, or to defend against any action challenging the validity of the AST Patents.
`NVIDIA has no right to institute any action against any third party for infringement of
`any AST Patent.
`
`Independent Contractors. Nothing in this Agreement is intended or shall
`9.2
`be deemed to constitute a partnership, agency, employer-employee, or joint venture
`relationship between the Parties. Neither Party shall incur any debts or make any
`commitments for the other. There is no fiduciary duty or special relationship of any
`kind between the Parties to this Agreement. Each Party expressly disclaims any reliance
`on any act, word, or deed of the other Party in entering into this Agreement.
`
`Implied Licenses. Unless expressly set forth elsewhere in this
`9.3
`Agreement, nothing herein shall be construed as conferring any right to a license or to
`otherwise use any patent, patent application, trademark, service name, service mark,
`trade dress, trade secret or other intellectual property belonging to NVIDIA.
`
`Severability. If any portion of this Agreement is found to be invalid,
`9.4
`illegal, or unenforceable for any reason, the remainder of the Agreement shall continue
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`in force and, if needed, the Parties or a court of competent jurisdiction shall substitute
`suitable provisions having like economic effect and intent.
`
`Amendment. This Agreement cannot be modified, terminated or
`9.5
`amended in any respect orally or by conduct of the Parties. Any termination,
`modification, or amendment may be made only by a writing signed by all Parties. No
`waiver of any provision shall be binding in any event unless executed in writing by the
`Party making the waiver.
`
`Counterparts. This Agreement may be executed in several counterparts,
`9.6
`each of which is deemed to be an original but all of which constitute one and the same
`instrument.
`
`Drafting. Each Party and counsel have reviewed and approved this
`9.7
`Agreement, and accordingly any presumption or rule of construction permitting
`ambiguities to be resolved against the drafting party shall not be employed in the
`interpretation or application of this Agreement.
`
`Interpretation. The headings inserted in this Agreement are for reference
`9.8
`only and are not intended to form any part of the operative portion of this Agreement,
`and they shall not be employed in the interpretation or application of this Agreement.
`Whenever the words “include,” “includes” or “including” are used in this Agreement,
`they shall be deemed to be followed by the words “without limitation.”
`
`Governing Law. This Agreement shall be construed, and the relationship
`9.9
`between the Parties determined, in accordance with the laws of Delaware, notwithstanding
`any choice-of-law principle that might dictate a different governing law.
`
`Integration. This Agreement sets forth the entire understanding of the
`9.10
`Parties with respect to the AST Patents, and replaces any prior oral or written
`communications, discussions or agreements between them.
`
`9.11
`
`LIABILITY. EXCEPT AS PROVIDED EXPLICITLY HEREIN, IN
`9.12
`NO EVENT SHALL ANY PARTY BE LIABLE TO ANY OTHER PARTY OR ANY
`OTHER PERSON OR ENTITY (UNDER CONTRACT, STRICT LIABILITY,
`NEGLIGENCE, OR OTHER THEORY) FOR SPECIAL, INDIRECT, EXEMPLARY,
`INCIDENTAL, OR CONSEQUENTIAL DAMAGES, INCLUDING LOST PROFITS,
`
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`OPPORTUNITIES OR SAVINGS, ARISING OUT OF OR RELATED TO THE
`SUBJECT MATTER OF THIS AGREEMENT.
`
`9.13 Bankruptcy. The Parties acknowledge and agree that the AST Patents
`are “intellectual property” as defined in Section 101(35A) of the United States
`Bankruptcy Code (the “Code”), as the same may be amended from time to time, that
`have been licensed hereunder in a contemporaneous exchange for value. AST
`acknowledges that if AST, as a debtor in possession or a trustee in bankruptcy in a
`case under the Code, rejects this Agreement, NVIDIA may elect to retain its rights
`under this Agreement as provided in Section 365(n) of the Code. Upon written request
`from NVIDIA to AST (as applicable) or the bankruptcy trustee of AST’s election to
`proceed under Section 365(n), AST (as applicable) or the bankruptcy trustee shall
`comply in all respects with Section 365(n), including, by not interfering with the rights
`of NVIDIA as provided by this Agreement.
`
`[Rest of Page Intentionally Left Blank; Signature Page Follows]
`
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`IN WITNESS WHEREOF, this Agreement has been duly executed by the Parties tu
`be cHeetive as of the Flltctive Date.
`
`ADVANCED SILICON
`
`NVIDIA CORPORATION
`
`TECHNOLOGIES LLC
`
`ras Aa22, Zale—owes ARB,22,2PM
`
`he HPid LEDER AGGIE WOREEMENT
`
`pM RAT RS
`
`

`

`Case 6:22-cv-00466-ADA-DTG Document 37-1 Filed 08/01/22 Page 20 of 48
`
`EXHIBIT A:
`AST Patents
`
`Page 13
`
`B
`
` SETTLEMENT AND LICENSE AGREEMENT
`NCED SILICON AND NVIDIA
`
`DC\4300133.8
`
`

`

`Case 6:22-cv-00466-ADA-DTG Document 37-1 Filed 08/01/22 Page 21 of 48
`
`Family
`Id
`
`Countr
`y
`
`Status
`
`Type
`
`US
`
`US
`
`US
`
`US
`
`US
`
`US
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Publication
`Type
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`
`Granted
`Patent
`
`Granted
`Patent
`
`Advanced Silicon Technologies LLC
`Patent Portfolio
`
`Grant No.
`
`Title
`
`PROCESSOR CONFIGURED TO DETECT PROGRAM PHASE
`CHANGES AND TO ADAPT THERETO
`METHOD AND APPARATUS FOR ANTI-ALIASING POST
`RENDERING OF AN IMAGE
`
`BURIED TRENCH CAPACITOR
`
`6055650
`
`6097400
`
`6140674
`
`5918062
`
`6085208
`
`6085212
`
`Filing
`Date
`
`Issue
`Date
`
`4/6/1998
`
`4/25/2000
`
`6/1/1998
`
`8/1/2000
`
`7/27/1998
`
`10/31/200
`0
`
`1/28/1998
`
`6/29/1999
`
`3/27/1998
`
`7/4/2000
`
`3/27/1998
`
`7/4/2000
`
`3/27/1998
`
`7/11/2000
`
`MICROPROCESSOR INCLUDING AN EFFICIENT
`IMPLEMENTATION OF AN ACCUMULATE INSTRUCTION
`LEADING ONE PREDICTION UNIT FOR NORMALIZING
`CLOSE PATH SUBRACTION RESULTS WITHIN A FLOATING
`POINT ARITHMETIC UNIT
`EFFICIENT METHOD FOR PERFORMING CLOSE PATH
`SUBTRACTION IN A FLOATING POINT ARITHMETIC UNIT
`CLOSE PATH SELECTION UNIT FOR PERFORMING
`EFFECTIVE SUBTRACTION WITHIN A FLOATING POINT
`ARITHMETIC UNIT
`FLOATING POINT ARITHMETIC UNIT INCLUDING AN
`EFFICIENT CLOSE DATA PATH
`METHOD AND APPARATUS FOR CALCULATING
`RECIPROCALS AND RECIPROCAL SQUARE ROOTS
`FLOATING POINT ADDITION PIPELINE CONFIGURED TO
`PERFORM FLOATING POINT-TO-INTEGER AND INTEGER-
`TO-FLOATING POINT CONVERSION OPERATIONS
`METHOD AND APPARATUS FOR MULTI-FUNCTION
`ARITHMETIC
`
`6088715
`
`6094668
`
`6115733
`
`6131104
`
`6223198
`
`3/27/1998
`
`7/25/2000
`
`5/8/1998
`
`9/5/2000
`
`3/27/1998
`
`10/10/200
`0
`
`8/14/1998
`
`4/24/2001
`
`6256653
`
`MULTI-FUNCTION BIPARTITE LOOK-UP TABLE
`
`1/29/1998
`
`7/3/2001
`
`6381625 METHOD AND APPARATUS FOR CALCULATING A POWER
`OF AN OPERAND
`METHOD AND APPARATUS FOR ROUNDING IN A
`MULTIPLIER
`
`6397238
`
`2/12/2001
`
`4/30/2002
`
`2/12/2001
`
`5/28/2002
`
`US
`
`Granted
`
`Patent
`
`US
`
`US
`
`US
`
`US
`
`US
`
`US
`
`US
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Abandon
`ed
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`Patent
`
`Granted
`Patent
`Granted
`Patent
`
`Granted
`Patent
`
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`
`Exhibit A: AST Patents
`Settlement and License Agreement between NVIDIA Corporation and Advanced Silicon Technologies LLC
`Page 1 of 11
`
`

`

`Case 6:22-cv-00466-ADA-DTG Document 37-1 Filed 08/01/22 Page 22 of 48
`
`Family
`Id
`
`Countr
`y
`
`Status
`
`Type
`
`US
`
`US
`
`US
`
`US
`
`US
`
`US
`
`US
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Patent
`
`Publication
`Type
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`
`Advanced Silicon Technologies LLC
`Patent Portfolio
`
`Grant No.
`
`Title
`
`SHARED FP AND SIMD 3D MULTIPLIER
`
`6490607
`
`6297835
`
`6321314
`
`6329701
`
`6339428
`
`6405303
`
`Filing
`Date
`10/12/199
`9
`
`Issue
`Date
`
`12/3/2002
`
`10/5/1998
`
`10/2/2001
`
`6/9/1999
`
`10/4/1999
`
`11/20/200
`1
`12/11/200
`1
`
`7/16/1999
`
`1/15/2002
`
`10/30/199
`8
`
`2/26/2002
`
`8/31/1999
`
`6/11/2002
`
`METHOD AND APPARATUS FOR PROCESSING DATA AS
`DIFFERENT SIZES
`METHOD AND APPARATUS FOR RESTRICTING MEMORY
`ACCESS
`SEMICONDUCTOR DEVICE COMPRISING COPPER
`INTERCONNECTS WITH REDUCED IN-LINE DIFFUSION
`METHOD AND APPARATUS FOR COMPRESSED TEXTURE
`CACHING IN A VIDEO GRAPHICS SYSTEM
`6351222 METHOD AND APPARATUS FOR RECEIVING AN INPUT BY
`AN ENTERTAINMENT DEVICE
`MASSIVELY PARALLEL DECODING AND EXECUTION OF
`VARIABLE-LENGTH INSTRUCTIONS
`COMPUTER SYSTEM IMPLEMENTING SYSTEM AND
`METHOD FOR ORDERING WRITE OPERATIONS AND
`MAINTAINING MEMORY COHERENCY
`
`6529999
`
`Granted
`Patent
`
`10/27/199
`9
`
`3/4/2003
`
`6546439
`
`METHOD AND SYSTEM FOR IMPROVED DATA ACCESS
`
`12/9/1998
`
`4/8/2003
`
`US
`
`US
`
`US
`
`US
`
`US
`
`US
`
`US
`
`US
`
`Granted
`
`Granted
`
`Patent
`
`Granted
`
`Granted
`
`Granted
`
`Granted
`
`Granted
`
`Granted
`
`Patent
`
`Patent
`
`Patent
`
`Patent
`
`Patent
`
`Patent
`
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`
`GEOMETRIC ENGINE INCLUDING A COMPUTATIONAL
`MODULE FOR USE IN A VIDEO GRAPHICS CONTROLLER
`DYNAMIC GRAPHICS AND/OR VIDEO MEMORY POWER
`REDUCING CIRCUIT AND METHOD
`METHOD AND APPARATUS FOR PARALLEL PROCESSING
`OF GEOMETRIC ASPECTS OF VIDEO GRAPHICS DATA
`6717941 METHOD AND APPARATUS FOR EARLY TERMINATION OF
`FRAME DATA
`VIDEO DECODING APPARATUS AND METHOD FOR A
`SHARED DISPLAY MEMORY SYSTEM
`SYNCHRONIZATION AND MIXING OF MULTIPLE STREAMS
`AT DIFFERENT SAMPLING RATES
`Exhibit A: AST Patents
`Settlement and License Agreement between NVIDIA Corporation and Advanced Silicon Technologies LLC
`Page 2 of 11
`
`6630935
`
`6657634
`
`6686924
`
`6717989
`
`6728584
`
`4/21/2000
`
`10/7/2003
`
`2/25/1999
`
`12/2/2003
`
`2/2/2000
`
`2/3/2004
`
`2/2/2000
`
`4/6/2004
`
`11/3/1999
`
`4/6/2004
`
`9/2/1998
`
`4/27/2004
`
`

`

`Case 6:22-cv-00466-ADA-DTG Document 37-1 Filed 08/01/22 Page 23 of 48
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`Family
`Id
`
`Countr
`y
`
`Status
`
`Type
`
`US
`
`US
`
`US
`
`US
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Advanced Silicon Technologies LLC
`Patent Portfolio
`
`Publication
`Type
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`
`Grant No.
`
`6432817
`
`6730587
`
`6731294
`
`6737222
`
`Title
`
`TUNGSTEN SILICIDE BARRIER FOR NICKEL SILICIDATION
`OF A GATE ELECTRODE
`TITANIUM BARRIER FOR NICKEL SILICIDATION OF A
`GATE ELECTRODE
`VECTOR ENGINE WITH PRE-ACCUMULATION BUFFER
`AND METHOD THEREFORE
`DUAL DAMASCENE PROCESS UTILIZING A BI-LAYER
`IMAING LAYER
`
`AU
`
`Unfiled
`
`Applicati
`on
`
`Application
`
`2911502A
`
`US
`
`US
`
`Granted
`
`Patent
`
`6745318
`
`Granted
`
`Patent
`
`Filing
`Date
`
`Issue
`Date
`
`12/7/2000
`
`8/13/2002
`
`12/7/2000
`
`5/4/2004
`
`4/21/2000
`
`5/4/2004
`
`6/19/2001
`
`5/18/2004
`
`
`
`
`
`8/18/1999
`
`6/1/2004
`
`6750920
`
`6766100
`
`6772356
`
`
`METHOD AND APPARATUS OF CONFIGURABLE
`PROCESSING
`METHOD AND APPARATUS FOR ADJUSTING BIAS AND
`AMPLITUDE OF A VIDEO SIGNAL
`6754234 METHOD AND APPARATUS FOR ASYNCHRONOUS FRAME
`SYNCHRONIZATION
`METHOD AND APPARATUS FOR MULTI-TV TUNER
`DISPLAY OF VIDEO INFORMATION
`SYSTEM FOR SPECIFYING CORE VOLTAGE FOR A
`MICROPROCESSOR BY SELECTIVELY OUTPUTTING ONE
`OF A FIRST, FIXED AND A SECOND, VARIABLE VOLTAGE
`CONTROL SETTINGS FROM THE MICROPROCESSOR
`MICROPROCESSOR EMPLOYING A FIXED POSITION
`DISPATCH UNIT
`APPARATUS AND METHOD FOR DECREASING POWER
`CONSUMPTION IN AN INTEGRATED CIRCUIT
`CLOCK CONTROL OF FUNCTIONAL UNITS IN AN
`INTEGRATED CIRCUIT BASED ON MONITORING UNIT
`SIGNALS TO PREDICT INACTIVITY
`
`6968444
`
`6976182
`
`6983389
`
`3/16/1999
`
`6/15/2004
`
`5/21/1999
`
`6/22/2004
`
`10/19/200
`0
`
`7/20/2004
`
`6/26/2000
`
`8/3/2004
`
`11/4/2002
`
`2/1/2002
`
`11/22/200
`5
`12/13/200
`5
`
`2/1/2002
`
`1/3/2006
`
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`Granted
`Patent
`
`Granted
`Patent
`
`Granted
`Patent
`Granted
`Patent
`
`Granted
`Patent
`
`Granted
`Patent
`
`US
`
`US
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`US
`
`Granted
`
`Patent
`
`US
`
`US
`
`US
`
`US
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`Granted
`
`Patent
`
`6999076
`
`SYSTEM, METHOD AND APPARATUS FOR EARLY CULLING
`
`2/19/2002
`
`2/14/2006
`
`Exhibit A: AST Patents
`Settlement and License Agreement between NVIDIA Corporation and Advanced Silicon Technologies LLC
`Page 3 of 11
`
`

`

`Case 6:22-cv-00466-ADA-DTG Document 37-1 Filed 08/01/22 Page 24 of 48
`
`Advanced Silicon Technologies LLC
`Patent Portfolio
`
`Grant No.
`
`6397379
`
`6549959
`
`Title
`
`RECORDING IN A PROGRAM EXECUTION PROFILE
`REFERENCES TO A MEMORY-MAPPED ACTIVE DEVICE
`DETECTING MODIFICATION TO COMPUTER MEMORY BY
`A DMA DEVICE
`
`Filing
`Date
`10/28/199
`9
`
`Issue
`Date
`
`5/28/2002
`
`11/4/1999
`
`4/15/2003
`
`Granted
`
`Patent
`
`6763452 MODIFYING PROGRAM