Professor Masahiro Iida v. Intel Corporation, 6:22-cv-00662, No. 1 (W.D.Tex. Jun. 24, 2022) (2024)

Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 1 of 19
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`PROFESSOR MASAHIRO IIDA,
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`Plaintiff,
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`____________________________________
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`Defendant.
`____________________________________:
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`v.
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`INTEL CORPORATION,
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`6:22-CV-00662
`Case No. ________________
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`JURY TRIAL DEMANDED
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff, Professor Masahiro Iida (“Professor Iida”), files this Complaint against
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`Defendant, Intel Corporation (“Intel”), for infringement of U.S. Patent No. 6,812,737 in
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`connection with its manufacture, use, offering for sale, and sale of programmable logic devices –
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`Field Programmable Gate Array (“FPGA”) chips and System-on-Chip (“SoC”) chips – that
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`employ Adaptive Logic Modules (the “Accused Products”), and alleges as follows:
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`PARTIES
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`1.
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`Professor Iida is an adult individual and Japanese citizen residing at 7-chōme-11-
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`6 Toroku Chūō-ku, Kumamoto, Japan. He holds a Doctorate of Engineering in Systems and
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`Information Science from Kumamoto University, and is Chair of the Department of Computer
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`Science and Electrical Engineering in the Faculty of Engineering at Kumamoto University
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`located in Kumamoto, Japan.
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`2.
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`Professor Iida is the inventor and owner of U.S. Patent No. 6,812,737 (the “’737
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`patent”) entitled “PROGRAMMABLE LOGIC CIRCUIT DEVICE HAVING LOOK UP
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 2 of 19
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`TABLE ENABLING TO REDUCE IMPLEMENTATION AREA.” A copy of the ’737 patent is
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`attached as Exhibit 1.
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`3.
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`Intel is a corporation duly organized and existing under the laws of the State
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`of Delaware, and has regular and established places of business in the Western District of
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`Texas, including at 1300 S. Mopac Expressway, Austin, Texas 78746.
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`4.
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`Intel can be served with process through its registered agent for service in Texas:
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`CT Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201.
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`5.
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`Since at least April 1989, Intel has been registered to do business in the State of
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`Texas under Texas Taxpayer No. 19416727436.
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`JURISDICTION
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` 6.
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`This action arises under the Patent Laws of the United States, 35 U.S.C. § 1, et
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`seq., and this Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§ 1331
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`and 1338(a).
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`7.
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`The United States District Court for the Western District of Texas has general and
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`specific personal jurisdiction over Intel because Intel has sufficient minimum contacts with this
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`forum as a result of the business it regularly conducts within the State of Texas and in this
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`District. In particular, this Court has personal jurisdiction over Intel because, inter alia, Intel, on
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`information and belief: (1) has substantial, continuous, and systematic business contacts with this
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`State and this District; (2) owns, manages, and/or operates facilities in this State and this District;
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`(3) enjoys substantial income from its operations in this State and this District; (4) employs
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`Texas residents in this State and this District; and (5) solicits business and markets goods,
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`including the Accused Products, in this State and this District.
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 3 of 19
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`8.
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`Intel has also purposefully and voluntarily availed itself of the privileges of
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`conducting business in the State of Texas, and the Western District of Texas, by continuously
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`and systematically placing goods, including the Accused Products, into the stream of commerce
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`through an established distribution channel with the expectation that they will be purchased by
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`consumers in Texas and in this District.
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`9.
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`Intel is subject to this Court’s personal jurisdiction in accordance with due process
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`and/or the Texas Long Arm Statute because, in part, Intel “[r]ecruits Texas residents, directly or
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`through an intermediary located in this state, for employment inside or outside this state.” Tex.
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`Civ. Prac. & Rem. Code § 17.042.
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`10.
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`This Court also has personal jurisdiction over Intel because Intel (directly and/or
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`through its subsidiaries, affiliates, or intermediaries) has committed and continues to commit acts
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`of patent infringement in this judicial district in violation of at least 35 U.S.C. § 271(a).
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`11.
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`Professor Iida’s cause of action arises, at least in part, from Intel’s contacts with
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`and activities in the State of Texas and within this District. Upon information and belief,
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`Defendant has committed acts of patent infringement within this District giving rise to this
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`action, including offering to sell and/or selling the Accused Products to customers in this
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`District.
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`12.
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`Intel has committed, and continues to commit, acts of patent infringement within
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`the United States, the State of Texas, and this District.
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`VENUE
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`13. Venue is proper in this District under 35 U.S.C. § 1400(b) because: (1) there is a
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`physical place located in this District, (2) it is a regular and established place of business, and (3)
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`it is the place of Intel. See In re Cray Inc., 871 F.3d 1355, 1360 (Fed. Cir. 2017).
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 4 of 19
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`14.
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`In touting its research and development facility in Austin, Intel declares that it is
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`“proud to call Texas home.”1
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`15.
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`16.
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`Intel maintains several facilities, which it refers to as campuses, in this District.2
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`Intel maintains a campus at 1300 S. Mopac Expressway, Austin Texas 78746
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`which it calls the Barton Skyway Campus.3 This is a regular and established place of business
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`within this District belonging to Intel.
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`17.
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`Intel also maintains a campus at 9442 N. Capital of Texas Hwy., Bldg. 2, Suite
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`600, Austin, Texas 78759 which it calls the Austin FSO, Arboretum Campus.4 This is a regular
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`and established place of business within this District belonging to Intel.
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`18.
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`Intel’s Austin facilities include a research and development center with close to
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`1,800 employees.5
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`19.
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`Intel’s Austin facilities are focused on supporting innovations in, among other
`
`things, programmable logic devices.6
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`20.
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`Intel’s interest in programmable logic devices dates back at least to December 28,
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`2015, with its acquisition of Altera Corporation (“Altera”), one the largest designers and
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`fabricators of FPGA products at that time.
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`21.
`
`Intel purchased Altera for approximately $16.7 billion.
`
`
`1 Intel in Texas, Intel Website (last visited June 2022), available at:
`https://www.intel.com/content/www/us/en/corporate-responsibility/intel-in-texas.html
`2 Contact Intel, Intel Website (last visited June 2022), available at:
`https://www.intel.com/content/www/us/en/support/contact-intel.html?tab=campus-locations#support-us-locations
`3 Id.
`4 Id.
`5 Intel in Texas, Intel Website (last visited June 2022), available at:
`https://www.intel.com/content/www/us/en/corporate-responsibility/intel-in-texas.html
`6 Id.
`
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 5 of 19
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`22.
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`Intel acquired Altera, at least in part, because Altera was a “leading provider of
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`field programmable gate array (FPGA) technology.”7
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`23.
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`The operations of Altera designing and selling FPGA products continued as a new
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`business unit of Intel called the Programmable Solutions Group (“PSG”).
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`24.
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`From 2016 through 2021, the PSG was one of six separately reporting business
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`units, called operating segments, through which Intel conducted and reported its operations.
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`25.
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`As of the first quarter of 2022, Intel implemented a reorganization of its various
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`business operations in which financial results were to be reported under six different operating
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`segments. The operations of the PSG are now included as part of the Data Center and AI
`
`(“DCAI”) Group, and revenues previously attributed to the PSG are now reported as part of the
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`revenues for the DCAI Group.
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`26. Certain of Intel’s operations within the PSG, including operations relating to
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`design and sale of the Accused Products, have been planned and executed, and continue to be
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`planned and executed, in this District.
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`27.
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`Intel employees in this District have worked, and presently work, on the design,
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`sale, and support of the Accused Products. Many of these employees are senior level software,
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`firmware, and/or hardware engineers who worked on the Accused Products for Altera in this
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`District and who continued to work on the Accused Products in the PSG for Intel in this District
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`since its acquisition of Altera in 2015. See LinkedIn profile page screen captures attached,
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`collectively, as Exhibit 2.8
`
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`7 Press Release, Intel Website (last visited June 2022), available at:
`https://download.intel.com/newsroom/2021/archive/2015-12-28-news-releases-intel-completes-acquisition-of-
`altera.pdf
`
` Full profiles of the identified Intel employees are accessible on LinkedIn website (last visited June 2022) at:
`Bacrau: https://www.linkedin.com/in/radubacrau/
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` 8
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 6 of 19
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`28.
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`Intel is currently looking to fill positions within the PSG that are principally
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`located in this District.9
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`29.
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`Upon information and belief, Intel’s records relating to the design and sales of the
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`Accused Products are accessible in this District by employees within the PSG who work in this
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`District.
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`THE ASSERTED PATENT
`
`30.
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`In 2001, Professor Iida was a doctoral student conducting research on FPGA
`
`architecture. During the course of his research, Professor Iida discovered a revolutionary way to
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`flexibly configure large look up tables (LUTs), primitive logic elements used in programmable
`
`
`
`
`Baumgartner: https://www.linkedin.com/in/yoanna-baumgartner-6327073/
`Blake: https://www.linkedin.com/in/galen-blake-3b657b1b/
`Brice: https://www.linkedin.com/in/bricedonaldn/
`Cid: https://www.linkedin.com/in/alberto-cid-a944151/
`Cozart: https://www.linkedin.com/in/sue-cozart-89a58224/
`Ehrlich: https://www.linkedin.com/in/rehrlich/
`Elias: https://www.linkedin.com/in/vinu-k-elias-a6424132/
`Flores: https://www.linkedin.com/in/jpcf/
`Howell: https://www.linkedin.com/in/richardwhowell/
`Jackson: https://www.linkedin.com/in/andy-jackson-387b851/
`Law: https://www.linkedin.com/in/sweehua/
`Leong: https://www.linkedin.com/in/deam-ieong-49632557/
`Lim: https://www.linkedin.com/in/kong-wai-lim-29234321/
`Martin: https://www.linkedin.com/in/susannah-martin-b716422/
`Mata: https://www.linkedin.com/in/luis-mata-04367646/
`Nasirian: https://www.linkedin.com/in/nasimnasirian/
`Nguyen: https://www.linkedin.com/in/dinh-nguyen-086b17/
`Reipold: https://www.linkedin.com/in/tony-reipold-20153518/
`Slockers: https://www.linkedin.com/in/shawn-slockers-52189b1a/
`Song: https://www.linkedin.com/in/zhen-song-a4a72219/
`Velagapudi: https://www.linkedin.com/in/supriya-velagapudi-a4375a/
`Vyas: https://www.linkedin.com/in/neema-vyas-b1326181/
`Williams: https://www.linkedin.com/in/kirtwilliams/
`Wilson: https://www.linkedin.com/in/david-wilson-791897/
`Zhou: https://www.linkedin.com/in/biyun-zhou-bb89999/
`
` 9
`
` Field Applications Engineer Job Posting, Intel Website (last visited June 2022), accessible at:
`https://jobs.intel.com/ShowJob/Id/3355235/Field-Applications-Engineer
`Design for Test Engineer Job Posting, Intel Website (last visited June 2022), accessible at:
`https://jobs.intel.com/ShowJob/Id/3446865/Design-for-Test-Engineer-(DFT)
`-6-
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 7 of 19
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`logic devices (such as FPGA chips), so that a single M-input N-output LUT can operate either as
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`a single “whole” LUT or as a plurality of “fractured” LUTs.
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`31.
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`This breakthrough in LUT architecture enabled a significant reduction in both
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`implementation area and power consumption for chips utilizing this innovation.
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`32.
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`For over 20 years, Professor Iida has remained at the forefront of his field by
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`teaching, conducting research, presenting at conferences, and publishing hundreds of articles and
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`other papers on various topics relating to programmable logic devices.
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`33.
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`On June 29, 2001, a Japanese patent application was filed on Professor Iida’s
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`invention.
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`34. On June 28, 2002, a United States patent application was filed on Professor Iida’s
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`invention, claiming priority directly to the prior-filed Japanese patent application.
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`35.
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`On November 2, 2004, the United States Patent and Trademark Office duly and
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`legally issued the ’737 patent.
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`36.
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`Since October 1, 2014, Professor Iida has been, and is presently, the sole owner of
`
`all right, title, and interest in the ’737 patent.
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`37.
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`By virtue of the claim of priority directly to a foreign application under 35 U.S.C.
`
`§ 119 (as opposed to a claim of priority through a PCT application), the 20-year term of the ’737
`
`patent is measured from its U.S. filing date. As a result, the ’737 patent expires on June 28,
`
`2022.
`
`38.
`
`The ’737 patent is presumed valid under 35 U.S.C. § 282.
`
`THE ACCUSED PRODUCTS
`
`39.
`
`The Accused Products are Intel’s programmable logic devices – FPGA chips and
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`SoC chips – that employ Adaptive Logic Modules (ALMs).
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`-7-
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 8 of 19
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`40.
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`Altera first employed ALMs into their programmable logic devices with the
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`introduction of the Stratix II line of FPGA chips in 2004.
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`41.
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`Altera expanded its use of ALMs by incorporating them into later generations of
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`Stratix chips (i.e., Stratix III, Stratix IV, Stratix V, and Stratix 10) as well as certain of its Arria
`
`and Cyclone lines of FPGA and SoC chips.
`
`42. With its acquisition of Altera in 2016, Intel continued the operations of Altera
`
`through its newly constituted business segment – the Programmable Solutions Group – which
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`included the design, manufacture, sale, and support of Stratix, Arria, and Cyclone chips that
`
`employ ALMs.
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`43.
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`In addition to continuing to make and sell Stratix, Arria, and Cyclone FPGA and
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`SoC chips that employ ALMs, Intel introduced a new line of FPGA and SoC chips under the
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`Agilex name that also employ ALMs.
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`44.
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`Intel has made, used, offered for sale, and/or sold, and continues to make, use,
`
`offer for sale, and/or sell, the following FPGA and SoC chips that employ ALMs:
`
`a. Stratix II FPGA products including EP2S15, EP2S30, EP2S60, EP2S90,
`EP2S130, and EP2S180;
`
`b. Stratix III E FPGA products including EP3SE50, EP3SE80, EP3SE110, and
`EP3SE260;
`
`c. Stratix III L FPGA products including EP3SL50, EP3SL70, EP3SL110,
`EP3SL150, EP3SL200, and EP3SL340;
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`d. Arria GX FPGA products including EP1AGX20, EP1AGX35, EP1AGX50,
`EP1AGX60 and EP1AGX90;
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`e. Stratix IV GT FPGA products including EP4S40G2, EP4S40G5, EP4S100G2,
`EP4S100G3, EP4S100G4, and EP4S100G5;
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`f. Stratix IV GX FPGA products including EP4SGX70, EP4SGX110, EP4SGX180,
`EP4SGX230, EP4SGX290, EP4SGX360, and EP4SGX530;
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 9 of 19
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`g. Stratix IV E FPGA products including EP4SE230, EP4SE360, EP4SE530, and
`EP4SE820;
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`h. Arria II GX FPGA products including EP2AGX45, EP2AGX65, EP2AGX95,
`EP2AGX125, EP2AGX190, and EP2AGX260;
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`i. Arria II GZ FPGA products including EP2AGZ225, EP2AGZ300, and
`EP2AGZ350;
`
`j. Stratix V E FPGA products including 5SEE9 and 5SEEB;
`
`k. Stratix V GS FPGA products including 5SGSD3, 5SGSD4, 5SGSD5, 5SGSD6,
`and 5SGSD8;
`
`l. Stratix V GX FPGA products including 5SGXA3, 5SGXA4, 5SGXA5, 5SGXA7,
`5SGXA9, 5SGXAB, 5SGXB5, 5SGXB6, 5SGXB9, and 5SGXBB;
`
`m. Arria V GT FPGA products including 5AGTC3, 5AGTC7, 5AGTD3, and
`5AGTD7;
`
`n. Arria V GX FPGA products including 5AGXA1, 5AGXA3, 5AGXA5, 5AGXA7,
`5AGXB1, 5AGXB3, 5AGXB5, and 5AGXB7;
`
`o. Arria V GZ FPGA products including 5AGZE1, 5AGZE3, 5AGZE5, and
`5AGZE7;
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`p. Arria V ST SoC products including 5ASTD3 and 5ASTD5;
`
`q. Arria V SX SoC products including 5ASXB3 and 5ASXB5;
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`r. Cyclone V E FPGA products including 5CEA2, 5CEA4, 5CEA5, 5CEA7, and
`5CEA9;
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`s. Cyclone V GT FPGA products including 5CGTD5, 5CGTD7, and 5CGTD9;
`
`t. Cyclone V GX FPGA products including 5CGXC3, 5CGXC4, 5CGXC5,
`5CGXC7, and 5CGXC9;
`
`u. Cyclone V SE SoC products including 5CSEA2, 5CSEA4, 5CSEA5, and
`5CSEA6;
`
`v. Cyclone V ST SoC products including 5CSTD5 and 5CSTD6;
`
`w. Cyclone V SX SoC products including 5CSXC2, 5CSXC4, 5CSXC5, and
`5CSXC6;
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 10 of 19
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`x. Stratix 10 DX SoC FPGA products including DX 1100, DX 2100, and DX 2800;
`
`y. Stratix 10 GX FPGA products including GX 400, GX 650, GX 850, GX 1100,
`GX 1650, GX 2100, GX 2500, GX 2800, GX 1660, GX 2110, and GX 10M;
`
`z. Stratix 10 MX FPGA products including MX 1650 and MX 2100;
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`aa. Stratix 10 SX SoC products including SX 400, SX 650, SX 850, SX 1100, SX
`1650, SX 2100, SX 2500, and SX 2800;
`
`bb. Stratix 10 TX FPGA products including TX 400, TX 850, TX 1100, TX 1650, TX
`2100, TX 2500, and TX 2800;
`
`cc. Stratix NX FPGA products including NX 2100;
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`dd. Arria 10 GT FPGA products including GT 900 and GT 1150;
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`ee. Arria 10 GX FPGA products including GX 160, GX 220, GX 270, GX 320, GX
`480, GX 570, GX 660, GX 900, and GX 1150;
`
`ff. Arria 10 SX SoC products including SX 160, SX 220, SX 270, SX 320, SX 480,
`SX 570, and SX 660;
`
`gg. Cyclone 10 GX FPGA products including 10CX085, 10CX105, 10CX150, and
`10CX220;
`
`hh. Agilex F-Series FPGA and SoC FPGA products including AGF 004, AGF 006,
`AGF 008, AGF 012, AGF 014, AGF 022, and AGF 027;
`
`ii. Agilex I-Series SoC FPGA products including AGI 022 and AGI 027; and
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`jj. Agilex M-Series FPGA products including AGM 032 and AGM 039.
`
`45. Upon information and belief, Intel’s annual revenues over the past six years from
`
`
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`the sale of the Accused Products constitute at least 80%, by dollar volume, of Intel’s annual
`
`revenues from the sale of products attributed to the PSG over that same period.
`
`
`
`46.
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`Intel recognized revenues of approximately $425 million in Q3 of 2016 from the
`
`sale of products attributed to the PSG.
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`
`
`47.
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`Intel recognized revenues of approximately $420 million in Q4 of 2016 from the
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`sale of products attributed to the PSG.
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 11 of 19
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`
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`48.
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`Intel recognized revenues of approximately $1.902 billion in 2017 from the sale
`
`of products attributed to the PSG.
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`
`
`49.
`
`Intel recognized revenues of approximately $2.123 billion in 2018 from the sale
`
`of products attributed to the PSG.
`
`
`
`50.
`
`Intel recognized revenues of approximately $1.987 billion in 2019 from the sale
`
`of products attributed to the PSG.
`
`
`
`51.
`
`Intel recognized revenues of approximately $1.853 billion in 2020 from the sale
`
`of products attributed to the PSG.
`
`
`
`52.
`
`Intel recognized revenues of approximately $1.934 billion in 2021 from the sale
`
`of products attributed to the PSG.
`
`
`
`53.
`
`Assuming the historical demand for Intel’s programmable logic devices has
`
`continued into 2022, Intel should recognize at least $900 million over the first half of 2022 from
`
`the sale of products that, prior to 2022, were attributed by Intel to its PSG (which are now
`
`reported within its DCAI Group).
`
`
`
`54. Over the six-year period immediately preceding the filing of this Complaint, Intel
`
`will have recognized at least $11.5 billion from the sale of products attributed to the PSG. Upon
`
`information and belief, at least 80% of those revenues will have been associated with the sale of
`
`the Accused Products.
`
`CLAIMS FOR RELIEF
`
`COUNT I – Direct Infringement of ’737 Patent
`
`55.
`
`The allegations set forth above are re-alleged and incorporated by reference as if
`
`they were set forth fully here.
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 12 of 19
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`56.
`
`Intel has directly infringed (literally and/or under the doctrine of equivalents), and
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`continues to infringe, at least claim 1 of the ’737 patent by making, using, offering to sell, and
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`selling the Accused Products without a license from Professor Iida.
`
`57.
`
`Professor Iida is the sole owner of all right, title, and interest in the ’737 patent
`
`with full rights to pursue recovery of damages for infringement.
`
`58.
`
`59.
`
`60.
`
`Each claim of the ’737 patent is valid, enforceable, and patent-eligible.
`
`Intel has never, either expressly or impliedly, been licensed under the ’737 patent.
`
`The Accused Products are Intel FPGA chips and SoC chips, as well as all other
`
`Intel products, that employ Adaptive Logic Modules (ALMs).
`
`61. ALMs are radically different from any other FPGA logic block, offering a number
`
`of major innovations.10
`
`62.
`
`Intel’s ALMs have look up tables (LUTs) that have M inputs and N outputs:11
`
`
`10 See Altera FPGA Architecture White Paper (attached as Exhibit 3) at p. 4.
`11 Id. at p. 7.
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 13 of 19
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`
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`63.
`
`The LUTs in Intel’s ALMs comprise a plurality of LUT units:12
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`
`
`
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`64.
`
`The LUTs in Intel’s ALMs also comprise an internal configuration control
`
`circuit:13
`
`
`
`12 Id.
`13 Id.
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 14 of 19
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`65.
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`The internal configuration control circuit of the LUTs in Intel’s ALMs controls
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`the internal configuration of the plurality of LUT units. A summary of combinational logic
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`configurations supported in an ALM are shown in the following table:14
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`14 Id. at p. 2.
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`-14-
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 15 of 19
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`66.
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`The internal configuration control circuit of the LUTs in Intel’s ALMs comprises
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`a plurality of selectors selecting I/O signals of said plurality of LUT units:15
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`67.
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`The internal configuration control circuit of the LUTs in Intel’s ALMs also
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`comprises a selector control circuit having a memory, controlling said plurality of selectors in
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`accordance with data stored in said memory, and defining the internal configuration of said
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`plurality of LUT units:16
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`15 Id. at p. 7.
`16 Fracturable FPGA Logic Elements, M. Hutton, et al. (2004) (attached as Exhibit 4) at p. 5.
`-15-
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 16 of 19
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`68.
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`The Accused Products infringe at least claim 1 of the ’737 patent.
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`69.
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`Intel has been on actual notice of the ’737 patent, and of Professor Iida’s specific
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`claims regarding Intel’s FPGA chips with ALMs, since at least February of 2018.
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`70. On February 19, 2018, counsel for Professor Iida sent a letter, via certified mail,
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`to the General Counsel of Intel in which she advised him that her firm had become aware that
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`Intel’s PSG “offers FPGAs with adaptive logic modules (ALMs) that appear to be claimed by
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`our client’s US Patent No. 6,812,737 entitled ‘PROGRAMMABLE LOGIC CIRCUIT DEVICE
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`HAVING LOOK UP TABLE ENABLING TO REDUCE IMPLEMENTATION AREA’
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`(enclosed).” A copy of this letter is attached as Exhibit 5.
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`71. Despite having been put on actual notice of the ’737 patent and of Professor Iida’s
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`specific claims regarding Intel’s use of ALMs in its programmable logic devices, Intel
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`nonetheless persisted in making, using, offering to sell, and selling the Accused Products.
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`72.
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`Intel’s actual knowledge of the ’737 patent and of Professor Iida’s claims since
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`February of 2018 has made its infringement of Professor Iida’s patent rights since that time
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`deliberate and intentional.
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`73.
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` Intel operates under a self-imposed Code of Conduct (the “Code”) which “applies
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`to every employee, members of the Intel Board of Directors, and employees of Intel subsidiaries”
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`as well as to “contingent workers, independent contractors, consultants, suppliers, and others
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`who do business with Intel.”17
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`17 Intel Code of Conduct at p. 6, Intel Website (last visited June 2022), available at:
`https://www.intel.com/content/www/us/en/policy/policy-code-conduct-corporate-information.html
`-16-
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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 17 of 19
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`74.
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`The Code purports to exemplify Intel’s “core values and its continuing
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`commitment to corporate responsibility” by setting forth how its employees “work and win with
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`integrity each day.”18
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`75. According to the Code, all Intel employees are mandated to “respect the
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`intellectual property rights of others.”19
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`76.
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`Intel has not respected the intellectual property rights of Professor Iida.
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`77.
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`Professor Iida has been damaged by Intel’s direct infringement of the ’737 patent
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`and is entitled to damages therefor as provided for in 35 U.S.C. § 284.
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`COUNT II – Indirect Infringement of ’737 Patent
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`78.
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`The allegations set forth above are re-alleged and incorporated by reference as if
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`they were set forth fully here.
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`79.
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`Intel’s distributors and end customers directly infringe at least claim 1 of the ’737
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`patent by offering for sale, selling, or using the Accused Products.
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`
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`80.
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`Intel has induced, and continues to induce, infringement of the ’737 patent under
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`35 U.S.C. § 271(b) by actively and knowingly aiding and abetting direct infringement by its
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`distributors and end customers.
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`
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`81.
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`Intel has been on actual notice of the ’737 patent and of Professor Iida’s claims
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`with regard to the Accused Products since at least as early as February of 2018. See Exhibit 5.
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`82. Despite such actual notice, Intel has induced, and continues to induce,
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`infringement of the ’737 patent by actively encouraging others, including its distributors and end
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`customers, to offer to sell, sell, or use the Accused Products. On information and belief, these
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`18 Id. at p. 2.
`19 Id. at p. 14.
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`-17-
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`

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`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 18 of 19
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`acts include providing the Accused Products to distributors; providing information and
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`instructions to distributors and end customers on the use of the Accused Products; and providing
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`information, education, and instructions supporting sales of the Accused Products by distributors.
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`See, e.g., roles and responsibilities of Intel employees as posted on their LinkedIn profile pages
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`attached as Exhibit 2.
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`83.
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`Professor Iida has been damaged by Intel’s indirect infringement of the ’737
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`patent and is entitled to damages therefor as provided for in 35 U.S.C. § 284.
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`JURY DEMAND
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`Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Professor Iida hereby
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`requests a trial by jury on all issues so triable.
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`PRAYER FOR RELIEF
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`WHEREFORE, Professor Masahiro Iida respectfully requests that the Court grant the
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`following relief:
`
`A.
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`A judgment in favor of Professor Iida that Intel has infringed the ’737 patent, and
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`that the ’737 patent is valid and enforceable;
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`B.
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`An award to Professor Iida of monetary damages adequate to compensate him for
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`Intel’s infringement but, in no event, less than a reasonable royalty for the use made of his
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`invention by Intel, together with costs and pre- and post-judgment interest pursuant to 35 U.S.C.
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`§ 284;
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`C.
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`An increase in the amount found by the jury and awarded to Professor Iida up to
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`three times that amount for Intel’s willful infringement pursuant to 35 U.S.C. § 284;
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`
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`D.
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`A finding that this case is exceptional under 35 U.S.C. § 285, and an award of
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`Professor Iida’s reasonable attorney’s fees; and
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`
`
`-18-
`
`

`

`Case 6:22-cv-00662-ADA Document 1 Filed 06/24/22 Page 19 of 19
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`E.
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`Any other and further relief that the Court determines to be just and equitable.
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`
`Dated: June 24, 2022
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`Respectfully submitted,
`
`Joshua R. Slavitt*
`Pennsylvania State Bar No. 63139
`SLAVITT IP LAW, LLC
`535 Hamilton Road
`Merion Station, PA 19066
`Phone: (215) 880-2569
`Email: josh@slavittiplaw.com
`
`
`Travis C. Barton
`Texas State Bar No. 00790276
`Richard D. Milvenan
`Texas State Bar No. 14171800
`McGINNIS & LOCHRIDGE LLP
`1111 W. 6th Street, Bldg. B, Suite 400
`Austin, TX 78703
`Phone: (512) 495-6005
`Facsimile: (512) 505-6305
`Email: tcbarton@mcginnislaw.com
`Email: rmilvenan@mcginnislaw.com
`
` By: /s/ Travis C. Barton
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`Jacob C. Cohn*
`Pennsylvania State Bar No. 54139
`Ilan Rosenberg*
`Pennsylvania State Bar No. 89668
`GORDON REES SCULLY MANSUKHANI LLP
`1717 Arch Street, Suite 610
`Philadelphia, PA 19103
`Phone: (215) 561-2300
`Email: jcohn@grsm.com
`Email: irosenberg@grsm.com
`
`*Pro hac vice to be filed
`
`Attorneys for Plaintiff,
`Professor Masahiro Iida
`
`-19-
`
`

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Professor Masahiro Iida v. Intel Corporation, 6:22-cv-00662, No. 1 (W.D.Tex. Jun. 24, 2022) (2024)
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