07
May
By Eric Schweibenz and Michael West
On May 7, 2018, Broadcom Corporation of San Jose, California filed a complaint (part 1 and part 2) requesting that the U.S. International Trade Commission (“Commission”) commence an investigation pursuant to Section 337.

The complaint alleges that the following entities (collectively, the “Proposed Respondents”) unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain infotainment systems that infringe one or more claims of U.S. Patent No. 6,937,187 (“the ’187 patent”); U.S. Patent No. 8,902,104 (“the ’104 patent”); U.S. Patent No. 7,512,752 (“the ’752 patent”); U.S. Patent No. 7,530,027 (“the ’027 patent”); U.S. Patent No. 8,284,844 (“the ’844 patent”); and U.S. Patent No. 7,437,583 (“the ’583 patent”) (collectively, the “Asserted Patents”):

  • Toyota Motor Corporation of Japan
  • Toyota Motor North America, Inc. of Plano, Texas
  • Toyota Motor Sales, U.S.A., Inc. of Plano, Texas
  • Toyota Motor Engineering & Manufacturing North America, Inc. of Plano, Texas
  • Toyota Motor Manufacturing, Indiana, Inc. of Princeton, Indiana
  • Toyota Motor Manufacturing, Kentucky, Inc. of Erlanger, Kentucky
  • Toyota Motor Manufacturing, Mississippi, Inc. of Tupelo, Mississippi
  • Toyota Motor Manufacturing, Texas, Inc. of San Antonio, Texas
  • Panasonic Corporation of Japan
  • Panasonic Corporation of North America of Newark, New Jersey
  • Denso Ten Limited of Japan
  • Denso Ten America Limited of Torrance, California
  • Renesas Electronics Corporation of Japan
  • Renesas Electronics America, Inc. of Milpitas, California
  • Japan Radio Corporation of Japan

According to the complaint, the asserted patents generally relate to the field of GNSS processing, video and graphics processing, and power and memory management. The asserted patents concern technologies used in infotainment systems, components thereof, and automobiles containing these infotainment systems. In particular, the ’187 patent describes a method and apparatus for locating position of a satellite signal receiver. The ’104 patent describes a method and apparatus for combining measurements and determining clock offsets between different satellite positioning systems. The ’752 patent generally relates to a memory access unit. The ’027 patent describes a system for processing graphics images for display that uses graphics windows, window descriptors for said graphics windows, and a display engine to reduce the memory required to process graphics images. The ’844 patent describes a cost-effective system for decoding digital video, encoded in any of a variety of bitstream formats, using hardware accelerators. The ’583 patent generally relates to a system for controlling clocks.

In the complaint, Broadcom states that the proposed Respondents import and sell products that infringe the asserted patents. The complaint specifically refers to head units, rear seat entertainment units, units for displaying information or entertainment, cameras, controllers, processing components and circuits used in such infotainment systems (such as SoCs and GNSS processing devices, including GNSS receivers and GNSS modules) located in or remotely from a head unit, and automobiles that contain such infotainment systems and components associated with the Proposed Respondents as the infringing products.

As to related litigation, Broadcom states that the ’187 patent was asserted in Investigation 337-TA-602, which settled in March 2011. The ’844 patent was asserted in Investigation 337-TA-1047, which is pending, and involved in related patent litigations in the U.S. District Court for the Central District of California. The ’844 patent was also involved in the following inter partes review proceedings: IPR2017-01111, IPR2017-01624, IPR2018-00013, and IPR2018-00477. IPR2017-01111 was terminated due to settlement. IPR2017-01624 was denied institution. IPR2018-00013 was instituted in April 2018. IPR2018-00477 was settled.

With respect to potential remedy, Broadcom requests that the Commission issue a limited exclusion order and permanent cease-and-desist orders directed at the Proposed Respondents and their related entities.