09
Mar
By Eric Schweibenz and Alex Englehart
On March 7, 2017, Broadcom Corporation of Irvine, California (“Broadcom”) filed a complaint requesting that the ITC 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 semiconductor devices and consumer audiovisual products containing the same that infringe one or more claims of U.S. Patent Nos. 8,284,844 (the ’844 patent), 7,590,059 (the ’059 patent), 8,068,171 (the ’171 patent), 7,310,104 (the ’104 patent), and 7,342,967 (the ’967 patent) (collectively, the “asserted patents”):

  • MediaTek Inc. of Taiwan
  • MediaTek USA Inc. of San Jose, California
  • MStar Semiconductor Inc. of Taiwan
  • Sigma Designs, Inc. of Fremont, California
  • LG Electronics Inc. of South Korea
  • LG Electronics U.S.A., Inc. of Englewood Cliffs, New Jersey
  • Funai Electric Company, Ltd. of Japan
  • Funai Corporation, Inc. of Rutherford, New Jersey
  • P&F USA, Inc. of Alpharetta, Georgia
  • Vizio, Inc. of Irvine, California

According to the complaint, the asserted patents generally relate to multimedia data processing technology. In particular, the ’844 patent relates to a system for decoding digital video using hardware accelerators. The ’059 patent relates to a system for decoding digital video streams encoded according to varying standards. The ’171 patent relates to fast-forward functionality of digital video streams, and more particularly to systems and methods that display pictures at a high speed, where, for example, the systems include, among other components, a buffer, a decoder, and a display manager. The ’104 patent relates to a system for blending graphics and video images. Lastly, the ’967 patent relates to a system for displaying pictures that includes, among other components, a host processor for transmitting transport packets providing a plurality of instructions and a video decoder for executing those instructions.

In the complaint, Broadcom states that the Proposed Respondents import and sell products that infringe the asserted patents. The complaint specifically refers to various semiconductor devices and consumer products that include such devices—including digital televisions, set-top boxes, Blu-ray disc players, DVD players/recorders, multimedia streaming players, and home theater systems—as infringing products.

Regarding domestic industry, Broadcom states that the technology of the asserted patents is widely incorporated into Broadcom’s semiconductor products, and particularly into Broadcom’s set-top box system-on-chip (“SoC”) products. Broadcom further states that it has conducted and continues to conduct extensive activities in the U.S. relating to its products that practice the asserted patents, including research and development and other technically-focused activities. Broadcom specifically refers to relevant facilities in California that occupy over 900,000 square feet of space. Broadcom also states that it invested over $100 million in the U.S. relating to the domestic industry products in fiscal year 2016 alone.

As to related litigation, Broadcom states that, contemporaneously with the filing of the instant ITC complaint, it is also filing complaints against the Proposed Respondents in the U.S. District Court for the Central District of California alleging infringement of the asserted patents. Broadcom further states that, on September 23, 2016, Broadcom and Avago Technologies General IP Singapore Pte Ltd brought an action against Amazon.com, Inc. and Amazon Web Services, Inc. in the U.S. District Court for the Central District of California, alleging infringement of, inter alia, the ’844 patent. Broadcom states that that action is still pending. Lastly, Broadcom states that it previously asserted the ’104 patent against SiRF Technology, Inc. and CSR plc.

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 related entities.
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