New 337 Complaints

Freescale Files New 337 Complaint Regarding Certain Integrated Circuits

By Eric Schweibenz
|
Jun
10
On June 8, 2011, Freescale Semiconductor, Inc. of Austin, Texas (“Freescale”) filed a Complaint requesting that the ITC commence an investigation pursuant to Section 337. The Complaint alleges that Funai Electric Co., Ltd. of Japan, Funai Corporation, Inc. of Rutherford, New Jersey (collectively, “Funai”), MediaTek Inc. of Taiwan (“MediaTek”) and Zoran Corporation of Sunnyvale, California (“Zoran”) unlawfully import, sell for importation, and/or sell within the U.S. after importation certain integrated circuits, chipsets, and products containing same that infringe U.S. Patent No. 5,467,455 (“the ‘455 patent”). According to the Complaint, the ‘455 patent is directed to circuitry that reduces unwanted signal reflection on a bi-directional communication bus between two integrated circuits by disabling the termination circuitry on one of the integrated circuits when data is not being received from the communication bus.  Freescale alleges that Funai, Zoran and MediaTek manufacture, import, sell for importation, and/or sell within the U.S. after importation products that infringe the ‘455 patent, including televisions.  The Complaint specifically refers to accused television products bearing brand names such as Philips, Magnavox, Emerson, Symphonic and Sylvania. According to Freescale, the Complaint was filed to (1) address evidentiary concerns identified in Investigation No. 337-TA-709 (“the 709 investigation”) in which Freescale was the Complainant and Funai were Respondents, and during which Zoran, a third-party supplier of integrated circuits to Funai, produced documents that Chief ALJ Paul J. Luckern found unreliable as evidence of the contents of the accused products; and (2) address the infringement of other Funai products that contain integrated circuits supplied by Zoran and MediaTek, as well as infringement of other end-products containing Zoran and/or MediaTek integrated circuits or chipsets.  In particular, Freescale asserts that in his Final Initial Determination in the 709 investigation (which the Commission declined to review) ALJ Luckern found that the datasheets and schematics produced by Zoran lacked any indicia of finality, but that if they were accorded weight, then the accused products would infringe claims 9 and 10 of the ‘455 patent.  Seeour May 20, 2011 post for more details. Regarding domestic industry, Freescale points to Order No. 33 in the 709 investigation, in which ALJ Luckern granted Freescale’s motion for summary determination that it had satisfied the domestic industry requirement based on licensing activities in the United States for each of the asserted patents in that investigation, including the ‘455 patent. The Complaint identifies the following related litigation regarding the ‘455 patent:  (1) infringement suit filed by Freescale against ProMOS Technologies in the Eastern District of Texas (C.A. No. 4:06-CV-491), settled by the parties in August 2008; (2) Investigation No. 337-TA-656, involving Freescale and Respondent LSI Corporation (“LSI”), terminated in November 2008 upon settlement by the parties; (3) infringement suit filed by Freescale against LSI in the Eastern District of Texas (C.A. No. 2:08-CV-314), stayed pursuant to 28 U.S.C. §1659 and ultimately dismissed by the parties; (4) the 709 investigation, which resulted in a finding of no violation; (5) infringement suit filed by Freescale against Funai in the Western District of Texas (C.A. No. 10-CV-138), filed on March 1, 2010; (6) request for re-examination of the ‘455 patent filed by anonymous third party on April 29, 2011; and (7) infringement suit filed by Freescale against Zoran and MediaTek in the Western District of Texas (C.A. No. 1:11-CV-472), filed on June 8, 2011. With respect to potential remedy, Freescale requests that the Commission issue a permanent exclusion order and permanent cease and desist orders directed at Funai, Zoran and MediaTek.
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Cypress Semiconductor Files New 337 Complaint Regarding Certain Static Random Access Memories

By Eric Schweibenz
|
Jun
15
On June 10, 2011, Cypress Semiconductor Corporation (“Cypress”) of San Jose, California filed a complaint requesting that the ITC commence an investigation pursuant to Section 337. The complaint alleges that GSI Technology, Inc. of Sunnyvale, California (“GSI”), Alcatel-Lucent of Paris, France (“ALU”), Telefonaktiebolaget LM Ericsson of Stockholm, Sweden (“Ericsson”), Motorola Solutions, Inc. of Schaumburg, Illinois (“Motorola”), Arrow Electronics, Inc. of Melville, New York (“Arrow”), and Nu Horizons Electronics Corp. of Melville, New York (“Nu Horizons”) unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain Static Random Access Memories (SRAM) and products containing same that infringe U.S. Patent Nos. 6,534,805 (the ‘805 patent), 6,651,134 (the ‘134 patent), 7,142,477 (the ‘477 patent), and 6,262,937 (the ‘937 patent) (collectively, the “asserted patents”). According to the complaint, while RAM storage is relatively volatile and must remain powered-up to preserve instructions or data stored therein, the SRAM technology generally relating to the asserted patents uses transistor-based circuitry to implement a bi-stable latch, which can be stable in either an “on” or “off” state.  Accordingly, a bit value written to a memory cell will be retained until it is deliberately changed.  More specifically, the complaint alleges that the ‘805 patent provides a new circuit configuration to minimize cell size, where a memory cell on a semiconductor substrate contains a series of four substantially oblong active regions arranged side-by-side with long substantially parallel axes. The active regions include inner active regions and outer active regions. Each of the inner active regions includes a pair of source/drain regions of one transistor type (such as a p-channel transistor) while the outer active regions of the series include a pair of source/drain regions for the opposite transistor type (such as an n-channel transistor).  The ‘134 patent relates to a memory product that includes a fixed “burst” memory, which generally allows multiple (and typically consecutive) addresses to be read using a single address. A fixed burst memory transfers a fixed number of words with each access (e.g., read or write access). Specifically, a fixed burst memory provides data from multiple address locations that can be accessed using a single address, and whose burst mode can be started and stopped using a control signal to avoid overwhelming the address and control buses. According to the complaint, fixed burst memory provides non-interruptible bursts, and operates at higher frequencies without needing interrupts to perform data refreshes.  The ‘477 patent discloses a QDR (“Quad Data Rate”) SRAM providing increased data rate by utilizing separate read and write address buses internal to the device.  This dual address bus architecture allows a write access and a read access to occur in a single cycle, thus increasing the amount of data that can be read from and written to the memory in a given time period.  Finally, the '937 patent relates to an increased data-rate random access memory that allows read and write operations to be executed in the same clock cycle, and also allows successive asserted addresses for read and write operations to be unrelated. In the complaint, Cypress alleges that GSI engages Taiwan Semiconductor Manufacturing Company and Advanced Semiconductor Engineering in Taiwan, together with other original equipment manufactures outside the United States to produce, process, manufacture, assemble and test accused SRAM products, which are then purchased by ALU, Ericsson, and Motorola LG and incorporated into downstream products, including networking products such as routers and/or switches that are in turn imported into the United States.  The complaint further alleges that Arrow and Nu Horizons distribute and/or resell the accused SRAM in the United States.  Cypress specifically identifies the Sigma DDR, SigmaQuad-II, and SigmaQuad-III families of GSI memory products as infringing one or more of the asserted patents, and the complaint further identifies downstream products by ALU, Ericsson, Motorola that incorporate these accused GSI products. Regarding domestic industry, Cypress asserts that its QDR Synchronous SRAM products, such as the QDR, QDR-II, and QDR-II+ product families are covered by claims of the asserted patents.  As to the economic prong, Cypress asserts significant investment in plant and equipment, labor and capital, and substantial investment in the exploitation of the asserted patents through research, development, fabrication and manufacturing performed at its facilities in San Jose, California and Bloomington, Minnesota. As to related litigation, Cypress states that it filed a complaint on March 30, 2011, against GSI in the U.S. District Court for the District of Minnesota relating to the ‘805, ‘134, and ‘477 patents. With respect to potential remedy, Cypress requests that the Commission issue a permanent limited exclusion order and permanent cease and desist orders directed at each proposed respondent and their affiliates, subsidiaries, successors, and assigns.
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Ogma Files New 337 Complaint Regarding Certain Motion-Sensitive Sound Effects Devices And Image Display Devices

By Eric Schweibenz
|
Jun
15
On June 13, 2011, Ogma, LLC of Longview, Texas (“Ogma”) 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 motion-sensitive sound effects devices and image display devices and components and products containing same that infringe one or both of U.S. Patent Nos. 6,150,947 (the ‘947 patent) and 5,825,427 (the ‘427 patent) (collectively, the “asserted patents”):
  • 3M Company of St. Paul, Minnesota
  • Bensussen Deutsch & Associates, Inc. dba Power A of Woodinville, Washington
  • Casio America, Inc. of Dover, New Jersey
  • Casio Computer Co., Ltd. of Japan
  • Christie Digital Systems USA, Inc. of Cypress, California
  • Eiki International, Inc. of Rancho Santa Margarita, California
  • Intec, Inc. of Miami, Florida
  • Mitsubishi Electric Corporation of Japan
  • Mitsubishi Electric & Electronics USA, Inc. of Cypress, California
  • Optoma Corporation of Taiwan
  • Optoma Technology, Inc. of Milpitas, California
  • Performance Designed Products LLC of Sherman Oaks, California
  • Planar Systems, Inc. of Beaverton, Oregon
  • Supersonic, Inc. of Commerce, California
  • Toshiba Corporation of Japan
  • Toshiba America Information Systems, Inc. of Irvine, California
According to the complaint, the ‘947 patent discloses a novel sound-effect device that couples a motion-sensitive actuator and a playback component to produce sounds associated with accelerations of the device.  In particular, the complaint states that electronic devices that employ the inventions claimed in the ‘947 patent, such as cellular phones, tablet computers, toys, video game devices and other electronics devices, employ an accelerometer that detects changes in motion and uses such changes to trigger the playing of sound effects.  As to the ‘427 patent, the complaint states that that patent is directed to an improved image display system that optimally produces video images that have aspect ratios intermediate to those of the traditional 4:3 aspect ratio of standard television and the 16:9 ratio of high definition television. In the complaint, Ogma states that the Proposed Respondents import and sell products that infringe the asserted patents.  The complaint specifically identifies a number of infringing products that are produced by the various Proposed Respondents. Regarding domestic industry, Ogma states that it and its predecessors-in-interest have made substantial investments in the exploitation of the asserted patents in the U.S., particularly in connection with licensing efforts.  Ogma further states that its licensees have made substantial investments in plant, equipment, labor and capital in the exploitation of the asserted patents.  In particular, Ogma has licensed the ‘947 patent to Source Audio, Inc. (“Source Audio”) and the complaint states that Source Audio’s Hot Hands Motion Controlled Phaser Flanger practices valid claims of the ‘947 patent, and further that Source Audio has made substantial investments in the U.S. related to its Hot Hands products.  With respect to the ‘427 patent, Ogma states that its predecessor licensed the ‘427 patent to Hewlett-Packard Company (“HP”) and that HP has conducted significant domestic industry activities in the U.S. relating to its LCD monitor products, which practice the ‘427 patent. As to related litigation, Ogma states that on April 1, 2011, it filed a complaint in the ITC alleging that various entities violate Section 337 in connection with the importation into the U.S., sale for importation, and/or sale within the U.S. after importation of certain motion-sensitive sound effects devices and image display devices and components and products containing same that infringe one or both the ‘947 and ‘427 patents.  Seeour April 4, 2011 post for more details.  On May 13, 2011, the ITC instituted an investigation (Inv. No. 337-TA-773) based on Ogma’s complaint of April 1, 2011 and subsequent filings.  Seeour May 17, 2011 post for more details.  Additionally, Ogma states that on February 3, 2011, it filed suit in the U.S. District Court for the Eastern District of Texas accusing a number of defendants of infringing the ‘947 patent.  Ogma further states that on March 11, 2011, it filed another lawsuit in the U.S. District Court for the Eastern District of Texas accusing various other defendants of infringing the ‘947 patent.  Moreover, Ogma states that on March 14, 2011, it filed a third lawsuit in the U.S. District Court for the Eastern District of Texas accusing various defendants of infringing the ‘427 patent.  Finally, Ogma states that on March 16, 2011, it filed a fourth lawsuit in the U.S. District Court for the Eastern District of Texas accusing various other defendants of infringing the ‘427 patent.  According to the complaint, Ogma’s claims against certain of the defendants in this fourth lawsuit have been severed and stayed pending resolution of all ITC proceedings between Ogma and those defendants.  The complaint also states that on December 18, 2006, Ogma’s predecessor filed suit against Hewlett Packard, Inc. and Dell, Inc. in the U.S. District Court for the Central District of California alleging infringement of the ‘427 patent.  According to the complaint, this case settled after Hewlett Packard, Inc. and Dell, Inc. took licenses to the ‘427 patent. With respect to potential remedy, Ogma requests that the Commission issue a permanent exclusion order and permanent cease and desist orders directed at the Proposed Respondents.
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Trek Files New 337 Complaint Regarding Certain Universal Serial Bus (“USB”) Portable Storage Devices, Including USB Flash Drives

By Eric Schweibenz
|
Jun
17
On June 14, 2011, Trek 2000 International Ltd., Trek Technology (Singapore) Pte. Ltd., and S-Com System (S) Pte. Ltd. (collectively, “Trek”), all of Singapore, filed a complaint requesting that the ITC commence an investigation pursuant to Section 337. The complaint alleges that Imation Corp. of Oakdale, Minnesota (“Imation”), IronKey, Inc. of Sunnyvale, California (“IronKey”), Kingston Technology Co., Inc. of Fountain Valley, California (“Kingston”), Patriot Memory, LLC of Fremont, California (“Patriot”), RITEK Corp. of Taiwan and Advanced Media, Inc./RITEK USA of Diamond Bar, California (collectively, “RITEK”), and Verbatim Corp., Inc. of Charlotte, North Carolina and Verbatim Americas, LLC of Charlotte, North Carolina (collectively, “Verbatim”) (all collectively, the “Proposed Respondents”) unlawfully import into the U.S., sell for importation, sell within the U.S. after importation and/or offer for sale within the U.S. after importation certain universal serial bus (“USB”) portable storage devices, including USB flash drives and components thereof that infringe one or more claims of U.S. Patent Nos. 6,880,054 (the ‘054 patent), 7,039,759 (the ‘759 patent), D463,426 (the ‘426 patent), and/or 7,549,161 (the ‘161 patent) (collectively, the “asserted patents”). According to the complaint, the asserted patents generally relate to USB flash drive technology.  In particular, the ‘054 and ‘759 patents relate to a USB flash drive that connects to the USB port of a computer and includes memory and a memory control device that controls the flow of data from the computer to the memory of the device.  The ‘054 patent further relates to a method of restricting access to data in a USB flash drive.  The ‘759 patent further relates to a device that has a USB plug integrated into the device, such that the device can be connected to a USB port of a computer without an intervening cable.  The ‘161 patent relates to an apparatus and method for implementing biometrics-based access control to a portable storage device, such as a USB flash drive having fingerprint access control.  Lastly, the ‘426 patent relates to the ornamental design for a portable data storage device. In the complaint, Trek alleges that the Proposed Respondents import and sell products that infringe the asserted patents.  The complaint specifically refers to the Imation Nano Flash Drive, Swivel Flash Drive, Pivot Plus Flash Drive, Pocket Flash Drive, Clip Flash Drive, Atom Flash Drive, and Defender series; the IronKey Enterprise series, Personal series, and Basic series; the Kingston DataTraveler 200, DataTraveler 310, DataTraveler 410, DataTraveler Locker series, DataTraveler 4000, and DataTraveler Vault; the Patriot Signature Line Bolt and Xporter Dash; the RITEK EZ Slider, EZ Twister, and EZ Sakura & Cursive; and the Verbatim Store ‘n’ Go series, BlazeDrive, Tuff-‘n’-Tiny, and Tuff-Clip. Regarding domestic industry, Trek states that it conducts significant licensing and enforcement activities in the U.S. relating to the asserted patents.  In particular, Trek states that it has invested substantial amounts in the U.S. towards analyzing third party products in comparison with Trek’s patents, enforcing the asserted patents, and negotiating licenses for Trek’s patents.  Trek further states that it continues to invest in licensing its patents, including investments directed at maintaining existing licenses and seeking additional licensees of the asserted patents.  According to the complaint, a domestic industry exists under Subpart (C) of Section 337(a)(3) by virtue of Trek’s substantial investment in the exploitation of the asserted patents. As to related litigation, Trek states that on August 5, 2006, it filed suit against Hana Micron Inc. and Hana Micron America, Inc. in the U.S. District Court for the Central District of California, alleging infringement of the ‘054 and ‘759 patents.  Trek further states that this district court case was terminated based on a voluntary dismissal filed on December 12, 2006.  Trek also states that from 2002 to 2005 it was involved in litigation in the Supreme Court of Singapore against M-Systems Flash Disk Pioneers Ltd., FE Global Electronics Pte. Ltd., Electec Pte. Ltd., and Ritronics Components (Singapore) Pte. Ltd. in connection with a Singapore patent that is related to the ‘054 and ‘759 patents. With respect to potential remedy, Trek requests that the Commission issue a limited exclusion order and a permanent cease and desist order directed at the Proposed Respondents and their affiliates, subsidiaries, successors, and assigns.
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Twin-Star Files New 337 Complaint Regarding Certain Electric Fireplaces

By Eric Schweibenz
|
Jun
21
On June 17, 2011, Twin-Star International, Inc. of Delray Beach, Florida and TS Investment Holding Corp. of Miami, Florida (collectively, “Twin-Star”) filed a complaint requesting that the ITC commence an investigation pursuant to Section 337. The complaint alleges that Shenzhen Reliap Industrial Co., Ltd. of China (“Reliap”) and Yue Qiu Sheng, a.k.a. Jason Yue of China (“Yue”) (collectively, the “Proposed Respondents”) unlawfully engage in unfair methods of competition and unfair acts in connection with the importation into the U.S., sale for importation, and/or sale within the U.S. after importation of certain electric fireplaces, components thereof, and products containing same and in relation to certain processes for manufacturing or relating to same.  According to the complaint, the unfair methods of competition and unfair acts at issue include the Proposed Respondents’ actual and threatened misappropriation of Twin-Star’s trade secrets, the Proposed Respondents’ infringement of Twin-Star’s registered copyrights, and Yue’s breach of contract. According to the complaint, the technology at issue relates to electric fireplaces.  In particular, the complaint states that “[a]n electric fireplace is a kinetic sculpture approximating the size and look of a real, wood burning fireplace.”  The complaint further states that an electric fireplace “replicates the moving flames, burning embers, and charred wood of a real wood-burning fireplace” and that the electric fireplace “may incorporate an electric heater to simulate heat radiated by a real wood-burning fireplace.” The complaint refers to Twin-Star’s trade secrets, Twin-Star’s component supplier list, Twin-Star’s customer list, the Twin-Star manufacturing process, the development of the Twin-Star technology, Twin-Star’s manufacturing specifications, hardware and software for a “Twin-Star Prototype 3 LED Functional Indicator Display,” and certain Twin-Star registered U.S. copyrights – including for the “E1 MANUAL,” “E22 MANUAL,” “KINETIC SCULPTURE 1,” and “KINETIC SCULPTURE 2” – as the intellectual property at issue. In the complaint, Twin-Star alleges that the Proposed Respondents import and sell Reliap Electric Fireplaces and related user manuals and that the Proposed Respondents wrongfully entered into the electric fireplace products industry through the misappropriation of Twin-Star’s trade secrets.  According to the complaint, Yue was formerly employed by Twin-Star and, since the termination of his employment, Yue has misappropriated Twin-Star’s trade secrets in connection with the formation of his own new company Reliap.  The complaint also accuses the Proposed Respondents of infringing Twin-Star’s registered copyrights.  Lastly, the complaint states that Yue has breached his Stockholder Agreement with Twin-Star through his wrongful solicitation of customers, wrongful use and/or disclosure of confidential information, and wrongful competition. Regarding domestic industry, Twin-Star states that a domestic industry exists “because of market realities,” including:  (a) Twin-Star’s design and distribution of electric fireplace products and their related technology in the U.S.; (b) Twin-Star’s manufacturing-related and other activities relating to its electric fireplace products technology in the U.S.; (c) Twin-Star’s substantial investment in exploitation, including engineering, research and development of its electric fireplace products technology in the U.S.; (d) Twin-Star’s significant employment of labor and capital relating to its electric fireplace technology in the U.S.; and (e) Twin-Star’s significant investment in facilities and equipment relating to its electric fireplace products technology in the U.S. With respect to potential remedy, Twin-Star requests that the Commission issue an exclusion order, a cease and desist order, and an order instructing the Proposed Respondents to immediately and verifiably turn over to Twin-Star all documents and things in their possession, custody, or control that contain or embody one or more of Twin-Star’s trade secrets or any information derived from or based on one or more of Twin-Star’s trade secrets.
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Vizio Files New 337 Complaint Regarding Certain Digital Televisions and Components Thereof

By Eric Schweibenz
|
Jun
21
On June 16, 2011, Vizio Inc. of Irvine, California (“Vizio”) filed a complaint requesting that the ITC commence an investigation pursuant to Section 337. The Complaint alleges that Coby Electronics Corp. of Lake Success, New York (“Coby”), Curtis International, Inc. of Canada (“Curtis”), ESI Enterprises, Inc. d/b/a Viore of Van Nuys, California (“ESI”), MStar Semiconductor, Inc. of Taiwan (“MStar”), ON Corp. US, Inc. of San Diego, California (“ON Corp.”), Renesas Electronics Corporation of Japan, Renesas Electronics America, Inc. of Santa Clara, California (collectively, “Renesas”), Sceptre, Inc. of City of Industry, California (“Sceptre”) and Westinghouse Digital, LLC of Orange, California (“Westinghouse”) unlawfully import, sell for importation, and/or sell within the U.S. after importation certain digital televisions and components thereof that infringe U.S. Patent Nos. 5,511,096 (“the ‘096 patent”), 5,621,761 (“the ‘761 patent”), 5,703,887 (“the ‘887 patent”), 5,745,522 (“the ‘522 patent”) and 5,511,082 (“the ‘082 patent”). According to the Complaint, the asserted patents relate to various techniques for the decoding and demodulation of digital TV signals transmitted via a digital cable TV system to a receiver that is both fast and has a low error rate, which includes using Quadrature Amplitude Modulation as implemented in all digital cable TV delivery systems throughout the U.S.  Vizio alleges that Coby, Curtis, ESI, ON Corp., Sceptre and Westinghouse directly infringe and/or induce infringement of the asserted patents through the use, sale, offer for sale, and/or importation of accused digital televisions, and that MStar and Renesas directly infringe by supplying components of same.  The complaint specifically identifies a number of allegedly infringing representative products produced or sold by the proposed respondents. Vizio asserts that a domestic industry exists, or is in the process of being established, through the significant employment of labor and capital and substantial investment in the exploitation of the asserted patents, including aftermarket customer service and technical support for Vizio’s digital televisions, as well as Vizio’s licensing activities.  Regarding the technical prong, Vizio specifically identifies its E420VL digital television as covering at least one claim of each asserted patent.  As to the economic prong, Vizio points to (1) two call centers it operates in the U.S. that provide aftermarket customer service and technical support for its domestic industry products, as well as other call centers operated by third parties contracted by Vizio; (2) Vizio’s investments in domestic aftermarket customer service and technical support programs; and (3) licensing activities related to the asserted patents, such as researching the digital TV market to identify and communicate with potential licensees. The Complaint identifies the following related litigation regarding the asserted patents:  (1) infringement suit filed by Vizio on May 20, 2011 against Coby, Curtis, ESI, ON Corp., Sceptre and Westinghouse in the Central District of California (C.A. No. 11-cv-04381); (2) infringement suit filed by Vizio on June 5, 2009 against LG Electronics, Inc. and LG Electronics U.S.A., Inc. in the District of Maryland (C.A. No. 09-cv-1481), dismissed upon settlement; (3) infringement suit filed by Vizio on May 20, 2009 against Funai Electric Co., Ltd. in the Central District of California (C.A. No. 09-cv-05813), dismissed upon settlement; (4) infringement suit filed by Vizio on May 13, 2009 against Sony Corp. and Sony Electronics, Inc. in the Southern District of California (C.A. No. 09-cv-01043), dismissed upon settlement; and (5) Investigation No. 337-TA-733, filed on July 16, 2010 and terminated by settlement agreement. With respect to potential remedy, Vizio requests that the Commission issue a permanent exclusion order and permanent cease and desist orders directed at the proposed respondents.
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Kaneka Files New 337 Complaint Regarding Certain Coenzyme Q10 Products

By Eric Schweibenz
|
Jun
21
On June 17, 2011, Kaneka Corporation of Japan (“Kaneka”) filed a complaint requesting that the ITC commence an investigation pursuant to Section 337. The complaint alleges that Zhejiang Medicine Co., Ltd. of China and ZMC-USA, L.L.C. of The Woodlands, Texas (collectively, “ZMC”), Xiamen Kingdomway Group Co. of China (“XKGC”), Pacific Rainbow International Inc. of City of Industry, California (“PRI”), Mitsubishi Gas Chemical Co., Inc. of Japan (“MGCC”), Maypro Industries, Inc. of Purchase, New York (“MAYPRO”), and Shenzhou Biology & Technology Co., Ltd. of China (“SBTC”) (collectively, the “Proposed Respondents”) unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain Coenzyme Q10 products made by certain processes that infringe one or more claims of U.S. Patent No. 7,910,340 (the ‘340 patent). According to the complaint, the ‘340 patent generally relates to novel processes for producing oxidized Coenzyme Q10 on an industrial scale.  The complaint states that Coenzyme Q10 is a powerful, fat-soluble, vitamin-like substance that is found naturally in all forms of animal life and is vital in the production of energy. In the complaint, Kaneka alleges that the Proposed Respondents manufacture, import and/or sell products that infringe the ‘340 patent.  The complaint specifically identifies a number of infringing products that are produced and/or sold by the various Proposed Respondents. Regarding domestic industry, Kaneka states that its own Coenzyme Q10 products, including the “KanekaQ10” and “Kaneka Q10 Emulsified Powder” are made by processes that practice one or more claims of the ‘340 patent.  As to the economic prong, Kaneka refers to its wholly-owned subsidiary Kaneka Nutrients L.P. of Pasadena, Texas (“KNL”) and states that KNL manufactures, markets, and sells the KanekaQ10 product in the U.S.  Kaneka also states that many U.S. brands formulate their Coenzyme Q10 products with Kaneka’s own KanekaQ10 product, and that KanekaQ10 is incorporated into a variety of finished products sold in the U.S. including cosmetics, oral care products, and beverages.  Kaneka further states that it has funded Coenzyme Q10 research projects in the U.S. As to related litigation, Kaneka states that on March 22, 2011, it filed suit against the Proposed Respondents in the U.S. District Court for the Central District of California alleging infringement of the ‘340 patent.  Kaneka states that this district court case is currently pending.  Additionally, Kaneka states that on March 21, 2011, ZMC filed a declaratory judgment action against Kaneka in the U.S. District Court for the Southern District of Texas in connection with the ‘340 patent.  Kaneka further states that on March 22, 2011, ZMC filed a second declaratory judgment action against Kaneka in the U.S. District Court for the District of Columbia in connection with the ‘340 patent.  Lastly, Kaneka states that on May 28, 2009, it filed suit against XKGC and PRI in the U.S. District Court for the Central District of California alleging infringement of U.S. Patent No. 7,145,044 (the ‘044 patent), which relates to methods for producing reduced Coenzyme Q10.  According to the complaint, the parties to this 2009 case reached a settlement whereby XKGC and PRI acknowledged the validity and enforceability of the ‘044 patent and agreed to discontinue their reduced Coenzyme Q10 products in the U.S. for the remainder of the ‘044 patent’s lifetime. With respect to potential remedy, Kaneka requests that the Commission issue a general exclusion order — or in the alternative, a limited exclusion order — and a permanent cease and desist order directed at the Proposed Respondents.
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AUO Files New 337 Complaint Regarding Certain Flat Panel Display Devices

By Eric Schweibenz
|
Jun
28
On June 27, 2011, AU Optronics Corporation of Taiwan and AU Optronics Corporation America of Milpitas, California (collectively, “AUO”) filed a complaintrequesting that the ITC commence an investigation pursuant to Section 337. The complaint alleges that Samsung Electronics Co., Ltd. of Korea and Samsung Electronics America, Inc. of Ridgefield Park, New Jersey (collectively, “Samsung”), AT&T, Inc. of Dallas, Texas, Best Buy Co., Inc. of Richfield, Minnesota, and BrandsMart USA, Inc. of Hollywood, Florida (all collectively, the “Proposed Respondents”) unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain flat panel display devices and products containing the same that infringe one or more claims of U.S. Patent Nos. 6,281,955 (the ‘955 patent), 7,697,093 (the ‘093 patent), 7,286,192 (the ‘192 patent), 6,818,967 (the ‘967 patent), 7,199,854 (the ‘854 patent), and 7,663,729 (the ‘729 patent) (collectively, the “asserted patents”). According to the complaint, the asserted patents generally relate to flat panel display technology.  In particular, the ‘955 patent relates to novel structures and techniques for liquid crystal display (“LCD”) devices to obtain excellent picture quality of color images, reduced assembly defects, and high production yields.  The ‘093 patent relates to novel structures for improving the display quality of LCDs by improving the color wash out problem under wide viewing angles and preventing light leakage from occurring.  The ‘192 patent relates to novel structures for improving the viewing quality of LCDs.  The ‘967 patent relates to low temperature poly-silicon thin-film transistors (“TFTs”) fabricated by novel techniques.  The ‘854 patent relates to novel structures and techniques to simplify grounding apparatus used for grounding printed circuit boards (“PCBs”) of an LCD, which can also save time needed to assemble the grounding apparatus with PCB.  Lastly, the ‘729 patent relates to novel techniques for arranging photo spacers in a flat display device, such as an LCD panel. In the complaint, AUO alleges that the Proposed Respondents import and sell products that infringe the asserted patents.  The complaint specifically refers to a Samsung 46” LCD television, the Samsung AT&T Captivate smartphone, and a Samsung 10.1” laptop LCD screen model as infringing products. Regarding domestic industry, AUO states that certain AUO TV Modules, Phone Modules, and Notebook Modules practice the asserted patents in the U.S.  As to the economic prong, AUO states that it has made significant investments in facilities and in employment of labor and capital for the repair and maintenance of its products and for customer support engineering in the U.S.  AUO further states that it has made, and is contractually bound to continue to make, substantial investments in the exploitation of the asserted patents in the U.S. As to related litigation, AUO states that the ‘955 and ‘093 patents are currently the subject of a declaratory judgment action that was filed by Samsung Electronics Co., Ltd. on June 1, 2011 in the U.S. District Court for the Northern District of California.  AUO further alleges that, concurrently with the filing of the instant ITC complaint, it has filed a civil action against the Proposed Respondents in the U.S. District Court for the Northern District of California alleging infringement of the ‘955 and ‘093 patents, as well as other patents not asserted in the ITC.  AUO additionally states that, also concurrently with the filing of the instant ITC complaint, it has filed another civil action against the Proposed Respondents in the U.S. District Court for the District of Delaware alleging infringement of the ‘192, ‘729, ‘967, and ‘854 patents. With respect to potential remedy, AUO requests that the Commission issue a permanent exclusion order and a permanent cease and desist order directed at the Proposed Respondents.
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Samsung Files New 337 Complaint Regarding Certain Electronic Devices, Including Wireless Communication Devices, Portable Music And Data Processing Devices, And Tablet Computers

By Eric Schweibenz
|
Jun
30
On June 28, 2011, Samsung Electronics Co., Ltd. of Korea and Samsung Telecommunications America, LLC of Richardson, Texas (“STA”) (collectively, “Samsung”) filed a complaint requesting that the ITC commence an investigation pursuant to Section 337. The complaint alleges that Apple Inc. of Cupertino, California (“Apple”) unlawfully imports into the U.S., sells for importation, and/or sells within the U.S. after importation certain electronic devices, including wireless communication devices, portable music and data processing devices, and tablet computers that infringe one or more claims of U.S. Patent Nos. 7,706,348 (the ‘348 patent), 7,486,644 (the ‘644 patent), 6,771,980 (the ‘980 patent), 6,879,843 (the ‘843 patent), and 7,450,114 (the ‘114 patent) (collectively, the “asserted patents”). According to the complaint, the asserted patents generally relate to technology used in electronic devices.  In particular, the ‘348 patent relates to third-generation (“3G”) wireless technology and the ability to simultaneously transmit multiple services.  The ‘644 patent relates to the 3GPP/UMTS standards that govern many, if not most, cell phones sold in the U.S.  The ‘980 patent relates to, among other things, integrating personal digital assistant (“PDA”) functions (e.g., surfing the web) with mobile phone functions (e.g., dialing a number).  The ‘843 patent relates to a device and method for storing and reproducing digital audio data in a mobile terminal.  Lastly, the ‘114 patent relates to, among other things, manipulating and viewing digital documents using a touch-sensitive display screen. In the complaint, Samsung alleges that Apple imports and sells products that infringe the asserted patents.  The complaint specifically refers to the Apple iPhone 4, iPad 2 3G, and iPod Touch as infringing products. Regarding domestic industry, Samsung states that its own wireless communications devices (including, e.g., the Samsung Galaxy S 4G T959V Smartphone) practice at least one claim of each of the asserted patents in the U.S.  Samsung further states it conducts significant activities in the U.S. relating to the technology of the asserted patents.  In particular, the complaint points to STA engineers and other personnel in the U.S. that are engaged in activities necessary to commercialize and support Samsung’s wireless communications devices covered by the asserted patents and exploit the technology claimed in the asserted patents.  The complaint further states that STA has made substantial investments in its research and development program that supports Samsung’s wireless communications devices covered by the asserted patents, including investments at its headquarters in Richardson, Texas and its research facility in San Jose, California.  Samsung also points to additional facilities in New Jersey, Georgia, Washington, Kansas, Texas, and California. As to related litigation, Samsung states that a parent of the ‘348 patent was involved in prior litigation with Ericsson, Inc. and related entities at the ITC (Inv. No. 337-TA-577) and in the U.S. District Court for the Eastern District of Texas.  Samsung further states that the European counterpart to the ‘348 patent was asserted in litigation against various Ericsson and Sony Ericsson entities in Germany, the UK, and the Netherlands.  According to the complaint, all of these cases – both in the U.S. and in Europe – ended in 2007 pursuant to settlement agreements between the parties.  Additionally, Samsung states that on April 21, 2011, Samsung Electronics GmbH filed an action in Germany against Apple Inc. and Apple GmbH alleging infringement of the European counterpart to the ‘348 patent. With respect to potential remedy, Samsung requests that the Commission issue a permanent exclusion order and a permanent cease and desist order directed at Apple, its subsidiaries, related companies and agents.
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ObjectVideo Files New 337 Complaint Regarding Certain Video Analytics Software, Systems

By Eric Schweibenz
|
Jul
05
On June 29, 2011, ObjectVideo, Inc. of Reston, Virginia (“ObjectVideo”) filed a complaint requesting that the ITC commence an investigation pursuant to Section 337. The complaint alleges that Robert Bosch GmbH of Germany and Bosch Security Systems, Inc. of Fairpoint, New York (collectively, “Bosch”), Samsung Techwin Co., Ltd. of Korea and Samsung Opto-Electronics America Inc. d/b/a Samsung Techwin America, Inc. of Ridgefield Park, New Jersey (collectively, “Samsung”), and Sony Corporation of Japan and Sony Electronics, Inc. of San Diego, California (collectively, “Sony”) (all collectively, the “Proposed Respondents”) unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain video analytics software, systems, components thereof, and products containing same that infringe one or more claims of U.S. Patent Nos. 6,696,945 (the ‘945 patent), 6,970,083 (the ‘083 patent), 7,613,324 (the ‘324 patent), 7,424,175 (the ‘175 patent), 7,868,912 (the ‘912 patent) and 7,932,923 (the ‘923 patent) (collectively, the “asserted patents”). According to the complaint, the asserted patents generally relate to various aspects of video analytics systems.  In particular, the ‘945 and ‘083 patents relate to a method and system that receives video from a device, such as a security camera, and then gathers and processes data based on the video.  The ‘324 patent relates to a method and system for detecting the change in posture of a person in a video data stream.  The ‘175 patent relates to a method and system for segmenting video into foreground portions and background portions using statistical modeling of the chromatic and/or intensity values of pixels in the video.  Lastly, the ‘912 and ‘923 patents relate to a method and system which can reduce the overall processing burden of a video surveillance system by, in some implementations, eliminating the need for video data to be reprocessed. In the complaint, ObjectVideo alleges that the Proposed Respondents import and sell products that infringe the asserted patents.  The complaint specifically refers to the Bosch Intelligent Video Analysis software — which is incorporated into certain Bosch camera products and encoder products — and the Bosch Archive Player for Forensic Search software and Bosch Video Client for Forensic Searching software.  The complaint further refers to the Samsung WiseNet Digital Signal Processor, which is incorporated into certain Samsung camera products.  Lastly, the complaint refers to Sony Real Shot Manager software products, Sony DEPA Platform camera products, Sony encoders, and Sony cameras having DEPA Advanced technology. Regarding domestic industry, ObjectVideo states that it has established a domestic industry in the U.S. pursuant to 19 U.S.C. § 1337(a)(3)(C) through its substantial investment in licensing the asserted patents.  According to the complaint, ObjectVideo employs a staff of three attorneys  who provide legal support in connection with the licensing and enforcement of ObjectVideo’s intellectual property.  ObjectVideo further states that it has three additional employees who provide technical analysis in support of ObjectVideo’s licensing efforts, and that it also works with outside consultants for the purpose of generating licensing revenues.  Additionally, ObjectVideo states that it has made significant investments in the exploitation of the asserted patents through engineering and research and development in the U.S., including the manufacturing and sale of video analytics systems that practice one or more claims of the ‘945, ‘083, ‘175, ‘912, and ‘923 patents.  According to the complaint, ObjectVideo designs these products at its facilities in Reston, Virginia, and the products are used in numerous video cameras and encoders for the benefit of numerous companies and institutions, including Boston University and The Kroger Co. As to related litigation, ObjectVideo states that on April 6, 2011, it filed a complaint against Bosch, Samsung, and Sony in the U.S. District Court for the Eastern District of Virginia alleging infringement of the ‘945, ‘083, ‘324, and ‘912 patents.  ObjectVideo further states that on May 11, 2011, it filed an amended complaint in the district court adding allegations that Bosch, Samsung, and Sony infringe the ‘175 and ‘923 patents.  With respect to potential remedy, ObjectVideo requests that the Commission issue a permanent exclusion order and permanent cease and desist orders directed at the Proposed Respondents and their successors and assigns.
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Apple Files New 337 Complaint Regarding Certain Electronic Digital Media Devices

By Eric Schweibenz
|
Jul
06
On July 5, 2011, Apple Inc. of Cupertino, California (“Apple”) filed a complaint requesting that the ITC commence an investigation pursuant to Section 337. The complaint alleges that Samsung Electronics Co., Ltd. of Korea, Samsung Electronics America, Inc. of Ridgefield Park, New Jersey, and Samsung Telecommunications America, LLC of Richardson, Texas (collectively, “Samsung”) unlawfully import into the U.S., sell for importation, sell within the U.S. after importation, and/or offer for sale within the U.S. after importation certain electronic digital media devices, including mobile phone handsets and tablet computers, and components thereof, including software, touch-pads, and hardware interfaces that infringe one or more claims of U.S. Patent Nos. 7,479,949 (the ‘949 patent), RE 41,922 (the ‘922 patent), 7,863,533 (the ‘533 patent), 7,789,697 (the ‘697 patent), 7,912,501 (the ‘501 patent), D558,757 (the ‘757 patent), and D618,678 (the ‘678 patent) (collectively, the “asserted patents”). According to the complaint, the asserted patents generally relate to graphical user interfaces, hardware interfaces, and ornamental designs for electronic digital media devices.  In particular, the ‘949 patent relates to a touchscreen-based device that applies heuristics to inputs, or gestures, made on its touchscreen, to determine the command that the gesture corresponds to and the resulting device behavior.  The ‘922 patent relates to the simultaneous presentation of opaque images and translucent images on a display screen.  The ‘533 patent relates to a cantilevered push button on an electronic device.  The ‘697 patent relates to a headphone interface that detects the presence of a headphone or headset plug, and alters certain functions in the device in which the assembly resides.  The ‘501 patent relates to a headphone interface that is configured to accept and operate with a headphone or headset, which contains a microphone, and to detect whether the component inserted into the jack is a headphone or headset.  Lastly, the ‘757 and ‘678 patents relate to specific ornamental design features for an electronic device, such as a communication device. In the complaint, Apple alleges that Samsung imports and sells products that infringe the asserted patents.  The complaint specifically refers to the Samsung Fascinate, Galaxy S 4G, Intercept, Transform, Captivate, and Infuse 4G as infringing mobile phone handsets.  The complaint further refers to the Samsung Galaxy Tab and Galaxy Tab 10.1 as infringing tablet computers. Regarding domestic industry, Apple states that its iPhone 4, iPhone 3GS, iPad, and iPod Touch practice the asserted patents.  As to the economic prong, Apple states that it researched, designed, and developed its products that practice the asserted patents in the U.S. and sells those products and provides customer support within the U.S. through its retail stores and other channels.  Apple further states that it spent more than $2.9 billion on research and development from fiscal year 2010 through the first half of 2011, of which a substantial amount is allocable to its products that practice the asserted patents.  According to the complaint, substantially all of this research and development was conducted within the U.S.  Apple further states that it spent more than $6.8 billion on sales, marketing, and distribution from fiscal year 2010 through the first half of 2011, of which a substantial amount is allocable to its products that practice the asserted patents.  Apple also specifically refers to its headquarters in Cupertino, California, its warehousing and distribution operation and customer support call center in Elk Grove, California, and its data center in Newark, California.  The complaint additionally states that Apple has made substantial investments in exploiting its patent portfolio — including the asserted patents — through its patent licensing activities. As to related litigation, Apple states that the ‘949 patent is currently being litigated against High Tech Computer Corp. and others in the U.S. District Court for the District of Delaware.  According to the complaint, this district court action was filed by Apple on March 2, 2010. With respect to potential remedy, Apple requests that the Commission issue a limited exclusion order and a permanent cease and desist order directed at the named Samsung entities and their affiliates, subsidiaries, successors, and assigns.
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Apple Files New 337 Complaint Regarding Certain Portable Electronic Devices And Related Software

By Eric Schweibenz
|
Jul
11
On July 8, 2011, Apple Inc. of Cupertino, California (“Apple”) filed a complaint requesting that the ITC commence an investigation pursuant to Section 337. The complaint alleges that HTC Corp. of Taiwan and HTC America, Inc. of Bellevue, Washington (collectively, “HTC”), and Exedea, Inc. of Houston, Texas (“Exedea”) (all collectively, the “Proposed Respondents”) unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain portable electronic devices and related software that infringe certain claims of U.S. Patent Nos. 7,844,915 (the ‘915 patent), 7,469,381 (the ‘381 patent), 7,084,859 (the ‘859 patent), 7,920,129 (the ‘129 patent) and 6,956,564 (the ‘564 patent) (collectively, the “asserted patents”). According to the complaint, the asserted patents generally relate to hardware and software used in a variety of portable electronic devices.  In particular, the ‘915 patent relates to user interface software interacting with a software application to enable the recognition and processing of gestures on a multitouch display.  The ‘381 patent relates to a scrolling method for a touch screen display that allows a user to scroll to and past the end of a displayed document in a natural and intuitive manner by using a “bounce-back” or “rubber band” effect when the edge of a document is reached.  The ‘859 patent relates to a number of gestures that a user can use on multitouch sensitive display screens to control the contents of the screen or data presented on the screen or otherwise represented in the computer system.  The ‘129 patent relates to designs for capacitive touch-sensitive panels.  Lastly, the ‘564 patent relates to the implementation and use of accelerometers and movement sensors in portable electronic devices, including handheld computing devices, to improve viewing orientation. In the complaint, Apple alleges that the Proposed Respondents import and sell products that infringe the asserted patents.  The complaint specifically refers to various HTC smartphones and tablet computers that include or contain software based on the Android operating system as infringing products. Regarding domestic industry, Apple states that it makes extensive use of the inventions claimed in the asserted patents in numerous products, including its iPhone, iPad, and iPod touch products.  According to the complaint, the iPhone, iPad, and iPod touch are developed in the U.S., manufactured abroad, and sold within the U.S.  Apple states that it has made significant investment in plant and equipment in the U.S. with respect to Apple products that practice the asserted patents.  Apple specifically refers to its headquarters in Cupertino, California, its land in Cupertino, California intended for the future development of its second corporate campus, its data center in Newark, California, and its land in North Carolina intended for a new data center facility that is currently under construction.  According to the complaint, substantially all of the research, development, design, engineering, and testing of the Apple products that practice the asserted patents was completed by Apple employees working in the U.S.  Additionally, Apple states that as of September 25, 2010, it had opened a total of 317 retail stores, including 233 stores in the U.S. As to related litigation, Apple states that on March 2, 2010, it filed a complaint against HTC, HTC (BVI) Corp., and Exedea in the U.S. District Court for the District of Delaware alleging infringement of the ‘381 patent.  Apple further states that on April 15, 2011, it filed suit against Samsung Electronics Co., Ltd. and related entities in the U.S. District Court for the Northern District of California, alleging infringement of the ‘381 and ‘915 patents.  Apple states that both of these district court cases are currently pending.  Apple additionally states that, concurrently with the filing of the instant ITC complaint, it will file a civil action in the U.S. District Court for the District of Delaware accusing the Proposed Respondents of infringing the ‘915, ‘859, ‘129, and ‘564 patents. With respect to potential remedy, Apple requests that the Commission issue a permanent exclusion order and a permanent cease and desist order directed at the Proposed Respondents and others acting on their behalf.
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Intellectual Ventures Files New 337 Complaint Regarding Certain Dynamic Random Access Memory And NAND Flash Memory Devices

By Eric Schweibenz
|
Jul
13
On July 12, 2011, Intellectual Ventures Management, LLC, Invention Investment Fund I, L.P., Invention Investment Fund II, LLC, Intellectual Ventures I LLC, and Intellectual Ventures II LLC (collectively, “Intellectual Ventures”), all of Bellevue, Washington, 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 dynamic random access memory (“DRAM”) and NAND Flash memory devices and products containing such DRAM and/or NAND Flash memory devices that infringe one or more claims of U.S. Patent Nos. 5,654,932 (the ‘932 patent), 5,963,481 (the ‘481 patent), 5,982,696 (the ‘696 patent), 5,500,819 (the ‘819 patent) and 5,687,132 (the ‘132 patent) (collectively, the “asserted patents”):
  • Hynix Semiconductor Inc. of South Korea
  • Hynix Semiconductor America, Inc. of San Jose, California
  • Elpida Memory, Inc. of Japan
  • Elpida Memory (USA) Inc. of Sunnyvale, California
  • Acer Inc. of Taiwan
  • Acer America Corp. of San Jose, California
  • ADATA Technology Co., Ltd. of Taiwan
  • ADATA Technology (U.S.A.) Co., Ltd. of Hacienda Heights, California
  • Asustek Computer Inc. of Taiwan
  • Asus Computer International Inc. of Fremont, California
  • Dell, Inc. of Round Rock, Texas
  • Hewlett-Packard Company of Palo Alto, California
  • Kingston Technology Co., Inc. of Fountain Valley, California
  • Logitech International S.A. of Switzerland
  • Logitech, Inc. of Fremont, California
  • Pantech Co., Ltd. of South Korea
  • Pantech Wireless, Inc. of Atlanta, Georgia
  • Best Buy Co., Inc. of Richfield, Minnesota
  • Wal-Mart Stores, Inc. of Bentonville, Arkansas
According to the complaint, the asserted patents generally relate to DRAM and NAND Flash memory technology.  In particular, the ‘932 patent relates to burst access with on-the-fly bit count variation and accessing groups of columns in a DRAM memory array using different access types during a single row address strobe (RAS) cycle.  The ‘481 patent relates to DRAM bank interleaving and a multi-row memory on a single substrate that accepts an access request to one row before an access request to another row has been completed.  The ‘696 patent relates to a DRAM mode register and a programmable volatile storage in a system with a hardwired address decoder and an external address bus.  The ‘819 patent relates to data moving and copying functionality in connection with NAND Flash memory.  Lastly, the ‘132 patent relates to NAND Flash copy back functionality, which facilitates wear leveling. In the complaint, Intellectual Ventures states that the Proposed Respondents import and sell products that infringe the asserted patents.  The complaint specifically identifies a number of allegedly infringing DRAM and NAND Flash memory devices manufactured and sold by Hynix Semiconductor Inc. and Hynix Semiconductor America, Inc. (collectively, “Hynex”) and Elpida Memory, Inc. and Elpida Memory (USA) Inc. (collectively, “Elpida”).  According to the complaint, the remaining Proposed Respondents import and sell products that contain DRAM and/or NAND Flash memory devices manufactured by Hynix and/or Elpida. Regarding domestic industry, Intellectual Ventures states that it has made substantial investments in the U.S. in the exploitation of the asserted patents, including through licensing, and that this constitutes a domestic industry under 19 U.S.C. § 1337(a)(3)(C).  In particular, Intellectual Ventures states it has engaged in the acquisition of patents, the grouping of patents into desirable packages, research into the relevant product markets, investigation of potential licensees, reverse engineering of potentially infringing products, preparation of technical claim charts, active efforts to negotiate licenses, including preparation for and travel to meetings with potential licensees, and preparation for litigation for the purpose of licensing.  Intellectual Ventures further states that approximately 350 dedicated service providers resident in its U.S. offices are engaged in licensing efforts on a fulltime basis.  Intellectual Ventures also refers to the significant U.S. activities of Micron Technology, Inc. — a licensee of all five of the asserted patents. As to related litigation, Intellectual Ventures states that the asserted patents are the subject of a civil action in the U.S. District Court for the Western District of Washington that was filed by Intellectual Ventures I LLC and Intellectual Ventures II LLC against the Proposed Respondents on July 11, 2011. With respect to potential remedy, Intellectual Ventures requests that the Commission issue a permanent general exclusion order, a permanent limited exclusion order, and a permanent cease and desist order directed at the Proposed Respondents.
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Samsung Files New 337 Complaint Regarding Certain Light-Emitting Diodes

By Eric Schweibenz
|
Jul
18
On July 15, 2011, Samsung LED Co., Ltd. of Korea and Samsung LED America, Inc. of Atlanta, Georgia (“SLA”) (collectively, “Samsung”) filed a complaint requesting that the ITC commence an investigation pursuant to Section 337. The complaint alleges that OSRAM GmbH of Germany, OSRAM Opto Semiconductors GmbH of Germany, OSRAM Opto Semiconductors Inc. of Sunnyvale, California, and OSRAM Sylvania Inc. of Danvers, Massachusetts (collectively, “OSRAM”) unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain light-emitting diodes (“LEDs”) and products containing the same that infringe one or more claims of U.S. Patent Nos. 6,551,848 (the ‘848 patent), 7,268,372 (the ‘372 patent), 7,282,741 (the ‘741 patent), 7,771,081 (the ‘081 patent), 7,893,443 (the ‘443 patent), 7,838,315 (the ‘315 patent), 7,959,312 (the ‘312 patent), and 7,964,881 (the ‘881 patent) (collectively, the “asserted patents”). According to the complaint, the asserted patents generally relate to LED technology.  In particular, the ‘848 patent relates to an improved process for fabricating semiconductor LEDs.  The ‘372 patent relates to an improved vertical “GaN” LED.  The ‘741 patent relates to a vertical LED that has an improved layout.  The ‘081 patent relates to an improved LED package.  The ‘443 patent relates to an improved semiconductor LED, which enhances efficiency based on the properties of the layers within it.  The ‘315 patent relates to an improved method for making vertical LEDs.  The ‘312 patent relates to an improved LED that emits white light.  Lastly, the ‘881 patent relates to an improved semiconductor LED. In the complaint, Samsung alleges that OSRAM imports and sells products that infringe the asserted patents.  The complaint specifically refers to OSRAM’s TOPLED and related products, DRAGON family and related products, OSLON family and related products, CERAMOS and related products, OSLUX and related products, and Sylvania products that contain the OSRAM accused LEDs. Regarding domestic industry, Samsung states that certain of its own LEDs and products practice at least one exemplary claim of each of the asserted patents in the U.S., and/or are expected to practice at least one exemplary claim in the U.S. when development and commercialization are completed.  As to the economic prong, Samsung states that SLA formally began operations in Atlanta, Georgia in 2010 to help prepare for an expected rapid expansion of the U.S. market for energy-efficient “green” LEDs and LED products.  According to the complaint, SLA employs engineers and other personnel in the U.S. that support Samsung’s domestic industry by providing design, development, assembly, engineering and other technical support relating to Samsung’s products that practice the asserted patents.  Samsung also states that it has entered into agreements with U.S. partners for LED-related joint research, development, design, assembly and engineering in the U.S.  As to related litigation, Samsung states that on June 3, 2011, OSRAM GmbH filed an ITC complaint against various Samsung entities alleging infringement of certain LED-related patents.  See our June 6, 2011 post for more details.  The ITC instituted an investigation (Inv. No. 337-TA-785) based on OSRAM GmbH’s complaint on July 6, 2011.  See our July 7, 2011 post for more details.  Samsung further states that, on June 6, 2011, OSRAM GmbH filed a complaint in the U.S. District Court for the District of Delaware against these same Samsung entities alleging infringement of certain LED-related patents.  Lastly, Samsung states that, in addition to the instant ITC complaint, Samsung anticipates filing a complaint in the U.S. District Court for the District of Delaware against OSRAM alleging infringement of the asserted patents. With respect to potential remedy, Samsung requests that the Commission issue a permanent limited exclusion order and a permanent cease and desist order directed at OSRAM and related companies.
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MyKey Files New 337 Complaint Regarding Certain Computer Forensic Devices

By Eric Schweibenz
|
Jul
28
On July 22, 2011, MyKey Technology Inc. of Gaithersburg, Maryland (“MyKey”) 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 computer forensic devices and products containing the same that infringe certain claims of U.S. Patent Nos. 6,813,682 (the ‘682 patent), 7,159,086 (the ‘086 patent) and 7,228,379 (the ‘379 patent) (collectively, the “asserted patents”):
  • Data Protection Solutions by Arco of Hollywood, Florida
  • CRU Acquisitions Group LLC of Vancouver, Washington
  • CRU-DataPort LLC of Vancouver, Washington
  • Digital Intelligence, Inc. of New Berlin, Wisconsin
  • Diskology, Inc. of Chatsworth, California
  • Guidance Software, Inc. of Pasadena, California
  • Guidance Tableau LLC of Pasadena, California
  • Ji2, Inc. of Cypress, California
  • MultiMedia Effects, Inc. of Canada
  • Voom Technologies, Inc. of S. Lakeland, Minnesota
  • YEC Co. Ltd. of Japan
According to the complaint, the asserted patents generally relate to computer forensics and computer security.  In particular, the ‘682 patent relates to mechanisms for controlling user access to storage devices.  The ‘086 patent relates to mechanisms for making exact copies of storage devices.  Lastly, the ‘379 patent relates to mechanisms for removing data from storage devices. In the complaint, MyKey states that the Proposed Respondents import and sell products that infringe the asserted patents.  The complaint specifically identifies a number of allegedly infringing products associated with the various Proposed Respondents. Regarding domestic industry, MyKey states that the technology disclosed and claimed in the ‘682 patent is embodied in MyKey’s NoWrite IDE, NoWrite FPU, NoWrite FlashBlock, and NoWrite RW products; the technology disclosed and claimed in the ‘086 patent is embodied in MyKey’s DriveCopy product; and the technology disclosed and claimed in the ‘379 patent is embodied in MyKey’s DriveCleaner product.  As to the economic prong, MyKey states that it has engaged in significant domestic investment in plant and equipment and significant domestic employment of labor and capital for the manufacturing, design, engineering, research, development, quality control, service, repair, packaging, testing, sales, and marketing of MyKey products that practice the asserted patents.  MyKey also states that it has made a substantial domestic investment in the exploitation, enforcement, and licensing of the asserted patents. As to related litigation, MyKey states that on May 20, 2011, it filed a complaint in the U.S. District Court for the District of Delaware alleging that the Proposed Respondents infringe the asserted patents.  MyKey further states that, also on May 20, 2011, it filed another complaint in the U.S. District Court for the District of Delaware alleging that CPR Tools, Inc., Intelligent Computer Solutions, Inc., and Logicube, Inc. infringe the asserted patents. With respect to potential remedy, MyKey requests that the Commission issue a permanent exclusion order and a permanent cease and desist order directed at the Proposed Respondents.
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InterDigital Files New 337 Complaint Regarding Certain Wireless Devices With 3G Capabilities

By Eric Schweibenz
|
Jul
28
On July 26, 2011, InterDigital Communications, LLC of King of Prussia, Pennsylvania, InterDigital Technology Corp. of Wilmington, Delaware, and IPR Licensing, Inc. of Wilmington, Delaware (collectively “InterDigital”) 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 wireless devices with 3G capabilities and components thereof that infringe certain claims of U.S. Patent Nos. 7,349,540 (the ‘540 patent), 7,502,406 (the ‘406 patent), 7,536,013 (the ‘013 patent), 7,616,970 (the ‘970 patent), 7,706,332 (the ‘332 patent), 7,706,830 (the ‘830 patent), and 7,970,127 (the ‘127 patent) (collectively, the “asserted patents”):
  • Huawei Technologies Co., Ltd. of China
  • FutureWei Technologies, Inc. d/b/a Huawei Technologies (USA) of Plano, Texas
  • Nokia Corp. of Finland
  • Nokia Inc. of White Plains, New York
  • ZTE Corp. of China
  • ZTE (USA) Inc. of Richardson, Texas
According to the complaint, the products and technology at issue concern wireless devices with 3G capabilities, and components thereof, for use in at least 3rd Generation or “3G” cellular systems.  In particular, the ‘540 patent “generally presents an improvement to the manner by which user equipment (e.g., mobile handsets and other devices) are able to accurately receive transmissions.”  The ‘406 patent is generally directed to improved automatic power control for a Code Division Multiple Access (CDMA) system.  The ‘013 and '127 patents “generally present[ ] an improvement to the manner by which user equipment are able to accurately receive transmissions.”  The ‘970 patent “generally concerns a technique for communication between user equipment and one or more wireless networks, e.g., a wireless local area network and a cellular network.”  The ‘332 patent “provides improvements to the way subscriber units and base stations communicate to control the power level of transmissions from the base station to a subscriber unit within a cellular CDMA system, thereby increasing the performance of the system.”  The ‘830 patent “is generally directed to improvements to the way a subscriber unit gains access to a cellular CDMA system.”    In the complaint, InterDigital asserts that the Proposed Respondents import and sell products that infringe the asserted patents.  The complaint specifically identifies a number of allegedly infringing wireless devices with CDMA wireless capabilities associated with the various Proposed Respondents. Regarding domestic industry, InterDigital argues that its activities in the United States that exploit the asserted patents by reason of InterDigital’s substantial investment in licensing of the technology protected by the patents, and including past and present research and development, engineering, and testing of the technology protected by the patents are sufficient to meet the requirement.  Specifically, InterDigital argues that its licensing efforts include the asserted patents and such efforts have been previously considered by the Commission in Investigation Nos. 337-TA-601 and 337-TA-613.  See our July 29, 2009 post for more details.  According to the complaint, in both of these investigations the ALJ found, on summary determination, the existence of a domestic industry based on InterDigital’s patent licensing activities relating to its wireless communications technology.  InterDigital further notes that in each case the Commission determined not to review the Initial Determination granting summary determination, which thus became the Commission’s determination. As to related litigation, InterDigital asserts that concurrently with the filing of its ITC complaint it also filed a complaint in the U.S. District Court for the District of Delaware alleging that the Proposed Respondents infringe the asserted patents.  InterDigital also identifies several proceedings involving one or more patents that are related to one or more of the asserted patents.  With respect to potential remedy, InterDigital requests that the Commission issue a permanent exclusion order and a permanent cease and desist order directed at the Proposed Respondents.
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Rovi Files New 337 Complaint Regarding Certain Products Containing Interactive Program Guide And Parental Controls Technology

By Eric Schweibenz
|
Jul
28
On July 26, 2011, Rovi Corporation, Rovi Guides, Inc., United Video Properties, Inc., and Gemstar Development Corporation (collectively, “Rovi”) — all of Santa Clara, California —filed a complaint requesting that the ITC commence an investigation pursuant to Section 337. The complaint alleges that Sharp Corporation of Japan, Sharp Electronics Corporation of Mahwah, New Jersey, and Sharp Electronics Manufacturing Company of America, Inc. of Mahwah, New Jersey (collectively, “Sharp”) unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain products containing interactive program guide and parental controls technology that infringe certain claims of U.S. Patent Nos. 6,305,016 (the ‘016 patent), 7,493,643 (the ‘643 patent) and RE41,993 (the ‘993 patent) (collectively, the “asserted patents”). According to the complaint, the asserted patents generally relate to interactive program guide and parental controls technology.  In particular, the ‘016 patent relates to a system for displaying program guide data with a perceived transparency over a selected television channel and methods for simultaneously presenting information (or alternatively, a computer generated image using digital data) with a television program, where the information is displayed with a perceived partial transparency.  The ‘643 patent relates to a system and method for providing an interactive television program guide with video-on-demand browsing capabilities.  Lastly, the ‘993 patent relates to a system and method for restricting access to television programs. In the complaint, Rovi states that Sharp imports and sells products that infringe the asserted patents.  The complaint specifically identifies a number of Sharp television models as infringing products. Regarding domestic industry, Rovi states that it has made a substantial investment in the exploitation of the asserted patents in the U.S., including engineering, research and development, and licensing efforts.  According to the complaint, Rovi maintains 10 offices across the U.S. and employs a full-time legal and technical staff in the U.S. to perform market analysis, identify potential licensing activities, and engage in licensing and enforcement activities.  Rovi further states that a domestic industry is also present as a result of Rovi’s significant investment in plant and equipment and substantial employment of labor and capital with respect to articles protected by the asserted patents, particularly its RoxioNow platform.  Additionally, Rovi states that a domestic industry is present because several licensees of the asserted patents practice the inventions claimed in the asserted patents within the U.S. As to related litigation, Rovi states that it previously asserted the ‘016 patent against Toshiba Corporation and related entities both at the ITC (Inv. No. 337-TA-747) and in the U.S. District Court for the District of Delaware.  See our November 23, 2010 post for more details on the 747 investigation.  According to the complaint, Toshiba agreed to take a license to settle these matters.  Rovi additionally states that the European counterpart to the ‘016 patent has been litigated successfully in Europe against Sharp Electronics GmbH, Toshiba Europe GmbH, and TechniSat Digital GmbH.  Rovi also states that the ‘643 patent is the subject of pending litigation against Amazon.com, Inc. and others in the U.S. District Court for the District of Delaware.  Additionally, Rovi states that the ‘016 patent is currently the subject of an ex partereexamination that was initiated on September 16, 2010 by a third party requester. With respect to potential remedy, Rovi requests that the Commission issue a permanent limited exclusion order and a cease and desist order.
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LG Files New 337 Complaint Regarding Certain Light Emitting Diodes

By Eric Schweibenz
|
Jul
29
On July 27, 2011, LG Electronics, Inc. of South Korea and LG Innotek Co., Ltd. of South Korea (collectively “LG”) filed a complaint requesting that the ITC commence an investigation pursuant to Section 337. The complaint alleges that OSRAM Gmbh of Germany, OSRAM Sylvania Inc. of Danvers, Massachusetts, and OSRAM Opto Semiconductors Gmbh of Germany (collectively, the “Proposed Respondents”) unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain light emitting diodes and products containing same that infringe certain claims of U.S. Patent Nos. 7,928,465 (the ‘465 patent), 7,956,364 (the ‘364 patent), 6,841,802 (the ‘802 patent), 7,649,210 (the ‘210 patent), 7,884,388 (the ‘388 patent), 7,821,024 (the ‘024 patent), 7,868,348 (the ‘348 patent), and 7,768,025 (the ‘025 patent) (collectively, the “asserted patents”). According to the complaint, the products and technology at issue concern semiconductor light emitting devices, including LEDs, which convert electrical current to light.  In particular, the ‘465 and ‘364 patents generally concern light emitting devices having a vertical structure.  The ‘802 and ‘210 patents generally concern a light emitting device that converts light emitted by an LED chip to light having a different wavelength.  The ‘388 patent provides an improved gallium nitride (GaN) semiconductor device.  The ‘024 patent generally concerns a semiconductor light-emitting device having a roughness layer on a surface of the semiconductor structure.  The ‘348 patent generally concerns vertical semiconductor light-emitting devices having improved light emission efficiency and light escape efficiency and a method for making them.  The ‘025 patent generally concerns vertical semiconductor light emitting devices and an improved method of making such devices. In the complaint, LG asserts that the Proposed Respondents import and sell products that infringe the asserted patents.  The complaint specifically identifies a number of allegedly infringing light-emitting devices associated with the Proposed Respondents. Regarding the technical prong of the domestic industry requirement, LG asserts that it sells in the United States certain LCD televisions and monitors that include LEDs that practice at least one claim of certain of the asserted patents.  With respect to the economic prong of the domestic industry requirement, LG states that it has made and continues to make significant investments in plant facilities and equipment within the U.S. in connection with the service and engineering of products covered by the asserted patents.  LG specifically refers to its facilities in Huntsville, Alabama and Rancho Cucamonga, California as facilities that are involved with products covered by the asserted patents.  As to related litigation, LG asserts that concurrently with the filing of its ITC complaint it also filed a complaint in the U.S. District Court for the District of Delaware alleging that OSRAM infringes the asserted patents.  LG also identifies two ongoing ITC investigations  (Inv. Nos. 337-TA-784 and 337-TA-785) and a U.S. district court case in the Northern District of California involving OSRAM and LG.  With respect to potential remedy, LG requests that the Commission issue a permanent exclusion order and a permanent cease and desist order directed at the Proposed Respondents.
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Litepanels Files New 337 Complaint Regarding Certain LED Photographic Lighting Devices

By Eric Schweibenz
|
Aug
08
On August 3, 2011, Litepanels, Inc. of Van Nuys, California and Litepanels, Ltd. of the United Kingdom (collectively, “Litepanels”) 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 LED photographic lighting devices, components thereof, and products containing same that infringe certain claims of U.S. Patent Nos. 7,972,022 (the ‘022 patent), 7,510,290 (the ‘290 patent), 7,429,117 (the ‘117 patent), 7,318,652 (the ‘652 patent), and 6,948,823 (the ‘823 patent) (collectively, the “asserted patents”):
  • FloLight, LLC of Campbell, California
  • Prompter People, Inc. of Campbell, California
  • Ikan Corporation of Houston, Texas
  • Advanced Business Computer Services, LLC of Reno, Nevada
  • Elation Lighting, Inc. of Los Angeles, California
  • Fotodiox Inc. of Waukegan, Illinois
  • Fuzhou F&V Photographic Equipment Co., Ltd. of China
  • Yuyao Lishuai Photo-Facility Co., Ltd. of China
  • Yuyao Fotodiox Photo Equipment Co., Ltd. of China
  • Shantou Nanguang Photographic Equipment Co., Ltd. of China
  • Visio Light, Inc. of Taiwan
  • Tianjin Wuqing Huanyu Film and TV Equipment Factory of China
  • Stellar Lighting Systems of Los Angeles, California
  • Yuyao Lily Collection Co., Ltd. of China
According to the complaint, the asserted patents generally relate to advanced camera-mountable and standalone lighting systems for use in television, broadcast news, and motion picture productions.  In particular, the ‘823 patent discloses a system that may include a portable frame that tracks camera movement, a mechanism for attachment to a yoke, a plurality of detachable panel members having a plurality of semiconductor light elements, an integrated lens for adjusting the focus of the light emitted, and a color gel that may be securely attached to the frame.  The ‘290, ‘117, ‘652, and ‘022 patents claim priority to the ‘823 patent and similarly disclose an advanced camera mountable lighting system that is directed towards use in television, broadcast news, and motion picture productions.  The ‘022 patent’s claims are specifically directed toward a photographic lighting device that can emit light in a plurality of color-temperatures. In the complaint, Litepanels states that the Proposed Respondents import and sell products that infringe the asserted patents.  The complaint specifically identifies a number of allegedly infringing products associated with the various Proposed Respondents. Regarding domestic industry, Litepanels states that certain of its LED-based lighting systems —including its 1x1 series devices and its Micro series devices — practice the claims of the asserted patents.  As to the economic prong, Litepanels states that it has made significant investments in plant and equipment, engaged in significant employment of labor and capital, and devoted substantial resources in the U.S. to developing, manufacturing, and testing devices that practice one or more claims of the asserted patents.  The complaint specifically refers to Litepanels’ facilities in Van Nuys, California where Litepanels conducts all of its research, development and manufacturing activities in the U.S.  As to related litigation, Litepanels states that it is asserting the ‘823, ‘290 and ‘117 patents in a co-pending action in the U.S. District Court for the Eastern District of Texas against various entities, including Proposed Respondents FloLight, LLC and Prompter People, Inc.  With respect to potential remedy, Litepanels requests that the Commission issue a permanent general exclusion order.  In particular, Litepanels states that there is a pattern of violation of Section 337, it is difficult to identify the sources of infringing products, and a general exclusion order is necessary to prevent circumvention of an exclusion order limited to products of the Proposed Respondents.
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ITRI Files New 337 Complaint Regarding Certain Devices For Improving Uniformity Used In A Backlight Module

By Eric Schweibenz
|
Aug
11
On August 10, 2011, Industrial Technology Research Institute of Taiwan and ITRI International Inc. of San Jose, California (collectively, “ITRI”) filed a complaint requesting that the ITC commence an investigation pursuant to Section 337. The complaint alleges that LG Corporation of South Korea, LG Electronics, Inc. of South Korea, and LG Electronics, U.S.A., Inc. of Englewood Cliffs, New Jersey (collectively, “LG”) unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain devices for improving uniformity used in a backlight module and products containing same, including display devices, such as digital televisions and monitors and components thereof that infringe one or more claims of U.S. Patent No. 6,883,932 (the ‘932 patent). According to the complaint, the ‘932 patent generally relates to an apparatus for improving the uniformity of light in a backlight module.  The complaint explains that it is important that the backlights used for liquid crystal displays (“LCDs”) produce light uniformly across the LCD display region so that images may be rendered using the correct amount of brightness.  According to the complaint, the ‘932 patent describes a housing for the light sources which reflects the light from the backlights’ light sources.  Further, the ‘932 patent describes structured arc sheets which improve the uniformity of light displayed on an LCD monitor or display. In the complaint, ITRI states that LG imports and sells products that infringe the ‘932 patent.  The complaint specifically names the LG “LW,” “LV,” “LH,” “LX,” “LE,” and “LD” families of displays as infringing products. Regarding domestic industry, ITRI states that its licensee Samsung Electronics Co., Ltd. and related entities (collectively, “Samsung”) practice the ‘932 patent in the U.S.  According to the complaint, Samsung conducts significant activities relating to products that practice the ‘932 patent in the U.S., including providing domestic support for LCD displays, LCD monitors and LCD televisions.  ITRI states that the Commission has previously found that Samsung’s significant U.S. investments in customer support constitute a significant employment of labor and capital, citing an Initial Determination in Inv. No. 337-TA-631.  ITRI also cites to Samsung’s June 1, 2011 verified complaint in Inv. No. 337-TA-782 (see our June 2, 2011 post for more details) as providing additional support for its domestic industry allegations. As to related litigation, ITRI states that on November 26, 2010, it asserted the ‘932 patent  and 14 other patents related to displays against LG in the U.S. District Court for the Eastern District of Texas.  According to the complaint, that district court case is still pending.  Additionally, ITRI states that on October 19, 2009, it asserted the ‘932 patent and 14 other patents related to displays against Samsung in the U.S. District Court for the Western District of Arkansas.  According to the complaint, that case was settled pursuant to an agreement between the parties with an effective date of May 1, 2010. With respect to potential remedy, ITRI requests that the Commission issue a limited exclusion order and a permanent cease and desist order directed at LG and related companies.
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