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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

CADDO SYSTEMS, INC. and 511 

TECHNOLOGIES, INC.,

Plaintiffs,

v.

MICROCHIP TECHNOLOGY 

INCORPORATED,

Defendant.

Civil Action No. 6:20-cv-245

DEMAND FOR JURY TRIAL

COMPLAINT FOR PATENT INFRINGEMENT

In this action for patent infringement Plaintiffs Caddo Systems, Inc. and 511 

Technologies, Inc.(“Plaintiffs”) hereby make the following allegations against Defendant

Microchip Technology Incorporated (“Defendant” or “Microchip”):

NATURE OF THE ACTION

1. This is an action for patent infringement arising under the Patent Laws of the 

United States, 35 U.S.C. § 1 et seq.

THE PARTIES

2. Plaintiff Caddo Systems, Inc. (“Caddo”) is a Texas corporation with its principal 

place of business in the 511 Technology Center at 511 N. Washington Avenue, Marshall, Texas 

75670. 

3. Plaintiff 511 Technologies, Inc. (“511 Tech”) is a Texas corporation with its 

principal place of business at 511 N. Washington Avenue, Marshall, Texas 75670. Since 2010, 

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511 Tech has operated the 511 Technology Center, including the provision of invention, patent 

and product development support services in diverse fields including color measurement, flash 

storage devices, communication protocols, electronic circuitry, software development, energy 

storage and control, cloud-connected industrial and consumer products, medical diagnostic 

device, and art instruction from its headquarters in the former Coca-Cola bottling plant located in 

the Ginocchi Historic District in Marshall, Texas. 

4. In collaboration with 511 Tech and others working in the 511 Technology Center, 

Caddo researches, designs, and develops information systems, including systems based on the 

Asserted Patents. The Caddo and 511 Tech collaboration includes software products based on 

inventions described and claimed in the Asserted Patents. 

5. Caddo is the owner by assignment of 100% interest in the Asserted Patents. 511 

Tech has the exclusive license to practice and develop the inventions of the Asserted Patents.

6. On information and belief, Defendant Microchip is a Delaware corporation with 

its principal place of business located at 8601 Ranch Road 2222, Park Centre, Bldg. 3, Austin, 

Texas 78730. Upon information and belief, Microchip is authorized to do business in Texas and 

may be served through its registered agent CT Corporation System, 1999 Bryan Street, Suite 

900, Dallas, Texas 75201. 

JURISDICTION AND VENUE

7. This action for patent infringement arises under the patent laws of the United 

States, Title 35 of the United States Code.

8. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).

9. This Court has personal jurisdiction over Microchip because it has sufficient 

minimum contacts with this forum as a result of business conducted within the State of Texas 

and within the Eastern District of Texas. For example, Microchip has a place of business in this 

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District at 8601 Ranch Road 2222, Park Centre, Bldg. 3, Austin, Texas 78730. Personal 

jurisdiction also exists specifically over Microchip because Microchip, directly or through 

subsidiaries or intermediaries, makes, uses, offers for sale, or sells products or services within the 

State of Texas and within the Western District of Texas through accused instrumentalities that 

directly or indirectly infringe the Asserted Patents (as discussed further below).

10. On information and belief, Defendant Microchip designs, develops, manufactures, 

sells, offers to sell, and/or imports products, devices, systems, and/or components of systems 

through certain accused instrumentalities that either infringe or support the infringement of the 

patents asserted in this action.

11. On information and belief, Microchip sells and offers to sell products and services 

throughout the United States and in Texas, including in this District, through the accused 

instrumentalities, through major electronics retailers in the United States, and in concert and 

partnership with third parties.

12. Furthermore, personal jurisdiction over Microchip in this action comports with 

due process. Microchip has conducted and regularly conducts business within the United States 

and this District. Microchip has purposefully availed itself of the privileges of conducting 

business in the United States, and more specifically in the State of Texas and this District. 

Microchip has sought protection and benefit from the laws of the State of Texas by making 

available products and services, including websites and associated web pages, that infringe the 

Asserted Patents with the awareness and/or intent that they will be used (or visited) by 

consumers in this District. Having purposefully availed itself of the privilege of conducting 

business within this District, Microchip should reasonably and fairly anticipate being brought 

into court here.

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13. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391 and 1400(b) at least 

because Microchip is subject to personal jurisdiction in this District and has regularly conducted 

business in this District, and because certain of the acts complained of herein occurred in this 

District. On information and belief, Microchip makes, uses, sells, offers to sell, and/or imports, 

within the state of Texas and in this District, products and services through the accused 

instrumentalities that infringe the Asserted Patents. 

14. Additionally, Microchip—directly or through intermediaries (including 

distributors, retailers, and others), subsidiaries, alter egos, and/or agents—ships, distributes, 

offers for sale, and/or sells its products and services in the United States and this District. 

Microchip has purposefully and voluntarily placed one or more of its products into the stream of 

commerce through the accused instrumentalities that infringe the Asserted Patents with the 

awareness and/or intent that they will be purchased by consumers in this District. Microchip 

knowingly and purposefully ships infringing products into, and within, this District. These 

infringing products have been, and continue to be, purchased by consumers and businesses in 

this District.

THE ASSERTED PATENTS

15. On March 13, 2007, the United States Patent and Trademark Office (“USPTO”)

duly and legally issued U.S. Patent No. 7,191,411 (“the ’411 Patent”), entitled “Active Path 

Menu Navigation System.” A copy of the ’411 Patent is attached hereto as Exhibit 1.

16. Plaintiffs own all substantial right, title, and interest in the ’411 Patent, and hold 

the right to sue and recover damages for infringement thereof, including past infringement.

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17. On May 8, 2007, the USPTO duly and legally issued U.S. Patent No. 7,216,301

(“the ’301 Patent”), entitled “Active Path Menu Navigation System.” A copy of the ’301 Patent 

is attached hereto as Exhibit 2.

18. Plaintiffs own all substantial right, title, and interest in the ’301 Patent, and hold 

the right to sue and recover damages for infringement thereof, including past infringement.

19. On December 29, 2009, the USPTO duly and legally issued U.S. Patent No. 

7,640,517 (“the ’517 Patent”), entitled “Active Path Menu Navigation System.” A copy of the 

’517 Patent is attached hereto as Exhibit 3.

20. Plaintiffs own all substantial right, title, and interest in the ’517 Patent, and hold 

the right to sue and recover damages for infringement thereof, including past infringement.

21. On May 25, 2010, the USPTO duly and legally issued U.S. Patent No. 7,725,836 

(“the ’836 Patent”), entitled “Active Path Menu Navigation System.” A copy of the ’836 Patent 

is attached hereto as Exhibit 4.

22. Plaintiffs own all substantial right, title, and interest in the ’836 Patent, and hold 

the right to sue and recover damages for infringement thereof, including past infringement.

23. On January 8, 2013, the USPTO duly and legally issued U.S. Patent No. 

8,352,880 (“the ’880 Patent”), entitled “Active Path Menu Navigation System.” A copy of the 

’880 Patent is attached hereto as Exhibit 5.

24. Plaintiffs own all substantial right, title, and interest in the ’880 Patent, and hold 

the right to sue and recover damages for infringement thereof, including past infringement.

25. On July 31, 2018, the USPTO duly and legally issued U.S. Patent No. 10,037,127 

(“the ’127 Patent”), entitled “Active Path Menu Navigation System.” A copy of the ’127 Patent 

is attached hereto as Exhibit 6.

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COUNT I - INFRINGEMENT OF U.S. PATENT NO. 7,191,411

26. Plaintiffs incorporate and reallege the preceding paragraphs as if fully set forth 

herein.

27. The ’411 Patent is directed to systems and methods for navigating within a multilevel hierarchical collapsing menu structure, as described and claimed in the ’411 Patent. 

28. Defendant has and continues to directly infringe at least Claims 1-4 and 6 of the 

’411 Patent, in this judicial District and elsewhere in the United States, pursuant to 35 U.S.C. § 

271(a), literally or under the doctrine of equivalents, by, among other things, by making, using, 

selling, offering to sell, and/or importing in or into the United States, without authority: (i) web 

pages and content to be interactively presented in browsers, including, without limitation, the 

web pages and content accessible via https://www.microchip.com/ and maintained on servers 

located in and/or accessible from the United States under the control of Defendant; (ii) software, 

including, without limitation, software that allows content to be interactively presented in and/or 

served to browsers; (iii) computer equipment including, without limitation, computer equipment 

that stores, serves, and/or runs any of the foregoing or that allows navigating within a multi-level 

hierarchical collapsing menu structure, where each level in the menu structure contains plural 

items, each item being at least one of a function, a pointer to a location, and a pointer to another 

level (hereinafter, the “’411 Accused Instrumentalities”) as shown below:

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See, e.g., https://www.microchip.com/design-centers/automotive-solutions/automotiveapplications (last visited Feb. 10, 2020) (annotated). 

29. By way of example, the ’411 Accused Instrumentalities provide a method for 

navigating within a multi-level hierarchical collapsing menu structure where each level in the 

menu contains plural items, each said item being at least one of a function, a pointer to a 

location, and a pointer to another level (e.g., the ’411 Accused Instrumentalities provide a 

method for navigating a multi-level hierarchical collapsing menu structure that includes a multilevel hierarchy where each level in the menu contains plural items, each said item being at least 

one of a function, a pointer to a location, and a pointer to another level (e.g., “Products” includes 

“Amplifiers and Linear,” which includes “Operational Amplifiers,” “Instrumentation 

Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and 

“DC Power Current Monitors”)) as shown below:

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See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

30. More specifically, the ’411 Accused Instrumentalities provide a graphical user 

menu system displaying the items of a given level and enabling selection thereof (e.g., 

“Products” displays and enables selection of items of a given level, such as “Amplifiers and 

Linear” and items within that same level), wherein access of said given level requires sequential 

access of each of the levels preceding said given level in the hierarchy (e.g., to access 

“Amplifiers and Linear,” “Products” is accessed first; similarly, to access “Comparators,” 

“Products” is accessed first, followed by accessing “Amplifiers and Linear”); automatically 

constructing an Active Path as a sequence of hierarchical active links as items are selected using 

the graphical user menu system without the need for any additional interaction with the graphical 

user system (e.g., the ’411 Accused Instrumentalities automatically construct an active path (e.g., 

“Amplifiers and Linear—Comparators”) as a sequence of hierarchical active links as items are 

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selected (e.g., as “Amplifiers and Linear” and “Comparators” are selected)), with one said active 

link corresponding to each of the items selected (e.g., the ’411 Accused Instrumentalities’ active 

path “Amplifiers and Linear—Comparators” corresponds to each of the items selected, including 

“Amplifiers and Linear” and “Comparators”) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

31. Also, each active link in the ’411 Accused Instrumentalities is independently 

selectable thereby providing direct access to the hierarchical level from which the corresponding 

item was selected without the need to navigate using said graphical user menu system (e.g., in 

the example above, the active link “Amplifiers and Linear” is independently selectable to thereby 

providing direct access to the hierarchical level from which “Amplifiers and Linear” was 

selected without the need to navigate using Microchip’s graphical user menu system; as another 

example, the active link “Comparators” is independently selectable to thereby providing direct 

access to the hierarchical level from which “Comparators” was selected without the need to 

navigate using Microchip’s graphical user menu system).

32. The ’411 Accused Instrumentalities’ active path is displayed as an alternative to 

the graphical user menu system for navigating the multi-level hierarchical collapsing menu 

structure after the user has finished selecting items using the graphical user system (e.g., the ’411 

Accused Instrumentalities display the Active Path as an alternative to Defendant’s graphical user 

menu system for navigating the multi-level hierarchical collapsing menu structure after the user 

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has finished selecting items, such as “Amplifiers and Linear” and “Comparators” using 

Microchip’s graphical user menu system such that Microchip’s Active Path is displayed after the 

multi-level hierarchical collapsing menu structure has collapsed) such that the Active Path is 

displayed after the multi-level hierarchical collapsing menu structure has collapsed (e.g., the 

Active Path is displayed after the multi-level hierarchical collapsing menu structure showing 

“Products” has collapsed) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

33. On information and belief, in the ’411 Accused Instrumentalities, pre-selecting a 

given active link triggers the display of sibling menu items on the level associated with said 

given active link without disturbing the displayed Active Path (e.g., pre-selecting the “Amplifiers 

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and Linear” active link triggers the display of sibling menu items, such as “Operational 

Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” “Comparators,” 

“Programmable Gain Amplifiers,” and “DC Power Current Monitors” without disturbing the 

displayed Active Path).

34. On information and belief, the ’411 Accused Instrumentalities provide predefined short-cuts enabling direct access to a given menu item (e.g., the ’411 Accused 

Instrumentalities provide pre-defined shortcuts, such as “Amplifiers and Linear” or 

“Comparators” in the collapsing menu enabling direct access to a given menu item); and 

automatically constructing the Active Path when a pre-defined short-cut is executed, with one 

said active link corresponding to each of the menu items necessary to access said given menu 

item using said graphical user menu system (e.g., the active path is automatically constructed 

when “Amplifiers and Linear” or “Comparators” is executed, with each active link “Amplifiers 

and Linear” or “Comparators” corresponding to each of the menu items necessary to access the 

given menu item using the graphical user menu system). 

35. On information and belief, in the ’411 Accused Instrumentalities, selecting a 

given active link triggers the execution of a function associated with said given active link (e.g., 

selecting a given active link such as “Amplifiers and Linear” triggers the execution of a function, 

such as displaying sibling menus (e.g., “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors”) or directing user to certain content). 

36. On information and belief, in the ’411 Accused Instrumentalities, selecting a 

given active link triggers display of information associated with said given active link (e.g., the 

’411 Accused Instrumentalities allow selecting the link “Amplifiers and Linear” to trigger 

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display of information (e.g., displaying “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors”) associated with the link “Amplifiers and Linear”). 

37. On information and belief, in the ’411 Accused Instrumentalities, pre-selecting a 

given menu item displayed while pre-selecting the given active link triggers the display of 

subordinate menu items (e.g., pre-selecting “Automotive Products” displayed while pre-selecting 

“Automotive Solution” triggers the display of subordinate menu items, such as 

“Microcontrollers,” “Analog Products,” “Connectivity,” “Automotive Touch,” “Car Access,” 

“memory Products,” “High Temperature Products,” “Timing Solutions,” and “Automotive 

Security”) as shown below:

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See, e.g., https://www.microchip.com/design-centers/automotive-solutions (last visited Feb. 10, 

2020). 

38. Discovery is expected to uncover the full extent of Defendant’s infringement of 

the ’411 Patent beyond the ’411 Accused Instrumentalities already identified through public 

information. 

39. Upon information and belief, Defendant has induced and continues to induce 

others to infringe at least Claims 1-4 and 6 of the ’411 Patent under 35 U.S.C. § 271(b) by, 

among other things, and with specific intent or willful blindness, actively aiding and abetting 

others to infringe, including but not limited to Defendant’s new, current, and prospective users, 

partners, customers and other third parties, whose use of the ’411 Accused Instrumentalities 

constitutes direct infringement of at least Claims 1-4 and 6 of the ’411 Patent. 

40. In particular, Defendant’s actions that aid and abet others such as its new, current, 

and prospective users, partners, customers and third parties to infringe include advertising the 

’411 Accused Instrumentalities. On information and belief, Defendant has engaged in such 

actions with specific intent to cause infringement or with willful blindness to the resulting 

infringement because Defendant has had actual knowledge of the ’411 Patent and knowledge 

that its acts were inducing infringement of the ’411 Patent since at least the date Defendant 

received notice based on the filing of this Complaint that such activities infringed the ’411 

Patent. 

41. Defendant’s acts of inducement include, without limitation: providing the ’411 

Accused Instrumentalities to its new, current, and prospective users, partners, and customers, and 

other third parties and intending them to use the ’411 Accused Instrumentalities that enable

and/or make use of content published therein; encouraging customers and other third parties to 

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communicate directly with Defendant’s representatives about the ’411 Accused Instrumentalities 

and content published therein for purposes of technical assistance as well as sales and marketing 

(see, e.g., https://microchipsupport.force.com/s/ (providing consumers with a technical support 

portal through which technical issues and concerns regarding the ’411 Accused Instrumentalities 

can be addressed); see, e.g., https://microchipsupport.force.com/s/supportresources?tabName=Contact (providing contact information for technical support regarding the 

’411 Accused Instrumentalities); see also id. (providing a community platform for discussing the 

’411 Accused Instrumentalities or content published therein); see also 

https://www.facebook.com/microchiptechnology/ (encouraging customers and other third parties 

to use the ’411 Accused Instrumentalities to access content published therein (e.g., providing an 

URL (https://page.microchip.com/ewTiming.html?utm_campaign=EmbeddedWorld2020&utm_source=facebook.com&utm_medium

=Post&utm_content=SharePoint43895.5417&fbclid=IwAR2TVwazReb1Ul3TgRAgkutaZY3eE_ikA0HfXVGI6vjYdziBuNwa5BtxOo) to a “Timing and System Solutions” webpage 

that can be accessed using the ’411 Accused Instrumentalities)); see also 

https://www.microchip.com/about-us/company-information/acquisitions (recommending 

investors and other third parties use the ’411 Accused Instrumentalities to access financial 

information relating to Microchip’s cooperate operations and acquisitions); see also 

https://www.microchip.com/documentlisting/financial-press-releases (for example, 

https://www.microchip.com/investor/Pressrelease/MCHP%20Announces%20Financial%20Resul

ts%20for%20Q3FY20.020420.pdf providing an URL (www.microchip.com) to the ’411 

Accused Instrumentalities); see also

https://twitter.com/MicrochipTech?ref_src=twsrc%5Egoogle%7Ctwcamp%5Eserp%7Ctwgr%5E

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author, https://www.facebook.com/microchiptechnology/ and 

https://www.linkedin.com/posts/microchip-technology_from-simple-buffers-and-clockgenerators-activity-6641422443871383552-bbea (Defendant’s social media accounts promoting 

the use of ’411 Accused Instrumentalities through which various media content can be accessed); 

providing press releases encouraging customers and other third parties to use the ’411 Accused 

Instrumentalities to access content (for example, providing an URL (www.microchip.com) to the 

“Microchip” main webpage that can be accessed using the ’411 Accused Instrumentalities); and 

https://www.microchip.com/blog (providing blogs encouraging customers and other third parties 

to use the ’411 Accused Instrumentalities to access content (for example, providing an URL 

(https://www.microchip.com/wwwproducts/en/MCP6C02) to a “MCP6C02” webpage that can 

be accessed using the ’411 Accused Instrumentalities))).

42. Defendant performed acts of inducement despite its actual knowledge since at 

least the filing date of this Complaint and its knowledge that the specific actions it actively 

induced and continues to actively induce on the part of its users, partners, and customers, and 

other third parties constitute infringement of the ’411 Patent. At the very least, because 

Defendant has been, and remains, on notice of the ’411 Patent and the accused infringement, it 

has been, and remains, willfully blind regarding the infringement that it has induced and 

continues to induce.

43. On information and belief, Defendant has contributed to, and continues to 

contribute to, infringement of at least Claims 1-4 and 6 of the ’411 Patent pursuant to 35 U.S.C. 

§ 271(c) by providing the ’411 Accused Instrumentalities that have contributed, and continue to 

contribute, to the direct infringement of new, current, and prospective users, partners, customers 

and other third parties with the knowledge (at least as of the filing date of this Complaint) that 

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the ’411 Accused Instrumentalities are especially made or adapted for use in an infringement of 

the ’411 Patent. For example, by providing the web pages, software, and computer equipment 

identified above, Defendant contributes to the direct infringement of users of said web pages, 

software, and computer equipment. The ’411 Accused Instrumentalities are material 

components or apparatuses for use in practicing the ’411 Patent and are not staple articles of 

commerce suitable for substantial non-infringing use.

44. For example, the ’411 Accused Instrumentalities provide a graphical user menu 

system through which a user can navigate within a multi-level hierarchical collapsing system 

according to the claimed invention(s). Defendant supplied, and continues to supply, the ’411 

Accused Instrumentalities, or components or apparatuses thereof, with the knowledge of the ’411 

Patent and with the knowledge that these components or apparatuses constitute critical and 

material parts of the claimed inventions of the ’411 Patent. Moreover, Defendant knows at least 

by virtue of its knowledge of its own products and services and the ’411 Patent that the ’411 

Accused Instrumentalities are especially made and/or especially adapted for use as claimed in the 

’411 Patent and there is no substantial non-infringing use of these components or apparatuses.

45. Defendant has directly and indirectly infringed the ’411 Patent and is thus liable 

for infringement of the ’411 Patent pursuant to 35 U.S.C. § 271.

46. Plaintiffs have suffered, and continue to suffer, damages as a result of 

Defendant’s infringement of the ’411 Patent. 

47. Defendant has continued to infringe the ’411 Patent since at least the filing date of 

this Complaint, despite being on notice of the ’411 Patent and its infringement. Defendant has 

therefore infringed the ’411 Patent knowingly, willfully, deliberately, and in disregard of 

Plaintiffs’ patent rights since at least the filing date of this Complaint, at least by infringing with 

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actual knowledge of its direct and indirect infringement or while remaining willfully blind to the 

fact of its direct and indirect infringement. As a result of at least this conduct, Plaintiffs are 

entitled to enhanced damages under 35 U.S.C. § 284 and to attorneys’ fees and costs under 35 

U.S.C. § 285.

48. Plaintiffs reserve the right to modify its infringement theories as discovery 

progresses in this case. Plaintiffs shall not be estopped for purposes of its infringement 

contentions or its claim constructions by the foregoing discussions on how the ’411 Accused 

Instrumentalities infringe the ’411 Patent. Plaintiffs intend only that the foregoing discussions 

satisfy the notice requirements of Rule 8(a)(2) of the Federal Rule of Civil Procedure, and that 

they should not be construed as Plaintiffs’ preliminary or final infringement contentions or 

preliminary or final claim construction positions.

COUNT II - INFRINGEMENT OF U.S. PATENT NO. 7,216,301

49. Plaintiffs incorporate and reallege the preceding paragraphs as if fully set forth 

herein.

50. The ’301 Patent is directed to systems and methods for navigating within a multilevel hierarchical information structure, as described and claimed in the ’301 Patent. 

51. Defendant has and continues to directly infringe at least Claims 1-5 and 9 of the 

’301 Patent, in this judicial District and elsewhere in the United States, pursuant to 35 U.S.C. § 

271(a), literally or under the doctrine of equivalents, by, among other things, by making, using, 

selling, offering to sell, and/or importing in or into the United States, without authority: (i) web 

pages and content to be interactively presented in browsers, including, without limitation, the 

web pages and content accessible via https://www.microchip.com/ and maintained on servers 

located in and/or accessible from the United States under the control of Defendant; (ii) software, 

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including, without limitation, software that allows content to be interactively presented in and/or 

served to browsers; (iii) computer equipment, including, without limitation, computer equipment 

that stores, serves, and/or runs any of the foregoing or that allows navigating within a multi-level 

hierarchical information structure, where each level in the information structure contains plural 

items, each item being at least one of a function, a pointer to a location, and a pointer to another 

level (hereinafter, the “’301 Accused Instrumentalities”) as shown below:

See, e.g., https://www.microchip.com/design-centers/automotive-solutions/automotiveapplications (last visited Feb. 10, 2020) (annotated). 

52. By way of example, the ’301 Accused Instrumentalities provide a method for 

navigating within a multi-level hierarchical information structure where each level in the 

information structure contains plural items, each said item being at least one of a function, a 

pointer to a location, and a pointer to another level (e.g., the ’301 Accused Instrumentalities 

provide a method for navigating within a multi-level hierarchical collapsing menu structure 

where each level in the information structure contains plural items, each said item being at least 

one of a function, a pointer to a location, and a pointer to another level (e.g., “Products” includes 

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“Amplifiers and Linear,” which includes “Operational Amplifiers,” “Instrumentation 

Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and 

“DC Power Current Monitors”)) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

53. More specifically, the ’301 Accused Instrumentalities provide a graphical user 

menu system displaying the items of a given level of the hierarchical information structure and 

enabling selection thereof (e.g., “Products” displays and enables selection of items of a given 

level, such as “Amplifiers and Linear” and items within that same level); and dynamically 

constructing an Active Path as a sequence of active links as items are selected using the graphical 

user menu system (e.g., the ’301 Accused Instrumentalities dynamically construct an active path 

(e.g., “Amplifiers and Linear—Comparators”) as a sequence of active links as items are selected 

(e.g., as “Amplifiers and Linear” and “Comparators” are selected)), with one said active link 

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corresponding to each of the items selected, said active links providing direct access to one of a 

function, corresponding level and menu item without the need to navigate using said graphical 

user menu system (e.g., the ’301 Accused Instrumentalities’ active path “Amplifiers and 

Linear—Comparators” corresponds to each of the items selected, including “Amplifiers and 

Linear” and “Comparators”) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

54. Also, each active link in the ’301 Accused Instrumentalities enables the user to 

directly browse all items on any given level of the hierarchical information structure including all 

hierarchically subordinate items without affecting the Active Path (e.g., the ’301 Accused 

Instrumentalities enable the user to directly browse all items under “Amplifiers and Linear” such 

as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors” without 

affecting the active path “Amplifiers and Linear—Comparators”) as shown below:

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See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020).

55. On information and belief, the ’301 Accused Instrumentalities provide predefined short-cuts enabling direct access to a given menu item (e.g., the ’301 Accused 

Instrumentalities provide pre-defined shortcuts, such as “Amplifiers and Linear” or 

“Comparators” in the collapsing menu, enabling direct access to a given menu item); and 

dynamically constructing the Active Path when a pre-defined short-cut is executed, with one said 

active link corresponding to each of the items necessary to access said given item using said 

graphical user menu system (e.g., the Active Path is dynamically constructed when “Amplifiers 

and Linear” is executed, with the active link “Amplifiers and Linear” corresponding to the menu 

item “Amplifiers and Linear” necessary to access the menu item using Defendant’s graphical 

user menu system). 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 21 of 100
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56. On information and belief, in the ’301 Accused Instrumentalities, rolling over a 

selected active link triggers the display of sibling items on the hierarchically subordinate levels 

associated with said selected active link (e.g., the ’301 Accused Instrumentalities allow rolling 

over the link “Amplifiers and Linear” to trigger the display of sibling items on the hierarchically 

subordinate levels associated with the selected active link “Amplifiers and Linear” such as 

“Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors”) as shown 

below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

57. On information and belief, the ’301 Accused Instrumentalities allow selecting a 

given active link to trigger the execution of a function associated with said given active link 

(e.g., selecting a given active link such as “Amplifiers and Linear” triggers the execution of a 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 22 of 100
- 23 -

function, such as displaying sibling menus (e.g., “Operational Amplifiers,” “Instrumentation 

Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and 

“DC Power Current Monitors”) or directing user to certain content).

58. On information and belief, the ’301 Accused Instrumentalities allow selecting a 

given active link to trigger display of information associated with said given active link (e.g., the 

’301 Accused Instrumentalities allow selecting the link “Amplifiers and Linear” to trigger 

display of information (e.g., displaying “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors”) associated with the link “Amplifiers and Linear”).

59. On information and belief, the ’301 Accused Instrumentalities provide a method 

for navigating within a multi-level hierarchical information structure where each level in the 

structure contains plural items, each said item being at least one of a function, a pointer to a 

location, and a pointer to another level as shown below:

See, e.g., https://www.microchip.com/design-centers/automotive-solutions/automotiveapplications (last visited Feb. 10, 2020) (annotated). 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 23 of 100
- 24 -

60. By way of example, the ’301 Accused Instrumentalities provide a method for 

navigating within a multi-level hierarchical information structure where each level in the 

structure contains plural items, each said item being at least one of a function, a pointer to a 

location, and a pointer to another level (e.g., the ’301 Accused Instrumentalities provide a 

method for navigating within a multi-level hierarchical collapsing menu structure where each 

level in the information structure contains plural items, each said item being at least one of a 

function, a pointer to a location, and a pointer to another level (e.g., “Products” includes 

“Amplifiers and Linear,” which includes “Operational Amplifiers,” “Instrumentation 

Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and 

“DC Power Current Monitors”)) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 24 of 100
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61. More specifically, the ’301 Accused Instrumentalities provide displaying a 

graphic element representing a root of the hierarchical information structure (e.g., the ’301 

Accused Instrumentalities display a number of graphic elements each representing a root of the 

hierarchical information structure) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020) (annotated). 

62. Also, the ’301 Accused Instrumentalities allow browsing the hierarchical 

information structure by rolling over said graphic element using a pointing device (e.g., by 

rolling over a mouse over the “Applications and Linear” or the “down arrow”), wherein 

browsing results in the display of sibling items or hierarchically subordinate items (e.g., 

browsing results in the display of items such as “Operational Amplifiers,” “Instrumentation 

Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “PGAs,” and “DC Power Current 

Monitors”) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 25 of 100
- 26 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

63. Also, the ’301 Accused Instrumentalities allow selecting one of the displayed 

items (e.g., selecting “Amplifiers and Linear”); dynamically constructing an Active Path as a 

sequence of active links as items are selected (e.g., the ’301 Accused Instrumentalities 

dynamically construct an active path (e.g., “Amplifiers and Linear—Comparators”) as a 

sequence of active links as items are selected (e.g., as “Amplifiers and Linear” and 

“Comparators” are selected)), with one said active link corresponding to each of the items 

selected, said active links providing direct access to one of a function, corresponding level and 

item without the need to navigate from the root of the hierarchical information structure (e.g., the 

’301 Accused Instrumentalities’ active path “Amplifiers and Linear—Comparators” corresponds 

to each of the items sequentially selected, including “Amplifiers and Linear” and 

“Comparators”).

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 26 of 100
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64. Also, each said active link in the ’301 Accused Instrumentalities enables the user 

to directly browse all items on any given level of the hierarchical information structure including 

all hierarchically subordinate items without affecting the Active Path (e.g., the ’301 Accused 

Instrumentalities enable the user to directly browse all items under “Amplifiers and Linear” such 

as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors” without 

affecting the active path “Amplifiers and Linear—Comparators”) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

65. Discovery is expected to uncover the full extent of Defendant’s infringement of 

the ’301 Patent beyond the ’301 Accused Instrumentalities already identified through public 

information. 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 27 of 100
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66. Upon information and belief, Defendant has induced and continues to induce 

others to infringe at least Claims 1-5 and 9 of the ’301 Patent under 35 U.S.C. § 271(b) by, 

among other things, and with specific intent or willful blindness, actively aiding and abetting 

others to infringe, including but not limited to Defendant’s new, current, and prospective users, 

partners, customers and other third parties, whose use of the ’301 Accused Instrumentalities 

constitutes direct infringement of at least Claims 1-5 and 9 of the ’301 Patent. 

67. In particular, Defendant’s actions that aid and abet others such as its new, current, 

and prospective users, partners, customers and third parties to infringe include advertising the 

’301 Accused Instrumentality. On information and belief, Defendant has engaged in such 

actions with specific intent to cause infringement or with willful blindness to the resulting 

infringement because Defendant has had actual knowledge of the ’301 Patent and knowledge 

that its acts were inducing infringement of the ’301 Patent since at least the date Defendant 

received notice based on the filing of this Complaint that such activities infringed the ’301 

Patent. 

68. Defendant’s acts of inducement include, without limitation: providing the ’301 

Accused Instrumentalities to its new, current, and prospective users, partners, and customers, and 

other third parties and intending them to use the ’301 Accused Instrumentalities that enable 

and/or make use of content published therein; encouraging customers and other third parties to 

communicate directly with Defendant’s representatives about the ’301 Accused Instrumentalities 

and content published therein for purposes of technical assistance as well as sales and marketing 

(see, e.g., https://microchipsupport.force.com/s/ (providing consumers with a technical support 

portal through which technical issues and concerns regarding the ’301 Accused Instrumentalities 

can be addressed); see, e.g., https://microchipsupport.force.com/s/supportCase 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 28 of 100
- 29 -

resources?tabName=Contact (providing contact information for technical support regarding the 

’301 Accused Instrumentalities); see also id. (providing a community platform for discussing the 

’301 Accused Instrumentalities or content published therein); see also 

https://www.facebook.com/microchiptechnology/ (encouraging customers and other third parties 

to use the ’301 Accused Instrumentalities to access content published therein (e.g., providing an 

URL (https://page.microchip.com/ewTiming.html?utm_campaign=EmbeddedWorld2020&utm_source=facebook.com&utm_medium

=Post&utm_content=SharePoint43895.5417&fbclid=IwAR2TVwazReb1Ul3TgRAgkutaZY3eE_ikA0HfXVGI6vjYdziBuNwa5BtxOo) to a “Timing and System Solutions” webpage 

that can be accessed using the ’301 Accused Instrumentalities)); see also 

https://www.microchip.com/about-us/company-information/acquisitions (recommending 

investors and other third parties use the ’301 Accused Instrumentalities to access financial 

information relating to Microchip’s cooperate operations and acquisitions); see also 

https://www.microchip.com/documentlisting/financial-press-releases (for example, 

https://www.microchip.com/investor/Pressrelease/MCHP%20Announces%20Financial%20Resul

ts%20for%20Q3FY20.020420.pdf providing an URL (www.microchip.com) to the ’301

Accused Instrumentalities); see also

https://twitter.com/MicrochipTech?ref_src=twsrc%5Egoogle%7Ctwcamp%5Eserp%7Ctwgr%5E

author, https://www.facebook.com/microchiptechnology/ and 

https://www.linkedin.com/posts/microchip-technology_from-simple-buffers-and-clockgenerators-activity-6641422443871383552-bbea (Defendant’s social media accounts promoting 

the use of ’301 Accused Instrumentalities through which various media content can be accessed); 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 29 of 100
- 30 -

providing press releases encouraging customers and other third parties to use the ’301 Accused 

Instrumentalities to access content (for example, providing an URL (www.microchip.com) to the 

“Microchip” main webpage that can be accessed using the ’301 Accused Instrumentalities); and 

https://www.microchip.com/blog (providing blogs encouraging customers and other third parties 

to use the ’301 Accused Instrumentalities to access content (for example, providing an URL 

(https://www.microchip.com/wwwproducts/en/MCP6C02) to a “MCP6C02” webpage that can 

be accessed using the ’301 Accused Instrumentalities))). 

69. Defendant performed acts of inducement despite its actual knowledge since at 

least the filing date of this Complaint and its knowledge that the specific actions it actively 

induced and continues to actively induce on the part of its users, partners, and customers, and 

other third parties constitute infringement of the ’301 Patent. At the very least, because 

Defendant has been, and remains, on notice of the ’301 Patent and the accused infringement, it 

has been, and remains, willfully blind regarding the infringement that it has induced and 

continues to induce.

70. On information and belief, Defendant has contributed to, and continues to 

contribute to, infringement of at least Claims 1-5 and 9 of the ’301 Patent pursuant to 35 U.S.C. 

§ 271(c) by providing the ’301 Accused Instrumentalities that have contributed, and continue to 

contribute, to the direct infringement of new, current, and prospective users, partners, customers 

and other third parties with the knowledge (at least as of the filing date of this Complaint) that 

the ’301 Accused Instrumentalities are especially made or adapted for use in an infringement of 

the ’301 Patent. For example, by providing the web pages, software, and computer equipment 

identified above, Defendant contributes to the direct infringement of users of said web pages, 

software, and computer equipment. The ’301 Accused Instrumentalities are material 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 30 of 100
- 31 -

components or apparatuses for use in practicing the ’301 Patent and are not staple articles of 

commerce suitable for substantial non-infringing use.

71. For example, the ’301 Accused Instrumentalities provide a graphical user menu 

system through which a user can navigate within a multi-level hierarchical information structure 

according to the claimed invention(s). Defendant supplied, and continues to supply, the ’301 

Accused Instrumentalities, or components or apparatuses thereof, with the knowledge of the ’301 

Patent and with the knowledge that these components or apparatuses constitute critical and 

material parts of the claimed inventions of the ’301 Patent. Moreover, Defendant knows at least 

by virtue of its knowledge of its own products and services and the ’301 Patent that the ’301 

Accused Instrumentalities are especially made and/or especially adapted for use as claimed in the 

’301 Patent and there is no substantial non-infringing use of these components or apparatuses.

72. Defendant has directly and indirectly infringed the ’301 Patent and is thus liable 

for infringement of the ’301 Patent pursuant to 35 U.S.C. § 271.

73. Plaintiffs have suffered, and continue to suffer, damages as a result of 

Defendant’s infringement of the ’301 Patent. 

74. Defendant has continued to infringe the ’301 Patent since at least the filing date of 

this Complaint, despite being on notice of the ’301 Patent and its infringement. Defendant has 

therefore infringed the ’301 Patent knowingly, willfully, deliberately, and in disregard of 

Plaintiffs’ patent rights since at least the filing date of this Complaint, at least by infringing with 

actual knowledge of its direct and indirect infringement or while remaining willfully blind to the 

fact of its direct and indirect infringement. As a result of at least this conduct, Plaintiffs are 

entitled to enhanced damages under 35 U.S.C. § 284 and to attorneys’ fees and costs under 35 

U.S.C. § 285.

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 31 of 100
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75. Plaintiffs reserve the right to modify its infringement theories as discovery 

progresses in this case. Plaintiffs shall not be estopped for purposes of its infringement 

contentions or its claim constructions by the foregoing discussions on how the ’301 Accused 

Instrumentalities infringe the ’301 Patent. Plaintiffs intend only that the foregoing discussions 

satisfy the notice requirements of Rule 8(a)(2) of the Federal Rule of Civil Procedure, and that 

they should not be construed as Plaintiffs’ preliminary or final infringement contentions or 

preliminary or final claim construction positions.

COUNT III - INFRINGEMENT OF U.S. PATENT NO. 7,640,517

76. Plaintiffs incorporate and reallege the preceding paragraphs as if fully set forth 

herein.

77. The ’517 Patent is directed to systems and methods for navigating within a 

hierarchical menu structure, as described and claimed in the ’517 Patent. 

78. Defendant has and continues to directly infringe at least Claims 1-6 of the ’517 

Patent, in this judicial District and elsewhere in the United States, pursuant to 35 U.S.C. § 

271(a), literally or under the doctrine of equivalents, by, among other things, by making, using, 

selling, offering to sell, and/or importing in or into the United States, without authority: (i) web 

pages and content to be interactively presented in browsers, including, without limitation, the 

web pages and content accessible via https://www.microchip.com/ and maintained on servers 

located in and/or accessible from the United States under the control of Defendant; (ii) software, 

including, without limitation, software that allows content to be interactively presented in and/or 

served to browsers; (iii) computer equipment, including, without limitation, computer equipment 

that stores, serves, and/or runs any of the foregoing or that allows navigating within a 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 32 of 100
- 33 -

hierarchical menu structure, where each level in the menu contains plural items (hereinafter, the 

“’517 Accused Instrumentalities”) as shown below:

See, e.g., https://www.microchip.com/design-centers/automotive-solutions/automotiveapplications (last visited Feb. 10, 2020) (annotated). 

79. By way of example, the ’517 Accused Instrumentalities provide a method for 

navigating within a hierarchical menu structure where each level in the menu contains plural 

items as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 33 of 100
- 34 -

See, e.g., https://www.microchip.com/design-centers/automotive-solutions/automotiveapplications (last visited Feb. 10, 2020) (annotated). 

80. More specifically, the ’517 Accused Instrumentalities provide a graphical user 

menu system displaying the items of a given level and enabling selection thereof (e.g., “What we 

do” displays and enables selection of items of a given level, such as “Amplifiers and Linear” and 

items within that same level), wherein access of said given level requires sequential access of 

each of the levels preceding said given level in the hierarchy (e.g., to access “Amplifiers and 

Linear,” “Products” is accessed first; similarly, to access “Comparators” “Amplifiers and Linear” 

is accessed first); and constructing an Active Path as a sequence of hierarchical active links as 

items are selected using the graphical user menu system (e.g., the ’517 Accused Instrumentalities 

construct an active path (e.g., “Amplifiers and Linear—Comparators”) as a sequence of 

hierarchical active links as items are selected (e.g., as “Amplifiers and Linear” and 

“Comparators” are selected)), with one said active link corresponding to each of the items 

selected, each said active link providing direct access to the hierarchical level from which the 

corresponding item was selected without using said graphical user menu system (e.g., the ’517 

Accused Instrumentalities’ active path “Amplifiers and Linear—Comparators” corresponds to 

each of the items selected, including “Amplifiers and Linear” and “Comparators,” each link 

providing direct access to the hierarchical level from which “Amplifiers and Linear” or 

“Comparators” was selected without using Defendant’s graphical user menu system) as shown 

below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 34 of 100
- 35 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

81. Also, the ’517 Accused Instrumentalities display the Active Path as an alternative 

to the graphical user menu system for navigating the menu structure after the user has finished 

selecting items using the graphical user system such that the Active Path is displayed (e.g., the 

’517 Accused Instrumentalities display the Active Path as an alternative to Defendant’s graphical 

user menu system for navigating the menu structure after the user has finished selecting items, 

such as “Amplifiers and Linear” and “Comparators,” using Microchip’s graphical user menu 

system such that Microchip’s Active Path is displayed) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 35 of 100
- 36 -

See, e.g., https://www.microchip.com/design-centers/automotive-solutions/automotiveapplications (last visited Feb. 10, 2020). 

82. On information and belief, in the ’517 Accused Instrumentalities, rolling over a 

given active link with the pointer of a pointing device triggers the display of menu items on the 

hierarchical level associated with said given active link without disturbing the displayed Active 

Path (e.g., the ’517 Accused Instrumentalities allow rolling over the link “Amplifiers and Linear”

with a mouse to trigger the display of menu items on the hierarchical level associated with 

“Amplifiers and Linear” such as “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors” without disturbing the displayed Active Path “What we do-Digital 

Innovation”) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 36 of 100
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83. On information and belief, the ’517 Accused Instrumentalities provide predefined short-cuts enabling direct access to a given menu item (e.g., the ’517 Accused 

Instrumentalities provide pre-defined shortcuts, such as “Amplifiers and Linear” or 

“Comparators” in the collapsing menu enabling direct access to a given menu item); and 

automatically constructing the Active Path when a pre-defined short-cut is executed, with one 

said active link corresponding to each of the menu items necessary to access said given menu 

item using said graphical user menu system (e.g., the Active Path is automatically constructed 

when “Amplifiers and Linear” or “Comparators” is executed, with each active link “Amplifiers 

and Linear” or “Comparators” corresponding to each of the menu items necessary to access the 

given menu item using the graphical user menu system).

84. On information and belief, in the ’517 Accused Instrumentalities, a given active 

link is browsed by rolling over the given active link with a pointing device to trigger the display 

of sibling menu items on the level associated with said given active link (e.g., the ’517 Accused 

Instrumentalities allow rolling over the link “Digital Innovation” with a mouse to trigger the 

display of sibling items on the level associated with “Amplifiers and Linear” such as 

“Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors”) as shown 

below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 37 of 100
- 38 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

85. On information and belief, in the ’517 Accused Instrumentalities, browsing a 

given active menu item triggers the display of subordinate menu items (e.g., browsing 

“Automotive Products” triggers the display of subordinate menu items, such as 

“Microcontrollers,” “Analog Products,” “Connectivity,” “Automotive Touch,” “Car Access,” 

“memory Products,” “High Temperature Products,” “Timing Solutions,” and “Automotive 

Security”) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 38 of 100
- 39 -

See, e.g., https://www.microchip.com/design-centers/automotive-solutions (last visited Feb. 10, 

2020). 

86. On information and belief, in the ’517 Accused Instrumentalities, selecting a 

given active link triggers the execution of a function associated with said given active link (e.g., 

selecting a given active link such as “Amplifiers and Linear” triggers the execution of a function, 

such as displaying sibling menus (e.g., “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors”) or directing user to certain content). 

87. On information and belief, in the ’517 Accused Instrumentalities, selecting a 

given active link triggers display of information associated with said given active link (e.g., the 

’517 Accused Instrumentalities allow selecting the link “Amplifiers and Linear” to trigger 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 39 of 100
- 40 -

display of information (e.g., displaying “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors”) associated with the link “Amplifiers and Linear”).

88. Discovery is expected to uncover the full extent of Defendant’s infringement of 

the ’517 Patent beyond the ’517 Accused Instrumentalities already identified through public 

information. 

89. Upon information and belief, Defendant has induced and continues to induce 

others to infringe at least Claims 1-6 of the ’517 Patent under 35 U.S.C. § 271(b) by, among 

other things, and with specific intent or willful blindness, actively aiding and abetting others to 

infringe, including but not limited to Defendant’s new, current, and prospective users, partners, 

customers and other third parties, whose use of the ’517 Accused Instrumentalities constitutes 

direct infringement of at least Claims 1-6 of the ’517 Patent. 

90. In particular, Defendant’s actions that aid and abet others such as its new, current, 

and prospective users, partners, customers and third parties to infringe include advertising the 

’517 Accused Instrumentality. On information and belief, Defendant has engaged in such 

actions with specific intent to cause infringement or with willful blindness to the resulting 

infringement because Defendant has had actual knowledge of the ’517 Patent and knowledge 

that its acts were inducing infringement of the ’517 Patent since at least the date Defendant 

received notice based on the filing of this Complaint that such activities infringed the ’517 

Patent. 

91. Defendant’s acts of inducement include, without limitation: providing the ’517 

Accused Instrumentalities to its new, current, and prospective users, partners, and customers, and 

other third parties and intending them to use the ’517 Accused Instrumentalities that enable 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 40 of 100
- 41 -

and/or make use of content published therein; encouraging customers and other third parties to 

communicate directly with Defendant’s representatives about the ’517 Accused Instrumentalities 

and content published therein for purposes of technical assistance as well as sales and marketing 

(see, e.g., https://microchipsupport.force.com/s/ (providing consumers with a technical support 

portal through which technical issues and concerns regarding the ’517 Accused Instrumentalities 

can be addressed); see, e.g., https://microchipsupport.force.com/s/supportresources?tabName=Contact (providing contact information for technical support regarding the 

’517 Accused Instrumentalities); see also id. (providing a community platform for discussing the 

’517 Accused Instrumentalities or content published therein); see also 

https://www.facebook.com/microchiptechnology/ (encouraging customers and other third parties 

to use the ’517 Accused Instrumentalities to access content published therein (e.g., providing an 

URL (https://page.microchip.com/ewTiming.html?utm_campaign=EmbeddedWorld2020&utm_source=facebook.com&utm_medium

=Post&utm_content=SharePoint43895.5417&fbclid=IwAR2TVwazReb1Ul3TgRAgkutaZY3eE_ikA0HfXVGI6vjYdziBuNwa5BtxOo) to a “Timing and System Solutions” webpage 

that can be accessed using the ’517 Accused Instrumentalities)); see also 

https://www.microchip.com/about-us/company-information/acquisitions (recommending 

investors and other third parties use the ’517 Accused Instrumentalities to access financial 

information relating to Microchip’s cooperate operations and acquisitions); see also 

https://www.microchip.com/documentlisting/financial-press-releases (for example, 

https://www.microchip.com/investor/Pressrelease/MCHP%20Announces%20Financial%20Resul

ts%20for%20Q3FY20.020420.pdf providing an URL (www.microchip.com) to the ’517 

Accused Instrumentalities); see also

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 41 of 100
- 42 -

https://twitter.com/MicrochipTech?ref_src=twsrc%5Egoogle%7Ctwcamp%5Eserp%7Ctwgr%5E

author, https://www.facebook.com/microchiptechnology/ and 

https://www.linkedin.com/posts/microchip-technology_from-simple-buffers-and-clockgenerators-activity-6641422443871383552-bbea (Defendant’s social media accounts promoting 

the use of ’517 Accused Instrumentalities through which various media content can be accessed); 

providing press releases encouraging customers and other third parties to use the ’517 Accused 

Instrumentalities to access content (for example, providing an URL (www.microchip.com) to the 

“Microchip” main webpage that can be accessed using the ’517 Accused Instrumentalities); and 

https://www.microchip.com/blog (providing blogs encouraging customers and other third parties 

to use the ’517 Accused Instrumentalities to access content (for example, providing an URL 

(https://www.microchip.com/wwwproducts/en/MCP6C02) to a “MCP6C02” webpage that can 

be accessed using the ’517 Accused Instrumentalities))). 

92. Defendant performed acts of inducement despite its actual knowledge since at 

least the filing date of this Complaint and its knowledge that the specific actions it actively 

induced and continues to actively induce on the part of its users, partners, and customers, and 

other third parties constitute infringement of the ’517 Patent. At the very least, because 

Defendant has been, and remains, on notice of the ’517 Patent and the accused infringement, it 

has been, and remains, willfully blind regarding the infringement that it has induced and 

continues to induce.

93. On information and belief, Defendant has contributed to, and continues to 

contribute to, infringement of at least Claims 1-6 of the ’517 Patent pursuant to 35 U.S.C. § 

271(c) by providing the ’517 Accused Instrumentalities that have contributed, and continue to 

contribute, to the direct infringement of new, current, and prospective users, partners, customers 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 42 of 100
- 43 -

and other third parties with the knowledge (at least as of the filing date of this Complaint) that 

the ’517 Accused Instrumentalities are especially made or adapted for use in an infringement of 

the ’517 Patent. For example, by providing the web pages, software, and computer equipment 

identified above, Defendant contributes to the direct infringement of users of said web pages, 

software, and computer equipment. The ’517 Accused Instrumentalities are material 

components or apparatuses for use in practicing the ’517 Patent and are not staple articles of 

commerce suitable for substantial non-infringing use.

94. For example, the ’517 Accused Instrumentalities provide a graphical user menu 

system through which a user can navigate within a multi-level hierarchical information structure 

according to the claimed invention(s). Defendant supplied, and continues to supply, the ’517 

Accused Instrumentalities, or components or apparatuses thereof, with the knowledge of the ’517 

Patent and with the knowledge that these components or apparatuses constitute critical and 

material parts of the claimed inventions of the ’517 Patent. Moreover, Defendant knows at least 

by virtue of its knowledge of its own products and services and the ’517 Patent that the ’517 

Accused Instrumentalities are especially made and/or especially adapted for use as claimed in the 

’517 Patent and there is no substantial non-infringing use of the ’517 Accused Instrumentalities, 

or components or apparatuses thereof.

95. Defendant has directly and indirectly infringed the ’517 Patent and is thus liable 

for infringement of the ’517 Patent pursuant to 35 U.S.C. § 271.

96. Plaintiffs have suffered, and continue to suffer, damages as a result of 

Defendant’s infringement of the ’517 Patent. 

97. Defendant has continued to infringe the ’517 Patent since at least the filing date of 

this Complaint, despite being on notice of the ’517 Patent and its infringement. Defendant has 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 43 of 100
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therefore infringed the ’517 Patent knowingly, willfully, deliberately, and in disregard of 

Plaintiffs’ patent rights since at least the filing date of this Complaint, at least by infringing with 

actual knowledge of its direct and indirect infringement or while remaining willfully blind to the 

fact of its direct and indirect infringement. As a result of at least this conduct, Plaintiffs are 

entitled to enhanced damages under 35 U.S.C. § 284 and to attorneys’ fees and costs under 35 

U.S.C. § 285.

98. Plaintiffs reserve the right to modify its infringement theories as discovery 

progresses in this case. Plaintiffs shall not be estopped for purposes of its infringement 

contentions or its claim constructions by the foregoing discussions on how the ’517 Accused 

Instrumentalities infringe the ’517 Patent. Plaintiffs intend only that the foregoing discussions 

satisfy the notice requirements of Rule 8(a)(2) of the Federal Rule of Civil Procedure, and that 

they should not be construed as Plaintiffs’ preliminary or final infringement contentions or 

preliminary or final claim construction positions. 

COUNT IV - INFRINGEMENT OF U.S. PATENT NO. 7,725,836

99. Plaintiffs incorporate and reallege the preceding paragraphs as if fully set forth 

herein.

100. The ’836 Patent is directed to systems and methods for navigating within a multilevel hierarchical information structure, as described and claimed in the ’836 Patent. 

101. Defendant has and continues to directly infringe at least Claims 1-5 and 7-8 of the 

’836 Patent, in this judicial District and elsewhere in the United States, pursuant to 35 U.S.C. § 

271(a), literally or under the doctrine of equivalents, by, among other things, by making, using, 

selling, offering to sell, and/or importing in or into the United States, without authority: (i) web 

pages and content to be interactively presented in browsers, including, without limitation, the 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 44 of 100
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web pages and content accessible via https://www.microchip.com/ and maintained on servers 

located in and/or accessible from the United States under the control of Defendant; (ii) software, 

including, without limitation, software that allows content to be interactively presented in and/or 

served to browsers; (iii) computer equipment, including, without limitation, computer equipment 

that stores, serves, and/or runs any of the foregoing or that allows navigating within a multi-level 

hierarchical information structure where each level in the menu contains plural items, each said 

item being at least one of a function, a pointer to a location, and a pointer to another level

(hereinafter, the “’836 Accused Instrumentalities”) as shown below: 

See, e.g., https://www.microchip.com/design-centers/automotive-solutions/automotiveapplications (last visited Feb. 10, 2020). 

102. By way of example, the ’836 Accused Instrumentalities provide a method for 

navigating within a multi-level hierarchical information structure where each level in the menu 

contains plural items as shown below:

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See, e.g., https://www.microchip.com/design-centers/automotive-solutions/automotiveapplications (last visited Feb. 10, 2020) (annotated). 

103. More specifically, the ’836 Accused Instrumentalities provide a graphical user 

menu system displaying the items of a given level of the hierarchical information structure and 

enabling selection thereof (e.g., “Products” displays and enables selection of items of a given 

level, such as “Amplifiers and Linear” and items within that same level); and constructing an 

Active Path as a sequence of active links as the user navigates the information structure using the 

graphical user menu system (e.g., the ’836 Accused Instrumentalities construct an active path 

(e.g., “Amplifiers and Linear—Comparators”) as a sequence of active links as the user navigates 

the information structure using the graphical user menu system (e.g., as “Amplifiers and Linear” 

and “Comparators” are selected)), with one said active link corresponding to each of the 

hierarchical levels accessed by the user, said active links providing direct access to one of a 

function, corresponding level and menu item without the need to navigate using said graphical 

user menu system (e.g., the ’836 Accused Instrumentalities’ active path “Amplifiers and 

Linear—Comparators” corresponds to each of the hierarchical levels accessed by the user, 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 46 of 100
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including “Amplifiers and Linear” and “Comparators,” each link providing direct access to one 

of a function, corresponding level and menu item without the need to navigate using said 

graphical user menu system) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020).

104. Also, in the ’836 Accused Instrumentalities, a given said active link enables the 

user to browse items of the hierarchical information structure starting from the level 

corresponding with the given active link and items on hierarchically subordinate levels without 

affecting the Active Path (e.g., the ’836 Accused Instrumentalities enable the user to browse 

items of the hierarchical information structure starting from “Amplifiers and Linear” and items 

on subordinate levels such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current 

Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current 

Monitors” without affecting the active path “Amplifiers and Linear—Comparators”) as shown 

below:

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See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

105. On information and belief, the ’836 Accused Instrumentalities provide predefined short-cuts enabling direct access to a given menu item (e.g., the ’836 Accused 

Instrumentalities provide pre-defined shortcuts, such as “Amplifiers and Linear” or 

“Comparators” in the collapsing menu enabling direct access to a given menu item); and 

dynamically constructing the Active Path when a pre-defined short-cut is executed, with one said 

active link corresponding to each of the menu items necessary to access said given menu item 

using said graphical user menu system (e.g., the Active Path is dynamically constructed when 

“Amplifiers and Linear” or “Comparators” is executed, with each active link “Amplifiers and 

Linear” or “Comparators” corresponding to each of the menu items necessary to access said 

given menu item using said graphical user menu system). 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 48 of 100
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106. On information and belief, in the ’836 Accused Instrumentalities, rolling over a 

selected active link triggers the display of sibling menu items on the hierarchically subordinate 

levels associated with said selected active link (e.g., the ’301 Accused Instrumentalities allow 

rolling over the link “Amplifiers and Linear” to trigger the display of sibling menu items on the 

hierarchically subordinate levels associated with the selected active link “Amplifiers and Linear”

such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors”) as shown 

below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

107. On information and belief, the ’836 Accused Instrumentalities allow selecting a 

given active link triggers the execution of a function associated with said given active link (e.g., 

selecting a given active link such as “Amplifiers and Linear” triggers the execution of a function, 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 49 of 100
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such as displaying sibling menus (e.g., “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors”) or directing user to certain content).

108. On information and belief, the ’836 Accused Instrumentalities allow selecting a 

given active link to trigger display of information associated with said given active link (e.g., the 

’836 Accused Instrumentalities allow selecting the link “Amplifiers and Linear” to trigger 

display of information (e.g., displaying Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors”) associated with the link “Amplifiers and Linear”).

109. On information and belief, the multi-level hierarchical information structure is a 

website (e.g., https://www.microchip.com/). 

110. On information and belief, the ’836 Accused Instrumentalities provides a method 

for navigating websites including a plurality of hierarchically organized web pages, including 

providing a means for navigating the multi-level hierarchical website (e.g., the ’836 Accused 

Instrumentalities provides a graphical user menu system for navigating a multi-level hierarchical 

website); and dynamically constructing an Active Path as a sequence of active links as the user 

navigates the multi-level hierarchical website (e.g., the ’836 Accused Instrumentalities 

dynamically construct an active path (e.g., “Amplifiers and Linear—Comparators”) as a 

sequence of active links as the user navigates the multi-level hierarchical website (e.g., as 

“Amplifiers and Linear” and “Comparators” are selected)), wherein each said active link 

corresponds to a level in the hierarchical structure, wherein a user may directly access any given 

level of the hierarchical structure by selecting a given said active link (e.g., the ’836 Accused 

Instrumentalities dynamically construct an active path as a sequence of active links as the user 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 50 of 100
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navigates the multi-level hierarchical website, such that the active path “Amplifiers and Linear—

Comparators” corresponds to each of the items selected, including “Amplifiers and Linear” and 

“Comparators”, with each link corresponding to a level in the hierarchical structure, where a user 

may directly access any level of the hierarchical structure by selecting “Amplifiers and Linear” 

and “Comparators”) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

111. Also, each active link provides the user the ability to directly browse items on any 

given level of the hierarchical menu structure and hierarchically subordinate items without 

affecting the Active Path (e.g., the ’836 Accused Instrumentalities enable the user to browse 

items of the hierarchical information structure starting from “Amplifiers and Linear” and items 

on subordinate levels such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current 

Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 51 of 100
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Monitors” without affecting the active path “Amplifiers and Linear—Comparators”) as shown 

below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020).

112. Discovery is expected to uncover the full extent of Defendant’s infringement of 

the ’836 Patent beyond the ’836 Accused Instrumentalities already identified through public 

information. 

113. Upon information and belief, Defendant has induced and continues to induce 

others to infringe at least Claims 1-5 and 7-8 of the ’836 Patent under 35 U.S.C. § 271(b) by, 

among other things, and with specific intent or willful blindness, actively aiding and abetting 

others to infringe, including but not limited to Defendant’s new, current, and prospective users, 

partners, customers and other third parties, whose use of the ’836 Accused Instrumentalities 

constitutes direct infringement of at least Claims 1-5 and 7-8 of the ’836 Patent. 

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114. In particular, Defendant’s actions that aid and abet others such as its new, current, 

and prospective users, partners, customers and third parties to infringe include advertising the 

’836 Accused Instrumentality. On information and belief, Defendant has engaged in such 

actions with specific intent to cause infringement or with willful blindness to the resulting 

infringement because Defendant has had actual knowledge of the ’836 Patent and knowledge 

that its acts were inducing infringement of the ’836 Patent since at least the date Defendant 

received notice based on the filing of this Complaint that such activities infringed the ’836 

Patent. 

115. Defendant’s acts of inducement include, without limitation: providing the ’836 

Accused Instrumentalities to its new, current, and prospective users, partners, and customers, and 

other third parties and intending them to use the ’836 Accused Instrumentalities that enable 

and/or make use of content published therein; encouraging customers and other third parties to 

communicate directly with Defendant’s representatives about the ’836 Accused Instrumentalities 

and content published therein for purposes of technical assistance as well as sales and marketing 

(see, e.g., https://microchipsupport.force.com/s/ (providing consumers with a technical support 

portal through which technical issues and concerns regarding the ’836 Accused Instrumentalities 

can be addressed); see, e.g., https://microchipsupport.force.com/s/supportresources?tabName=Contact (providing contact information for technical support regarding the 

’836 Accused Instrumentalities); see also id. (providing a community platform for discussing the 

’836 Accused Instrumentalities or content published therein); see also 

https://www.facebook.com/microchiptechnology/ (encouraging customers and other third parties 

to use the ’836 Accused Instrumentalities to access content published therein (e.g., providing an 

URL (https://page.microchip.com/ewCase 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 53 of 100
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Timing.html?utm_campaign=EmbeddedWorld2020&utm_source=facebook.com&utm_medium

=Post&utm_content=SharePoint43895.5417&fbclid=IwAR2TVwazReb1Ul3TgRAgkutaZY3eE_ikA0HfXVGI6vjYdziBuNwa5BtxOo) to a “Timing and System Solutions” webpage 

that can be accessed using the ’836 Accused Instrumentalities)); see also 

https://www.microchip.com/about-us/company-information/acquisitions (recommending 

investors and other third parties use the ’836 Accused Instrumentalities to access financial 

information relating to Microchip’s cooperate operations and acquisitions); see also 

https://www.microchip.com/documentlisting/financial-press-releases (for example, 

https://www.microchip.com/investor/Pressrelease/MCHP%20Announces%20Financial%20Resul

ts%20for%20Q3FY20.020420.pdf providing an URL (www.microchip.com) to the ’836 

Accused Instrumentalities); see also

https://twitter.com/MicrochipTech?ref_src=twsrc%5Egoogle%7Ctwcamp%5Eserp%7Ctwgr%5E

author, https://www.facebook.com/microchiptechnology/ and 

https://www.linkedin.com/posts/microchip-technology_from-simple-buffers-and-clockgenerators-activity-6641422443871383552-bbea (Defendant’s social media accounts promoting 

the use of ’836 Accused Instrumentalities through which various media content can be accessed); 

providing press releases encouraging customers and other third parties to use the ’836 Accused 

Instrumentalities to access content (for example, providing an URL (www.microchip.com) to the 

“Microchip” main webpage that can be accessed using the ’836 Accused Instrumentalities); and 

https://www.microchip.com/blog (providing blogs encouraging customers and other third parties 

to use the ’836 Accused Instrumentalities to access content (for example, providing an URL 

(https://www.microchip.com/wwwproducts/en/MCP6C02) to a “MCP6C02” webpage that can 

be accessed using the ’836 Accused Instrumentalities))).

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116. Defendant performed acts of inducement despite its actual knowledge since at 

least the filing date of this Complaint and its knowledge that the specific actions it actively 

induced and continues to actively induce on the part of its users, partners, and customers, and 

other third parties constitute infringement of the ’836 Patent. At the very least, because 

Defendant has been, and remains, on notice of the ’836 Patent and the accused infringement, it 

has been, and remains, willfully blind regarding the infringement that it has induced and 

continues to induce.

117. On information and belief, Defendant has contributed to, and continues to 

contribute to, infringement of at least Claims 1-5 and 7-8 of the ’836 Patent pursuant to 35 

U.S.C. § 271(c) by providing the ’836 Accused Instrumentalities that have contributed, and 

continue to contribute, to the direct infringement of new, current, and prospective users, partners, 

customers and other third parties with the knowledge (at least as of the filing date of this 

Complaint) that the ’836 Accused Instrumentalities are especially made or adapted for use in an 

infringement of the ’836 Patent. For example, by providing the web pages, software, and 

computer equipment identified above, Defendant contributes to the direct infringement of users 

of said web pages, software, and computer equipment. The ’836 Accused Instrumentalities are 

material components or apparatuses for use in practicing the ’836 Patent and are not staple 

articles of commerce suitable for substantial non-infringing use.

118. For example, the ’836 Accused Instrumentalities provide a graphical user menu 

system through which a user can navigate within a multi-level hierarchical information structure 

according to the claimed invention(s). Defendant supplied, and continues to supply, the ’836 

Accused Instrumentalities, or components or apparatuses thereof, with the knowledge of the ’836 

Patent and with the knowledge that these components or apparatuses constitute critical and 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 55 of 100
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material parts of the claimed inventions of the ’836 Patent. Moreover, Defendant knows at least 

by virtue of its knowledge of its own products and services and the ’836 Patent that the ’836 

Accused Instrumentalities are especially made and/or especially adapted for use as claimed in the 

’836 Patent and there is no substantial non-infringing use of these components or apparatuses.

119. Defendant has directly and indirectly infringed the ’836 Patent and is thus liable 

for infringement of the ’836 Patent pursuant to 35 U.S.C. § 271.

120. Plaintiffs have suffered, and continue to suffer, damages as a result of 

Defendant’s infringement of the ’836 Patent. 

121. Defendant has continued to infringe the ’836 Patent since at least the filing date of 

this Complaint, despite being on notice of the ’836 Patent and its infringement. Defendant has 

therefore infringed the ’836 Patent knowingly, willfully, deliberately, and in disregard of 

Plaintiffs’ patent rights since at least the filing date of this Complaint, at least by infringing with 

actual knowledge of its direct and indirect infringement or while remaining willfully blind to the 

fact of its direct and indirect infringement. As a result of at least this conduct, Plaintiffs are 

entitled to enhanced damages under 35 U.S.C. § 284 and to attorneys’ fees and costs under 35 

U.S.C. § 285.

122. Plaintiffs reserve the right to modify its infringement theories as discovery 

progresses in this case. Plaintiffs shall not be estopped for purposes of its infringement 

contentions or its claim constructions by the foregoing discussions on how the ’836 Accused 

Instrumentalities infringe the ’836 Patent. Plaintiffs intend only that the foregoing discussions 

satisfy the notice requirements of Rule 8(a)(2) of the Federal Rule of Civil Procedure, and that 

they should not be construed as Plaintiffs’ preliminary or final infringement contentions or 

preliminary or final claim construction positions.

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 56 of 100
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COUNT V - INFRINGEMENT OF U.S. PATENT NO. 8,352,880

123. Plaintiffs incorporate and reallege the preceding paragraphs as if fully set forth 

herein.

124. The ’880 Patent is directed to systems and methods for navigating an information 

structure, as described and claimed in the ’880 Patent. 

125. The ’880 Patent is directed to systems and methods for navigating within a 

hierarchical menu structure where each level in the menu contains plural items, as described and 

claimed in the ’880 Patent. 

126. Defendant has and continues to directly infringe at least Claims 1, 3-10, 12-20 

and 22 of the ’880 Patent, in this judicial District and elsewhere in the United States, pursuant to 

35 U.S.C. § 271(a), literally or under the doctrine of equivalents, by, among other things, by 

making, using, selling, offering to sell, and/or importing in or into the United States, without 

authority: (i) web pages and content to be interactively presented in browsers, including, without 

limitation, the web pages and content accessible via https://www.microchip.com/ and maintained 

on servers located in and/or accessible from the United States under the control of Defendant; (ii) 

software, including, without limitation, software that allows content to be interactively presented 

in and/or served to browsers; (iii) computer equipment, including, without limitation, computer 

equipment that stores, serves, and/or runs any of the foregoing or that allows navigating an 

information structure (hereinafter, the “’880 Accused Instrumentalities”) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 57 of 100
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See, e.g., https://www.microchip.com/design-centers/automotive-solutions/automotiveapplications (last visited Feb. 10, 2020) (annotated). 

127. By way of example, the ’880 Accused Instrumentalities provide a method for 

navigating an information structure as shown below:

See, e.g., https://www.microchip.com/design-centers/automotive-solutions/automotiveapplications (last visited Feb. 10, 2020) (annotated). 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 58 of 100
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128. More specifically, the ’880 Accused Instrumentalities provide a graphical menu 

interface displaying the items of a given level of the information structure and enabling selection 

thereof (e.g., “Products” displays and enables selection of items of a given level, such as 

“Amplifiers and Linear” and items within that same level); and dynamically constructing an 

Active Path as a sequence of active links as items are selected using the graphical user menu 

system (e.g., the ’880 Accused Instrumentalities dynamically construct an active path (e.g., 

“Amplifiers and Linear—Comparators”) as a sequence of active links as items are selected (e.g., 

as “Amplifiers and Linear” and “Comparators” are selected)), with one said active link 

corresponding to each of the items selected, said active links providing direct access to one of a 

function, corresponding level and menu item without the need to navigate using said graphical 

user menu system (e.g., the ’301 Accused Instrumentalities’ active path “Amplifiers and 

Linear—Comparators” corresponds to each of the items selected, including “Amplifiers and 

Linear” and “Comparators”) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

129. Also, the active links allow a user to access an item in the information structure 

by selecting from the one or more items displayed by one of the active links on the active path 

(e.g., the link “Amplifiers and Linear” in the active path “Amplifiers and Linear—Comparators” 

allows a user to access an item in the information structure such as “Operational Amplifiers,” 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 59 of 100
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“Instrumentation Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “Programmable Gain 

Amplifiers,” and “DC Power Current Monitors”) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

130. On information and belief, in the ’880 Accused Instrumentalities, the one or more 

active links allow the display of one or more items on a given level of the information structure 

when a pointer is rolled over one of the active links (e.g., the active link “Amplifiers and Linear”

allows the display of items such as “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors” when a pointer is rolled over it) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 60 of 100
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See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

131. On information and belief, in the ’880 Accused Instrumentalities, the one or more 

active links allow the display of one or more items on a given level of the information structure 

when one of the active links is selected (e.g., the active link “Amplifiers and Linear” allows the 

display of items such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense 

Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current 

Monitors” when it is selected) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 61 of 100
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See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

132. On information and belief, in the ’880 Accused Instrumentalities, the one or more 

active links allow the display of one or more items on a given level of the information structure 

when a visual icon associated with one of the active links is selected (e.g., the active link 

“Amplifiers and Linear” allows the display of items such as “Operational Amplifiers,” 

“Instrumentation Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “Programmable Gain 

Amplifiers,” and “DC Power Current Monitors” when the “down arrow” icon is selected) as 

shown below:

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See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020) (annotated). 

133. On information and belief, in the ’880 Accused Instrumentalities, the active links 

in the active path allow the display of one or more items on a given level of the information 

structure without changing the active path (e.g., the active link “Amplifiers and Linear” in the 

active path allows the display of “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors” without affecting the active path “Amplifiers and Linear—Comparators”) as 

shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

134. On information and belief, in the ’880 Accused Instrumentalities, a user may 

directly access one or more active links in the active path by selecting the active link (e.g., a user 

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may directly access “Comparators” in the “Amplifiers and Linear—Comparators” active path by 

selecting the “Comparators” link).

135. On information and belief, in the ’880 Accused Instrumentalities, the selection of 

an active link causes the active path to truncate to the selected active link (e.g., the selection of 

“Amplifiers and Linear” causes the active link “Automotive and Linear—Comparators” to 

truncate to “Automotive and Linear”).

136. On information and belief, the ’880 Accused Instrumentalities further provide 

pre-defined shortcuts that enable direct access to a given item in the information structure (e.g., 

the ’880 Accused Instrumentalities provide pre-defined shortcuts such as “Amplifiers and 

Linear” or “Comparators” in the collapsing menu enabling direct access to a given menu item in 

the information structure), wherein selection of a predefined shortcut dynamically constructs an 

active path including one active link corresponding to each item necessary to navigate to the 

given item in the information structure (e.g., the active path is dynamically constructed upon 

selection of a predefined shortcut “Amplifiers and Linear” or “Comparators,” including one 

active link “Amplifiers and Linear” or “Comparators” corresponding to each item necessary to 

navigate to “Amplifiers and Linear” or “Comparators” in the information structure). 

137. On information and belief, the ’880 Accused Instrumentalities include an 

apparatus for navigating an information structure, the apparatus including a processor configured 

to: provide a graphical menu interface displaying the items of a given level of the information 

structure and enabling selection thereof (e.g., “Products” displays and enables selection of items 

of a given level, such as “Amplifiers and Linear”); dynamically construct an active path as a 

sequence of active links after an item of the information structure has been selected (e.g., the 

’880 Accused Instrumentalities dynamically construct an active path (e.g., “Amplifiers and 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 64 of 100
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Linear—Comparators”) as a sequence of active links after an item of the information structure 

has been selected (e.g., as “Amplifiers and Linear” and “Comparators” are selected)); upon 

provisional selection of a given one of said active links, display one or more items on a given 

level of the information structure associated with said provisionally selected active link without 

affecting the active path (e.g., the ’880 Accused Instrumentalities displays one or more items 

under “Amplifiers and Linear” such as “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors” without affecting the active path “Amplifiers and Linear—Comparators”) as 

shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

138. On information and belief, in the ’880 Accused Instrumentalities allow a user to 

access an item in the information structure by selecting the item from the one or more items 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 65 of 100
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displayed by one of the active links on the active path (e.g., each link in the active path 

“Amplifiers and Linear—Comparators” allows a user to access an item in the information 

structure such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense 

Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current 

Monitors” by selecting from the “Amplifiers and Linear” link) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020).

139. On information and belief, in the ’880 Accused Instrumentalities, the one or more 

active links allow the display of one or more items on a given level of the information structure 

when a pointer is rolled over one of the active links (e.g., the active link “Amplifiers and Linear”

allows the display of items such as “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors” when a mouse is rolled over it) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 66 of 100
- 67 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

140. On information and belief, in the ’880 Accused Instrumentalities, the one or more 

active links allow the display of one or more items on a given level of the information structure 

when one of the active links is selected (e.g., the active link “Amplifiers and Linear” allows the 

display of items such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense 

Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current 

Monitors” when it is selected) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 67 of 100
- 68 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

141. On information and belief, in the ’880 Accused Instrumentalities, the one or more 

active links allow the display of one or more items on a given level of the information structure 

when a visual icon associated with one of the active links is selected (e.g., the active link 

“Amplifiers and Linear” allows the display of items such as “Operational Amplifiers,” 

“Instrumentation Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “Programmable Gain 

Amplifiers,” and “DC Power Current Monitors” when the “down arrow” icon is selected) as 

shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 68 of 100
- 69 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020) (annotated). 

142. On information and belief, in the ’880 Accused Instrumentalities, the active links 

in the active path allow the display of one or more items on a given level of the information 

structure without changing the active path (e.g., the active link “Amplifiers and Linear” in the 

active path allows the display of “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors” without affecting the active path “Amplifiers and Linear—Comparators”) as 

shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

143. On information and belief, in the ’880 Accused Instrumentalities, a user may 

directly access one or more active links in the active path by selecting the active link (e.g., a user 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 69 of 100
- 70 -

may directly access “Comparators” in the “Amplifiers and Linear—Comparators” active path by 

selecting the “Comparators” link).

144. On information and belief, in the ’880 Accused Instrumentalities, the selection of 

an active link causes the active path to truncate to the selected active link (e.g., the selection of 

“Amplifiers and Linear” causes the active link “Automotive and Linear—Comparators” to 

truncate to “Automotive and Linear”).

145. On information and belief, the ’880 Accused Instrumentalities are further 

configured to provide pre-defined shortcuts to enable access to a given item in the information 

structure (e.g., the ’880 Accused Instrumentalities provide pre-defined shortcuts such as 

“Amplifiers and Linear” or “Comparators” in the collapsing menu enabling direct access to a 

given menu item in the information structure ), wherein selection of a pre-defined shortcut 

dynamically constructs an active path including one active link corresponding to each item 

necessary to navigate to the given item in the information structure (e.g., the active path is 

dynamically constructed upon selection of a predefined shortcut “Amplifiers and Linear” or 

“Comparators,” including one active link “Amplifiers and Linear” or “Comparators” 

corresponding to each item necessary to navigate to “Amplifiers and Linear” or “Comparators” 

in the information structure). 

146. On information and belief, in the ’880 Accused Instrumentalities, two functions 

are associated with at least one of said active links (e.g., displaying sibling menus such as 

“Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors” and 

directing user to certain content).

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 70 of 100
- 71 -

147. On information and belief, in the ’880 Accused Instrumentalities, execution of 

said functions is initiated by selecting different portions of said at least one of active link (e.g., 

by selecting “Automotive and Linear” of the active link “Automotive and Linear—Comparators”

to display sibling menus or direct user to certain content).. 

148. On information and belief, in the ’880 Accused Instrumentalities, at least two 

functions are associated with at least one of said active links (e.g., displaying sibling menus such 

as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors” and 

directing user to certain content).

149. Discovery is expected to uncover the full extent of Defendant’s infringement of 

the ’880 Patent beyond the ’880 Accused Instrumentalities already identified through public 

information. 

150. Upon information and belief, Defendant has induced and continues to induce 

others to infringe at least Claims 1, 3-10, 12-20 and 22 of the ’880 Patent under 35 U.S.C. 

§ 271(b) by, among other things, and with specific intent or willful blindness, actively aiding and 

abetting others to infringe, including but not limited to Defendant’s new, current, and prospective 

users, partners, customers and other third parties, whose use of the ’880 Accused 

Instrumentalities constitutes direct infringement of at least Claims 1, 3-10, 12-20 and 22 of the 

’880 Patent. 

151. In particular, Defendant’s actions that aid and abet others such as its new, current, 

and prospective users, partners, customers and third parties to infringe include advertising the 

’880 Accused Instrumentality. On information and belief, Defendant has engaged in such 

actions with specific intent to cause infringement or with willful blindness to the resulting 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 71 of 100
- 72 -

infringement because Defendant has had actual knowledge of the ’880 Patent and knowledge 

that its acts were inducing infringement of the ’880 Patent since at least the date Defendant 

received notice based on the filing of this Complaint that such activities infringed the ’880 

Patent. 

152. Defendant’s acts of inducement include, without limitation: providing the ’880 

Accused Instrumentalities to its new, current, and prospective users, partners, and customers, and 

other third parties and intending them to use the ’880 Accused Instrumentalities that enable 

and/or make use of content published therein; encouraging customers and other third parties to 

communicate directly with Defendant’s representatives about the ’880 Accused Instrumentalities 

and content published therein for purposes of technical assistance as well as sales and marketing 

(see, e.g., https://microchipsupport.force.com/s/ (providing consumers with a technical support 

portal through which technical issues and concerns regarding the ’880 Accused Instrumentalities 

can be addressed); see, e.g., https://microchipsupport.force.com/s/supportresources?tabName=Contact (providing contact information for technical support regarding the 

’880 Accused Instrumentalities); see also id. (providing a community platform for discussing the 

’880 Accused Instrumentalities or content published therein); see also 

https://www.facebook.com/microchiptechnology/ (encouraging customers and other third parties 

to use the ’880 Accused Instrumentalities to access content published therein (e.g., providing an 

URL (https://page.microchip.com/ewTiming.html?utm_campaign=EmbeddedWorld2020&utm_source=facebook.com&utm_medium

=Post&utm_content=SharePoint43895.5417&fbclid=IwAR2TVwazReb1Ul3TgRAgkutaZY3eE_ikA0HfXVGI6vjYdziBuNwa5BtxOo) to a “Timing and System Solutions” webpage 

that can be accessed using the ’880 Accused Instrumentalities)); see also 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 72 of 100
- 73 -

https://www.microchip.com/about-us/company-information/acquisitions (recommending 

investors and other third parties use the ’880 Accused Instrumentalities to access financial 

information relating to Microchip’s cooperate operations and acquisitions); see also 

https://www.microchip.com/documentlisting/financial-press-releases (for example, 

https://www.microchip.com/investor/Pressrelease/MCHP%20Announces%20Financial%20Resul

ts%20for%20Q3FY20.020420.pdf providing an URL (www.microchip.com) to the ’880 

Accused Instrumentalities); see also

https://twitter.com/MicrochipTech?ref_src=twsrc%5Egoogle%7Ctwcamp%5Eserp%7Ctwgr%5E

author, https://www.facebook.com/microchiptechnology/ and 

https://www.linkedin.com/posts/microchip-technology_from-simple-buffers-and-clockgenerators-activity-6641422443871383552-bbea (Defendant’s social media accounts promoting 

the use of ’880 Accused Instrumentalities through which various media content can be accessed); 

providing press releases encouraging customers and other third parties to use the ’880 Accused 

Instrumentalities to access content (for example, providing an URL (www.microchip.com) to the 

“Microchip” main webpage that can be accessed using the ’880 Accused Instrumentalities); and 

https://www.microchip.com/blog (providing blogs encouraging customers and other third parties 

to use the ’880 Accused Instrumentalities to access content (for example, providing an URL 

(https://www.microchip.com/wwwproducts/en/MCP6C02) to a “MCP6C02” webpage that can 

be accessed using the ’880 Accused Instrumentalities))). 

153. Defendant performed acts of inducement despite its actual knowledge since at 

least the filing date of this Complaint and its knowledge that the specific actions it actively 

induced and continues to actively induce on the part of its users, partners, and customers, and 

other third parties constitute infringement of the ’880 Patent. At the very least, because 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 73 of 100
- 74 -

Defendant has been, and remains, on notice of the ’880 Patent and the accused infringement, it 

has been, and remains, willfully blind regarding the infringement that it has induced and 

continues to induce.

154. On information and belief, Defendant has contributed to, and continues to 

contribute to, infringement of at least Claims 1, 3-10, 12-20 and 22 of the ’880 Patent pursuant to 

35 U.S.C. § 271(c) by providing the ’880 Accused Instrumentalities that have contributed, and 

continue to contribute, to the direct infringement of new, current, and prospective users, partners, 

customers and other third parties with the knowledge (at least as of the filing date of this 

Complaint) that the ’880 Accused Instrumentalities are especially made or adapted for use in an 

infringement of the ’880 Patent. For example, by providing the web pages, software, and 

computer equipment identified above, Defendant contributes to the direct infringement of users 

of said web pages, software, and computer equipment. The ’880 Accused Instrumentalities are 

material components or apparatuses for use in practicing the ’880 Patent and are not staple 

articles of commerce suitable for substantial non-infringing use.

155. For example, the ’880 Accused Instrumentalities provide a graphical user menu 

system through which a user can navigate an information structure or an apparatus for navigating 

an information structure according to the claimed invention(s). Defendant supplied, and 

continues to supply, the ’880 Accused Instrumentalities, or components or apparatuses thereof, 

with the knowledge of the ’880 Patent and with the knowledge that these components or 

apparatuses constitute critical and material parts of the claimed inventions of the ’880 Patent. 

Moreover, Defendant knows at least by virtue of its knowledge of its own products and services 

and the ’880 Patent that the ’880 Accused Instrumentalities are especially made and/or especially 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 74 of 100
- 75 -

adapted for use as claimed in the ’880 Patent and there is no substantial non-infringing use of 

these components or apparatuses.

156. Defendant has directly and indirectly infringed the ’880 Patent and is thus liable 

for infringement of the ’880 Patent pursuant to 35 U.S.C. § 271.

157. Plaintiffs have suffered, and continue to suffer, damages as a result of 

Defendant’s infringement of the ’880 Patent. 

158. Defendant has continued to infringe the ’880 Patent since at least the filing date of 

this Complaint, despite being on notice of the ’880 Patent and its infringement. Defendant has 

therefore infringed the ’880 Patent knowingly, willfully, deliberately, and in disregard of 

Plaintiffs’ patent rights since at least the filing date of this Complaint, at least by infringing with 

actual knowledge of its direct and indirect infringement or while remaining willfully blind to the 

fact of its direct and indirect infringement. As a result of at least this conduct, Plaintiffs are 

entitled to enhanced damages under 35 U.S.C. § 284 and to attorneys’ fees and costs under 35 

U.S.C. § 285.

159. Plaintiffs reserve the right to modify its infringement theories as discovery 

progresses in this case. Plaintiffs shall not be estopped for purposes of its infringement 

contentions or its claim constructions by the foregoing discussions on how the ’880 Accused 

Instrumentalities infringe the ’880 Patent. Plaintiffs intend only that the foregoing discussions 

satisfy the notice requirements of Rule 8(a)(2) of the Federal Rule of Civil Procedure, and that 

they should not be construed as Plaintiffs’ preliminary or final infringement contentions or 

preliminary or final claim construction positions.

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 75 of 100
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COUNT VI - INFRINGEMENT OF U.S. PATENT NO. 10,037,127

160. Plaintiffs incorporate and reallege the preceding paragraphs as if fully set forth 

herein.

161. The ’127 Patent is directed to systems and methods for navigating an information 

structure, as described and claimed in the ’880 Patent. 

162. The ’127 Patent is directed to systems and methods for navigating an information 

structure, as described and claimed in the ’127 Patent. 

163. Defendant has and continues to directly infringe at least Claims 1, 3-11, 13-14, 

16-24 and 26 of the ’127 Patent, in this judicial District and elsewhere in the United States, 

pursuant to 35 U.S.C. § 271(a), literally or under the doctrine of equivalents, by, among other 

things, by making, using, selling, offering to sell, and/or importing in or into the United States, 

without authority: (i) web pages and content to be interactively presented in browsers, including, 

without limitation, the web pages and content accessible via https://www.microchip.com/ and 

maintained on servers located in and/or accessible from the United States under the control of 

Defendant; (ii) software, including, without limitation, software that allows content to be 

interactively presented in and/or served to browsers; (iii) computer equipment, including, 

without limitation, computer equipment that stores, serves, and/or runs any of the foregoing or 

that allows navigating an information structure (hereinafter, the “’880 Accused 

Instrumentalities”) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 76 of 100
- 77 -

See, e.g., https://www.microchip.com/design-centers/automotive-solutions/automotiveapplications (last visited Feb. 10, 2020) (annotated). 

164. By way of example, the ’127 Accused Instrumentalities provide an apparatus for 

navigating an information structure as shown below:

See, e.g., https://www.microchip.com/design-centers/automotive-solutions/automotiveapplications (last visited Feb. 10, 2020) (annotated). 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 77 of 100
- 78 -

165. More specifically, the ’127 Accused Instrumentalities provide a graphical menu 

interface displaying the items of a given level of the information structure and enabling selection 

thereof (e.g., “Products” displays and enables selection of items of a given level, such as 

“Amplifiers and Linear”); dynamically construct an active path as a sequence of active links after 

an item of the information structure has been selected (e.g., the ’127 Accused Instrumentalities 

dynamically construct an active path (e.g., “Amplifiers and Linear—Comparators”) as a 

sequence of active links after an item of the information structure has been selected (e.g., as 

“Amplifiers and Linear” and “Comparators” are selected)); upon provisional selection of a given 

one of said active links, display one or more items on a given level of the information structure 

associated with said provisionally selected active link without affecting the active path (e.g., the 

’127 Accused Instrumentalities displays one or more items under “Amplifiers and Linear” such 

as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors” without 

affecting the active path “Amplifiers and Linear—Comparators”) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 78 of 100
- 79 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

166. Also, the ’127 Accused Instrumentalities allow a user to access an item in the 

information structure by selecting the item from the one or more items displayed by one of the 

active links on the active path, wherein a function is associated with at least one of said active 

links (e.g., the “Amplifiers and Linear” link in the active path “Amplifiers and Linear—

Comparators” allows a user to access an item in the information structure such as “Operational 

Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” “Comparators,” 

“Programmable Gain Amplifiers,” and “DC Power Current Monitors” by selecting from the one 

or more items displayed by “Amplifiers and Linear” where it is associated with a function such 

as displaying sibling menus or directing user to certain content) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 79 of 100
- 80 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

167. On information and belief, the ’127 Accused Instrumentalities are further 

configured to allow provisional selection of the one or more items to display one or more 

additional items on a given level of the information structure as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 80 of 100
- 81 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

168. On information and belief, in the ’127 Accused Instrumentalities, the one or more 

active links allow the display of one or more items on a given level of the information structure 

when a pointer is rolled over one of the active links (e.g., the active link “Amplifiers and Linear”

allows the display of items such as “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors” when a mouse is rolled over it) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 81 of 100
- 82 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

169. On information and belief, in the ’127 Accused Instrumentalities, the one or more 

active links allow the display of one or more items on a given level of the information structure 

when one of the active links is selected (e.g., the active link “Amplifiers and Linear” allows the 

display of items such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense 

Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current 

Monitors” when it is selected) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 82 of 100
- 83 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

170. On information and belief, in the ’127 Accused Instrumentalities, the one or more 

active links allow the display of one or more items on a given level of the information structure 

when a visual icon associated with one of the active links is selected (e.g., the active link 

“Amplifiers and Linear” allows the display of items such as “Operational Amplifiers,” 

“Instrumentation Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “Programmable Gain 

Amplifiers,” and “DC Power Current Monitors” when the “down arrow” icon is selected) as 

shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 83 of 100
- 84 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020) (annotated). 

171. On information and belief, in the ’127 Accused Instrumentalities, the active links 

in the active path allow the display of one or more items on a given level of the information 

structure without changing the active path (e.g., the active link “Amplifiers and Linear” in the 

active path allows the display of “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors” without affecting the active path “Amplifiers and Linear—Comparators”) as 

shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

172. On information and belief, in the ’127 Accused Instrumentalities, a user may 

directly access one or more active links in the active path by selecting the active link (e.g., a user 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 84 of 100
- 85 -

may directly access “Comparators” in the “Amplifiers and Linear—Comparators” active path by 

selecting the “Comparators” link).

173. On information and belief, in the ’127 Accused Instrumentalities, the selection of 

an active link causes the active path to truncate to the selected active link (e.g., the selection of 

“Amplifiers and Linear” causes the active link “Automotive and Linear—Comparators” to 

truncate to “Automotive and Linear”).

174. On information and belief, the ’127 Accused Instrumentalities further provide 

pre-defined shortcuts to enable access to a given item in the information structure (e.g., the ’127 

Accused Instrumentalities provide pre-defined shortcuts such as “Amplifiers and Linear” or 

“Comparators” in the collapsing menu enabling direct access to a given menu item in the 

information structure), wherein selection of a pre-defined shortcut dynamically constructs an 

active path including one active link corresponding to each item necessary to navigate to the 

given item in the information structure (e.g., the active path is dynamically constructed upon 

selection of a predefined shortcut “Amplifiers and Linear” or “Comparators,” including one 

active link “Amplifiers and Linear” or “Comparators” corresponding to each item necessary to 

navigate to “Amplifiers and Linear” or “Comparators” in the information structure). 

175. On information and belief, in the ’127 Accused Instrumentalities, two functions 

are associated with at least one of said active links (e.g., displaying sibling menus such as 

“Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors” and 

directing user to certain content).

176. On information and belief, in the ’127 Accused Instrumentalities, execution of 

said functions is initiated by selecting different portions of said at least one of active link (e.g., 

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 85 of 100
- 86 -

by selecting “Amplifiers and Linear” of the active link “Automotive and Linear—Comparators”

to display sibling menus or direct user to certain content). 

177. On information and belief, in the ’127 Accused Instrumentalities, at least two 

functions are associated with at least one of said active links (e.g., displaying sibling menus such 

as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors” and 

directing user to certain content).

178. On information and belief, the ’127 Accused Instrumentalities perform a method 

for navigating an information structure, comprising providing a graphical menu interface 

displaying the items of a given level of the information structure and enabling selection thereof 

(e.g., “Products” displays and enables selection of items of a given level, such as “Amplifiers 

and Linear”); dynamically construct an active path as a sequence of active links after an item of 

the information structure has been selected (e.g., the ’880 Accused Instrumentalities dynamically 

construct an active path (e.g., “Automotive and Linear—Comparators”) as a sequence of active 

links after an item of the information structure has been selected (e.g., as “Amplifiers and 

Linear” and “Comparators” are selected)); upon provisional selection of a given one of said 

active links, display one or more items on a given level of the information structure associated 

with said provisionally selected active link without affecting the active path (e.g., the ’880 

Accused Instrumentalities displays one or more items under “Amplifiers and Linear” such as 

“Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors” without 

affecting the active path “Amplifiers and Linear—Comparators”) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 86 of 100
- 87 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

179. On information and belief, in the ’127 Accused Instrumentalities allow a user to 

access an item in the information structure by selecting the item from the one or more items 

displayed by one of the active links on the active path, wherein a function is associated with at 

least one of said active links (e.g., the link “Amplifiers and Linear” in the active path 

“Amplifiers and Linear—Comparators” allows a user to access an item in the information 

structure such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense 

Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current 

Monitors” by selecting from the one or more items displayed by “Amplifiers and Linear” where 

at least one of the active links is associated with a function such as displaying sibling menus or 

directing user to certain content) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 87 of 100
- 88 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

180. On information and belief, in the ’127 Accused Instrumentalities, the active path 

is further configured to allow provisional selection of the one or more active links to display one 

or more additional items on a given level of the information structure as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 88 of 100
- 89 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

181. On information and belief, in the ’127 Accused Instrumentalities, the one or more 

active links allow the display of one or more items on a given level of the information structure 

when a pointer is rolled over one of the active links (e.g., the active link “Amplifiers and Linear”

allows the display of items such as “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors” when a mouse is rolled over it) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 89 of 100
- 90 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

182. On information and belief, in the ’127 Accused Instrumentalities, the one or more 

active links allow the display of one or more items on a given level of the information structure 

when one of the active links is selected (e.g., the active link “Amplifiers and Linear” allows the 

display of items such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense 

Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current 

Monitors” when it is selected) as shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 90 of 100
- 91 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

183. On information and belief, in the ’127 Accused Instrumentalities, the one or more 

active links allow the display of one or more items on a given level of the information structure 

when a visual icon associated with one of the active links is selected (e.g., the active link 

“Amplifiers and Linear” allows the display of items such as “Operational Amplifiers,” 

“Instrumentation Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “Programmable Gain 

Amplifiers,” and “DC Power Current Monitors” when the “down arrow” icon is selected) as 

shown below:

Case 6:20-cv-00245-ADA Document 1 Filed 03/27/20 Page 91 of 100
- 92 -

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020) (annotated). 

184. On information and belief, in the ’127 Accused Instrumentalities, the active links 

in the active path allow the display of one or more items on a given level of the information 

structure without changing the active path (e.g., the active link “Amplifiers and Linear” in the 

active path allows the display of “Operational Amplifiers,” “Instrumentation Amplifiers,” 

“Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power 

Current Monitors” without affecting the active path “Amplifiers and Linear—Comparators”) as 

shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited 

Feb. 10, 2020). 

185. On information and belief, in the ’127 Accused Instrumentalities, a user may 

directly access one or more active links in the active path by selecting the active link (e.g., a user 

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may directly access “Comparators” in the “Amplifiers and Linear—Comparators” active path by 

selecting the “Comparators” link).

186. On information and belief, in the ’127 Accused Instrumentalities, the selection of 

an active link causes the active path to truncate to the selected active link (e.g., the selection of 

“Amplifiers and Linear” causes the active link “Automotive and Linear—Comparators” to 

truncate to “Automotive and Linear”).

187. On information and belief, the ’127 Accused Instrumentalities are further 

configured to provide pre-defined shortcuts to enable access to a given item in the information 

structure (e.g., the ’127 Accused Instrumentalities provide pre-defined shortcuts such as 

“Amplifiers and Linear” or “Comparators” in the collapsing menu enabling direct access to a 

given menu item in the information structure ), wherein selection of a pre-defined shortcut 

dynamically constructs an active path including one active link corresponding to each item 

necessary to navigate to the given item in the information structure (e.g., the active path is 

dynamically constructed upon selection of a predefined shortcut “Amplifiers and Linear” or 

“Comparators,” including one active link “Amplifiers and Linear” or “Comparators” 

corresponding to each item necessary to navigate to “Amplifiers and Linear” or “Comparators” 

in the information structure). 

188. On information and belief, in the ’127 Accused Instrumentalities, two functions 

are associated with at least one of said active links (e.g., displaying sibling menus such as 

“Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors” and 

directing user to certain content).

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189. On information and belief, in the ’127 Accused Instrumentalities, execution of 

said functions is initiated by selecting different portions of said at least one of active link (e.g., 

by selecting “Amplifiers and Linear” of the active link “Automotive and Linear—Comparators” 

to display sibling menus or direct user to certain content). 

190. On information and belief, in the ’127 Accused Instrumentalities, at least two 

functions are associated with at least one of said active links (e.g., displaying sibling menus such 

as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors” and 

directing user to certain content).

191. Discovery is expected to uncover the full extent of Defendant’s infringement of 

the ’127 Patent beyond the ’127 Accused Instrumentalities already identified through public 

information. 

192. Upon information and belief, Defendant has induced and continues to induce 

others to infringe at least Claims 1, 3-11, 13-14, 16-24 and 26 of the ’127 Patent under 35 U.S.C. 

§ 271(b) by, among other things, and with specific intent or willful blindness, actively aiding and 

abetting others to infringe, including but not limited to Defendant’s new, current, and prospective 

users, partners, customers and other third parties, whose use of the ’127 Accused 

Instrumentalities constitutes direct infringement of at least Claims 1, 3-11, 13-14, 16-24 and 26 

of the ’127 Patent. 

193. In particular, Defendant’s actions that aid and abet others such as its new, current, 

and prospective users, partners, customers and third parties to infringe include advertising the 

’127 Accused Instrumentality. On information and belief, Defendant has engaged in such 

actions with specific intent to cause infringement or with willful blindness to the resulting 

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infringement because Defendant has had actual knowledge of the ’127 Patent and knowledge 

that its acts were inducing infringement of the ’127 Patent since at least the date Defendant 

received notice based on the filing of this Complaint that such activities infringed the ’127 

Patent. 

194. Defendant’s acts of inducement include, without limitation: providing the ’127 

Accused Instrumentalities to its new, current, and prospective users, partners, and customers, and 

other third parties and intending them to use the ’127 Accused Instrumentalities that enable 

and/or make use of content published therein; encouraging customers and other third parties to 

communicate directly with Defendant’s representatives about the ’127 Accused Instrumentalities 

and content published therein for purposes of technical assistance as well as sales and marketing 

(see, e.g., https://microchipsupport.force.com/s/ (providing consumers with a technical support 

portal through which technical issues and concerns regarding the ’127 Accused Instrumentalities 

can be addressed); see, e.g., https://microchipsupport.force.com/s/supportresources?tabName=Contact (providing contact information for technical support regarding the 

’127 Accused Instrumentalities); see also id. (providing a community platform for discussing the 

’127 Accused Instrumentalities or content published therein); see also 

https://www.facebook.com/microchiptechnology/ (encouraging customers and other third parties 

to use the ’127 Accused Instrumentalities to access content published therein (e.g., providing an 

URL (https://page.microchip.com/ewTiming.html?utm_campaign=EmbeddedWorld2020&utm_source=facebook.com&utm_medium

=Post&utm_content=SharePoint43895.5417&fbclid=IwAR2TVwazReb1Ul3TgRAgkutaZY3eE_ikA0HfXVGI6vjYdziBuNwa5BtxOo) to a “Timing and System Solutions” webpage 

that can be accessed using the ’127 Accused Instrumentalities)); see also 

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https://www.microchip.com/about-us/company-information/acquisitions (recommending 

investors and other third parties use the ’127 Accused Instrumentalities to access financial 

information relating to Microchip’s cooperate operations and acquisitions); see also 

https://www.microchip.com/documentlisting/financial-press-releases (for example, 

https://www.microchip.com/investor/Pressrelease/MCHP%20Announces%20Financial%20Resul

ts%20for%20Q3FY20.020420.pdf providing an URL (www.microchip.com) to the ’127 

Accused Instrumentalities); see also

https://twitter.com/MicrochipTech?ref_src=twsrc%5Egoogle%7Ctwcamp%5Eserp%7Ctwgr%5E

author, https://www.facebook.com/microchiptechnology/ and 

https://www.linkedin.com/posts/microchip-technology_from-simple-buffers-and-clockgenerators-activity-6641422443871383552-bbea (Defendant’s social media accounts promoting 

the use of ’127 Accused Instrumentalities through which various media content can be accessed); 

providing press releases encouraging customers and other third parties to use the ’127 Accused 

Instrumentalities to access content (for example, providing an URL (www.microchip.com) to the 

“Microchip” main webpage that can be accessed using the ’127 Accused Instrumentalities); and 

https://www.microchip.com/blog (providing blogs encouraging customers and other third parties 

to use the ’127 Accused Instrumentalities to access content (for example, providing an URL 

(https://www.microchip.com/wwwproducts/en/MCP6C02) to a “MCP6C02” webpage that can 

be accessed using the ’127 Accused Instrumentalities))). 

195. Defendant performed acts of inducement despite its actual knowledge since at 

least the filing date of this Complaint and its knowledge that the specific actions it actively 

induced and continues to actively induce on the part of its users, partners, and customers, and 

other third parties constitute infringement of the ’127 Patent. At the very least, because 

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Defendant has been, and remains, on notice of the ’127 Patent and the accused infringement, it 

has been, and remains, willfully blind regarding the infringement that it has induced and 

continues to induce.

196. On information and belief, Defendant has contributed to, and continues to 

contribute to, infringement of at least Claims 1, 3-11, 13-14, 16-24 and 26 of the ’127 Patent 

pursuant to 35 U.S.C. § 271(c) by providing the ’127 Accused Instrumentalities that have 

contributed, and continue to contribute, to the direct infringement of new, current, and 

prospective users, partners, customers and other third parties with the knowledge (at least as of 

the filing date of this Complaint) that the ’127 Accused Instrumentalities are especially made or 

adapted for use in an infringement of the ’127 Patent. For example, by providing the web pages, 

software, and computer equipment identified above, Defendant contributes to the direct 

infringement of users of said web pages, software, and computer equipment. The ’127 Accused 

Instrumentalities are material components or apparatuses for use in practicing the ’127 Patent 

and are not staple articles of commerce suitable for substantial non-infringing use.

197. For example, the ’127 Accused Instrumentalities provide a graphical user menu 

system through which a user can navigate an information structure or an apparatus for navigating 

an information structure according to the claimed invention(s). Defendant supplied, and 

continues to supply, the ’127 Accused Instrumentalities, or components or apparatuses thereof, 

with the knowledge of the ’127 Patent and with the knowledge that these components or 

apparatuses constitute critical and material parts of the claimed inventions of the ’127 Patent. 

Moreover, Defendant knows at least by virtue of its knowledge of its own products and services 

and the ’127 Patent that the ’127 Accused Instrumentalities are especially made and/or especially 

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adapted for use as claimed in the ’127 Patent and there is no substantial non-infringing use of 

these components or apparatuses.

198. Defendant has directly and indirectly infringed the ’127 Patent and is thus liable 

for infringement of the ’127 Patent pursuant to 35 U.S.C. § 271.

199. Plaintiffs have suffered, and continue to suffer, damages as a result of 

Defendant’s infringement of the ’127 Patent. 

200. Defendant has continued to infringe the ’127 Patent since at least the filing date of 

this Complaint, despite being on notice of the ’127 Patent and its infringement. Defendant has 

therefore infringed the ’127 Patent knowingly, willfully, deliberately, and in disregard of 

Plaintiffs’ patent rights since at least the filing date of this Complaint, at least by infringing with 

actual knowledge of its direct and indirect infringement or while remaining willfully blind to the 

fact of its direct and indirect infringement. As a result of at least this conduct, Plaintiffs are 

entitled to enhanced damages under 35 U.S.C. § 284 and to attorneys’ fees and costs under 35 

U.S.C. § 285.

201. Plaintiffs reserve the right to modify its infringement theories as discovery 

progresses in this case. Plaintiffs shall not be estopped for purposes of its infringement 

contentions or its claim constructions by the foregoing discussions on how the ’127 Accused 

Instrumentalities infringe the ’127 Patent. Plaintiffs intend only that the foregoing discussions 

satisfy the notice requirements of Rule 8(a)(2) of the Federal Rule of Civil Procedure, and that 

they should not be construed as Plaintiffs’ preliminary or final infringement contentions or 

preliminary or final claim construction positions.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs demand judgment for itself and against Defendant as follows:

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a. A judgment that Defendant has infringed, and continues to infringe, one or more 

claims of each of the Asserted Patents;

b. A judgment that Defendant has induced infringement, and continues to induce 

infringement, of one or more claims of each of the Asserted Patents; 

c. A judgment that Defendant has contributed to, and continues to contribute, to the 

infringement of one or more claims of each of the Asserted Patents; 

d. A judgment that Defendant has willfully infringed one or more claims of each of 

the Asserted Patents;

e. A judgment awarding Plaintiffs all damages adequate to compensate for 

Defendant’s infringement, and in no event less than a reasonable royalty for Defendant’s acts of 

infringement, including all pre-judgment and post-judgment interest at the maximum rate 

allowed by law; 

f. A judgment awarding Plaintiffs treble damages pursuant to 35 U.S.C. § 284 as a 

result of Defendant’s willful conduct; 

g. A judgment and order finding that this is an exceptional case within the meaning 

of 35 U.S.C. § 285 and awarding Plaintiffs their reasonable attorneys’ fees; and 

h. A judgment awarding Plaintiffs such other relief as the Court may deem just and 

equitable.

DEMAND FOR JURY TRIAL

Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiffs demand a trial 

by jury of this action.

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Dated: March 27, 2020 DEVLIN LAW FIRM LLC

/s/ Alex Chan

Timothy Devlin 

tdevlin@devlinlawfirm.com

Alex Chan 

Texas State Bar No. 24108051

achan@devlinlawfirm.com

1526 Gilpin Ave.

Wilmington, Delaware 19806

Telephone: (302) 449-9010

Facsimile: (302) 353-4251

Attorneys for Plaintiffs,

Caddo Systems, Inc. and 511 Technologies, Inc.

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