1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

GREENTHREAD, LLC 

Plaintiff, 

vs. 

OMNIVISION TECHNOLOGIES INC., 

Defendant. 

Civil Action No. 2:23-cv-212 

JURY TRIAL DEMANDED 

ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 

Plaintiff Greenthread, LLC (“Greenthread” or “Plaintiff”) files this Original Complaint 

against OmniVision Technologies Inc., (“OmniVision” or “Defendant”) and hereby alleges as 

follows: 

THE NATURE OF THE ACTION 

1. This is a patent infringement action. Two related actions are pending in this court 

for infringement of the same patents: Greenthread, LLC v. OSRAM GMBH et al., 23-cv-00179-

JRG (E.D. Tex.) and Greenthread, LLC v Texas Instruments Incorporated, 23-cv-00157-JRG 

(E.D. Tex.). This Court has already construed the claims of the patents-in-suit and/or patents of 

the same family in Greenthread, LLC v. Samsung Electronics Co., Ltd. et al., 19-cv-00147-JRG 

(E.D. Tex.). See Dkt. 67. 

2. Greenthread owns a family of patents related to transistors and other components 

of integrated semiconductor devices. Greenthread’s patented inventions describe semiconductor 

devices that employ graded dopants and well regions for creating electric fields for aiding and/or 

limiting the movement of carriers to (or from) the semiconductor surface to (or from) the 

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semiconductor substrate. These inventions improve semiconductor devices by (1) creating faster, 

more efficient, and more reliable processors, logic devices, and image sensors; and (2) allowing 

manufacturers to scale down the feature size of their semiconductor products. 

3. Defendant has infringed and continues to infringe six Greenthread patents: U.S. 

Patent Nos. 8,421,195 (“the ’195 Patent”), 9,190,502 (“the ’502 Patent”), 10,510,842 (“the ’842 

Patent”), 10,734,481 (“the ’481 Patent”), 11,121,222 (“the ’222 Patent”), and 11,316,014 (“the 

’014 Patent”), (collectively “the Greenthread Patents”), copies of which are attached hereto as 

Exhibits 1-6, respectively. Defendant has infringed and continue to infringe the Greenthread 

Patents by making, using, selling, offering for sale, and/or importing into the United States, 

semiconductor devices with infringing graded dopant regions and/or electronic products 

containing the same. 

THE PARTIES 

4. Plaintiff Greenthread, LLC (“Greenthread”) is a limited liability company 

organized and existing under the laws of Texas, having its principal place of business at 7424 

Mason Dells Drive, Dallas, Texas 75230-3244. 

5. Defendant OmniVision Technologies, Inc. is a corporation organized and existing 

under the laws of Delaware. Defendant may be served with process by serving its registered agent, 

the Corporation Trust Company, at 1209 Orange Street, Wilmington, Delaware, 19801. 

6. OmniVision designs and develops digital imaging products for use in mobile 

phones, security & surveillance, automotive, computing, medical, and emerging applications. 

OmniVision describes itself as a “global fabless semiconductor organization” who has “enabled 

smoother human/machine interfacing solutions within the automotive, medical, security & 

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surveillance, computing, mobile phone, and emerging technology spaces.”1 

7. OmniVision controls the www.ovt.com internet domain. 

8. OmniVision designs, tests, imports into the United States, uses, sells, and offers to 

sell OmniVision Accused Products, which occurs in the United States. OmniVision has employees 

throughout the United States including responsible for these functions, including in Texas, 

California, Colorado, Illinois, and Michigan.2 

9. During Omnivision’s markeing, testing, and quality control, OmniVision uses and 

sells sample products of the Omnivision Accused Products in the United States.3 Those uses of 

the OmniVision Accused Products are essential to its ability to make sales to customers worldwide, including in the United States. 

 

1

 https://www.ovt.com/company/about-us/ 

2

 https://www.ovt.com/company/contact-us/ 

3

 https://www.ovt.com/partners/ 

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10. Further, OmniVision partners with United States authorized distributors to sell 

OmniVision Accused Products in the United States and directs potential U.S. consumers to 

purchase OmniVision products through these U.S. distributors and “representatives” on its 

website.4

 

 

4 See, e.g., https://www.ovt.com/contact-sales/distribution-channels; see also 

https://www.arrow.com/en/manufacturers/omnivision-technologies/view-all

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11. OmniVision sells OmniVision Accused Products in the United States through its 

distributors on OmniVision-branded product pages. 

12. OmniVision’s U.S.-based employees include personnel responsible for sales of 

OmniVision Accused Products to the U.S. automotive industry. 

13. OmniVision maintains an office in this district at 1255 W. 15th Street, Suite 370 

Plano, TX 75075-4216. On information and belief, OmniVision uses its Plano office to serve and 

make infringing sales of the Accused Products to its customer Texas Instruments Inc. (“Texas 

Instruments”) in this district.5

 

5

 https://www.ti.com/about-ti/company/ti-at-a-glance/manufacturing/richardson.html#moreinformation 

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14. Texas Instruments incorporates OmniVision Accused Products into its products, 

including, on information and belief at Texas Instruments facilities in this district. 

15. For example, Texas Instruments markets an “Automotive 1.3-MP Low-Cost 

Camera Module Reference Design With YUV422, PMIC, FPD-Link III, and POC” which includes 

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an OmniVision Accused Product, a “1.3-MP OX01F10 image sensor from Omnivision.”6 

16. For example, Texas Instruments also markets a “Low-Power Wireless Camera 

Reference Design for Extended Battery Life” stating that it includes an OmniVision Accused 

Product: “This design utilizes the OmniVision OA7000 to enable secured live video streaming 

with a resolution of up to 1080p at 48 FPS (1920 × 1080).”7

 

6

 https://www.ti.com/lit/ug/tidubf0/tidubf0.pdf?ts=1683552290038 

7

https://www.ti.com/lit/ug/tiduez4/tiduez4.pdf?ts=1683652725026&ref_url=https%253A%252F

%252Fwww.google.com%252F 

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17. For example, Texas Instruments also markets a “ADAS 8-Channel Sensor Fusion 

Hub Reference Design With Two 4-Gbps Quad Deserializers” which is “built around ... an 

OmniVision OV2775 imager,” which is an OmniVision Accused Product. 

SUBJECT MATTER JURISDICTION 

18. This action arises under the patent laws of the United States, namely 35 U.S.C. 

§§ 271, 281, and 284-285, among others. 

19. This court has subject matter jurisdiction over the patent infringement claims 

asserted in this case under 28 U.S.C. §§ 1331 and 1338(a). 

PERSONAL JURISDICTION AND VENUE 

20. This Court has specific personal jurisdiction over Defendant because it has 

committed acts within this District giving rise to this action (including acts of infringement) and 

has established minimum contacts with this forum such that the exercise of jurisdiction over 

Defendant would not offend traditional notions of fair play and substantial justice. Such acts 

include selling, offering to sell, demonstrating, and marketing OmniVision Accused Products to 

Texas Instruments in this district. 

21. Venue is proper under 28 U.S.C. §§ 1391(b) and 1400(b), because OmniVision has 

a regular and established place of business in this district, including at 1255 W. 15th Street, Suite 

370 Plano, TX 75075-4216 and has committed acts of infringement in this district, including sales 

to Texas Instruments. 

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22. This Court has personal jurisdiction over OmniVision in accordance with the Texas 

Long Arm Statute, Tex. Civ. Prac. & Rem. Code § 17.042, because, among other things, 

OmniVision has (1) committed acts of infringement in Texas, including, on information and belief, 

selling, offering to sell, and demonstrating OmniVision Accused Products in Texas, including to 

Texas Instrument, and (2) recruited Texas residents for employment, including at OmniVision’s 

facility in Plano Texas. 

23. “OmniVision Accused Products” are products accused of meeting the claim 

limitations of a Greenthread Patent in this suit. OmniVision designs, manufactures, sells, and uses 

semiconductor devices containing transistors and other structures that infringe the Greenthread 

Patents in the United States. 

24. The infringing structures within semiconductor devices identified in Exhibit 8 have 

application, not only in the product identified in Exhibit 8 (OV24A1Q), but in many types of 

devices designed and manufactured by OmniVision, including image sensors, ASICs, 

CameraCubeChip®, LCOS, power management, touch & display, OVMed® ISP, and OVMed® 

cable module devices.8

 To obtain the benefits of the claimed technology, on information and 

belief, OmniVision incorporates the infringing structures similar to those described in Exhibit 8 

into transistors in its other products, including ASICs, CameraCubeChip®, LCOS, power 

management, touch & display, OVMed® ISP, and OVMed® cable module devices. The 

infringement described in Exhibit 8 is therefore exemplary of infringement by transistors in other 

OmniVision products. 

25. Exhibit 8 demonstrates how exemplary OmniVision Accused Products meet the 

claim limitations of Greenthread Patents and is herein incorporated by reference. 

 

8 https://www.ovt.com/company/about-us/ 

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THE GREENTHREAD PATENTS 

26. On April 16, 2013, the U.S. Patent and Trademark Office duly and legally issued 

U.S. Patent No. 8,421,195 (“the ’195 Patent”), entitled “Semiconductor Devices with Graded 

Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed January 

12, 2007. The ’195 Patent claims priority from U.S. Patent Application No. 10/934,915,9 filed on 

September 3, 2004. A true and correct copy of the ’195 Patent is attached hereto as Exhibit 1 and 

incorporated herein by reference. 

27. On November 17, 2015, the U.S. Patent and Trademark Office duly and legally 

issued U.S. Patent No. 9,190,502 (“the ’502 Patent”), entitled “Semiconductor Devices with 

Graded Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed 

October 16, 2014. The ’502 Patent claims priority from U.S. Patent Application No. 10/934,915,10

filed on September 3, 2004. A true and correct copy of the ’502 Patent is attached hereto as Exhibit 

2 and incorporated herein by reference. 

28. On December 17, 2019, the U.S. Patent and Trademark Office duly and legally 

issued U.S. Patent No. 10,510,842 (“the ’842 Patent”), entitled “Semiconductor Devices with 

Graded Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed 

on May 9, 2017. The ’842 Patent claims priority from U.S. Patent Application No. 10/934,915,11

filed on September 3, 2004. A true and correct copy of the ’842 Patent is attached hereto as Exhibit 

3 and incorporated herein by reference. 

29. On August 4, 2020, the U.S. Patent and Trademark Office duly and legally issued 

 

9

 Pub. No. US 2006/0049464. 

10 Pub. No. US 2006/0049464. 

11 Pub. No. US 2006/0049464. 

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U.S. Patent No. 10,734,481 (“the ’481 Patent”), entitled “Semiconductor Devices with Graded 

Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed on 

December 17, 2019. The ’481 Patent claims priority from U.S. Patent Application No. 

10/934,915,12 filed on September 3, 2004. A true and correct copy of the ’481 Patent is attached 

hereto as Exhibit 4 and incorporated herein by reference. 

30. On September 14, 2021, the U.S. Patent and Trademark Office duly and legally 

issued U.S. Patent No. 11,121,222 (“the ’222 Patent”), entitled “Semiconductor Devices with 

Graded Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed 

on July 27, 2020. The ’222 Patent claims priority from U.S. Patent Application No. 10/934,915,13

filed on September 3, 2004. A true and correct copy of the ’222 Patent is attached hereto as Exhibit 

5 and incorporated herein by reference. 

31. On April 26, 2022, the U.S. Patent and Trademark Office duly and legally issued 

U.S. Patent No. 11,316,014 (“the ’014 Patent”), entitled “Semiconductor Devices with Graded 

Dopant Regions,” listing Dr. Mohan Rao as the inventor, from a patent application filed on July 9, 

2021. The ’014 Patent claims priority from U.S. Patent Application No. 10/934,915,14 filed on 

September 3, 2004. A true and correct copy of the ’014 Patent is attached hereto as Exhibit 6 and 

incorporated herein by reference. 

32. The ’195, ’502, ’842, ’481, ’222, and ’014 Patents are collectively referred to as 

the “Greenthread Patents.” 

33. Greenthread exclusively owns all rights, title, and interest in the Greenthread 

 

12 Pub. No. US 2006/0049464. 

13 Pub. No. US 2006/0049464. 

14 Pub. No. US 2006/0049464. 

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Patents necessary to bring this action, including the right to recover past and future damages. 

Certain of the Greenthread Patents were previously owned by Dr. G.R. Mohan Rao (“Dr. Rao”). 

On April 27, 2015, Dr. Rao assigned to Greenthread the then-issued Greenthread Patents and all 

related “continuations, continuations-in-part and extensions of said Applications and Patents and 

any pending applications or issued patents that directly claim or are amended to claim priority to 

any of the Applications or Patents.” Dr. Rao’s assignment was recorded with the U.S. Patent and 

Trademark Office on May 13, 2015, and again on July 22, 2021, and is attached hereto as Exhibit 

7. Greenthread has therefore owned all rights to the Greenthread Patents necessary to bring this 

action throughout the period of Defendant’s infringement and still owns those rights to the 

Greenthread Patents. 

34. Defendant is not currently licensed to practice the Greenthread Patents. 

35. The Greenthread Patents are valid and enforceable. 

FACTUAL BACKGROUND 

36. Dr. G.R. Mohan Rao (“Dr. Rao”), the sole inventor of the Greenthread Patents, has 

been an innovator in the semiconductor industry since the 1960s. He is a named inventor on more 

than 100 Patents worldwide and authored numerous technical publications over the last 50 years. 

37. In September 1968, Dr. Rao received a Ph.D. in physics with a specialization in 

electronics from Andhra University in Waltair, India. He then traveled to the United States to 

attend a graduate program in physics at the University of Cincinnati. 

38. After learning of an opportunity to work with Professor William Carr of Southern 

Methodist University (“SMU”), Dr. Rao transferred to SMU where he earned a Ph.D. in Electrical 

Engineering. While there, he worked in the SMU laboratory with Jack Kilby of Texas Instruments 

(a pioneering electrical engineer who would later receive a Nobel Prize for his work), on metaloxide-silicon transistors (“MOS devices”), which are used for switching and amplifying electronic 

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signals in electronic devices. MOS devices form the basis of modern electronics and are the most 

widely used semiconductor devices in the world. The U.S. Patent and Trademark Office has called 

this device a “groundbreaking invention that transformed life and culture around the world.”15 Dr. 

Rao built these devices from scratch while a graduate student at SMU. 

39. Through his mentor, Jack Kilby, Dr. Rao interviewed with—and was ultimately 

hired by—Texas Instruments to continue his work on MOS devices in 1972. Dr. Rao worked at 

Texas Instruments for the next twenty-two years, rising from an engineer to a Senior Fellow. At 

that time, Texas Instruments had only 12 Senior Fellows out of approximately 20,000 engineers. 

Eventually, Dr. Rao moved into a management position at Texas Instruments, ultimately becoming 

a Senior Vice President in 1985. 

40. At Texas Instruments, Dr. Rao received his first patent while working in a process 

and product engineering capacity to solve a production problem with Texas Instruments’ 4-kilobit 

RAM product. That patent was merely the beginning of Dr. Rao’s long inventive career. Indeed, 

from the late 1970s through the mid-1980s, Dr. Rao worked on or managed projects relating to 

Texas Instruments’ 64kb RAM, 256Kb RAM, 1Mb RAM, 4 Mb RAM, EEPROM, SRAM, and 

microcontrollers. For that work, Dr. Rao received numerous additional U.S. Patents. 

41. The USPTO was not the only organization to recognize Dr. Rao’s achievements. 

Some of Dr. Rao’s work at Texas Instruments was so remarkable that it has been credited in 

multiple exhibits in the National Museum of American History at the Smithsonian Institution.16 

For example, the Smithsonian has displayed Texas Instruments’ experimental 1-megabit CMOS 

DRAM, produced in April 1985 under Dr. Rao’s leadership, and credited Dr. Rao for the 

 

15 https://www.uspto.gov/about-us/news-updates/remarks-director-iancu-2019-internationallectual-property-conference 

16 http://smithsonianchips.si.edu/texas/wafer.htm 

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achievement.17 

42. In 1994, Dr. Rao left Texas Instruments for Cirrus Logic. During his two-year 

tenure at Cirrus Logic, he received more U.S. Patents relating to his work on integrated graphics 

controllers and memory. 

43. In 1996, Dr. Rao started a company called Silicon Aquarius. Through a relationship 

between Silicon Aquarius and Matsushita, Dr. Rao led a design team in working on a 256Mb 

DRAM chip. After Silicon Aquarius ceased operations, Dr. Rao did consulting work for a number 

of different consulting companies and devoted much of his free time to thinking about various 

challenges and problems with which the semiconductor industry had struggled for years. 

44. In 2003, Dr. Rao and Philip John founded Greenthread to continue Dr. Rao’s 

 

17 http://smithsonianchips.si.edu/texas/t_360.htm 

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pioneering work. A focal point of Dr. Rao’s research was poor refresh time and the related 

problem of how to deal with and control the movement of both wanted and unwanted carriers in 

semiconductor devices, including memory and logic devices. Dr. Rao realized that graded dopants 

could be used to create a “drift layer” and other structures to facilitate the movement—in an 

upward or downward direction, as appropriate—of carriers from the semiconductor surfaces down 

into the substrate and vice versa. It was Dr. Rao’s work on this problem that culminated in the 

Greenthread Patents. 

45. Dr. Rao resides in this district. 

OMNIVISION’S INFRINGEMENT 

46. OmniVision has directly infringed, and continues to infringe, one or more claims 

of each of the Greenthread Patents through making, using, offering to sell, selling within the United 

States, and/or importing into the United States semiconductor products, including OV24A1Q, that 

practice the claimed inventions (i.e., the OmniVision Accused Products). A non-exhaustive, 

exemplary list of the types or categories of products or devices that infringe are further identified 

in Exhibit 8. 

47. Further, in concert with its authorized distributors and customers, OmniVision 

causes or induces infringing accused products to be made, used, offered to be sold, sold within the 

United States, and/or imported into the United States. Omnivision has obtained knowledge of 

Greenthread’s patents and its infringement at least through the filing of this Complaint. 

48. As shown in Exhibit 8, the exemplary OmniVision Accused Product, OV24A1Q, 

meets each and every element of at least one claim of the Greenthread Patents. 

49. Upon information and belief, OmniVision fabricates and designs the OmniVision 

Accused Products using similar designs according to a limited number of processes, many or all 

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of which utilize substantially similar process steps, including process steps for creating regions 

with graded dopant concentrations, because the invention would have application in those 

categories of products, for example by improving switching time in transistors in the OmniVision 

Accused Products. Upon information and belief, the OmniVision Accused Products are in relevant 

part substantially similar to the exemplary OV24A1Q shown in Exhibit 8, particularly with regard 

to the manner in which the exemplary OV24A1Q includes and utilizes regions with graded dopant 

concentrations. Exhibit 8 is thus illustrative of the manner in which the OmniVision Accused 

Products meet the claim limitations of the Greenthread Patents.18 

COUNT I: INFRINGEMENT OF U.S. PATENT NO. 8,421,195 

50. Greenthread incorporates by reference and re-alleges all of the foregoing 

paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein. 

51. The following allegations are based on publicly available information and a 

 

18 This Court already interpreted and adopted Greenthread’s claim construction in Greenthread, 

LLC v. Samsung Electronics Co., Ltd. et al., Case No. 2:19-cv-00147-JRG (E.D. Tex.). See Dkt. 

67. Multiple other courts have also upheld Greenthread’s construction of the Greenthread Patents 

in related matters. In Greenthread, LLC v. Intel Corp., et al., Case No. 6:22-cv-00105-ADA (W.D. 

Tex.), the Western District of Texas similarly issued a preliminary claim construction order 

adopting Greenthread’s construction. See Dkt. 36-21 in Greenthread, LLC v. Intel Corp., Case No. 

3:22-cv-02001-JR (attaching as an exhibit the Western District of Texas’s preliminary claim 

construction order in a status update before the District of Oregon). The claims in this matter 

against Intel were ultimately severed and transferred to Oregon, and the District of Oregon adopted 

the Western District of Texas’ preliminary claim construction. See Dkt. 44 (“The Court also finds 

that the WDTX’s preliminary constructions and summary judgment rulings are neither legally 

incorrect nor factually distinguishable. As a result, the Court adopts the WDTX’s preliminary 

constructions and summary judgment rulings as its own. . .”). The Western District of Texas also 

denied Defendants’ motions to dismiss and for summary judgment on similar grounds. See Dkt. 

36-22 in Greenthread, LLC v. Intel Corp., Case no. 3:22-cv-02001-JR (attaching as an exhibit the 

Western District of Texas’ denial of Defendants’ motion for summary judgment); Dkt. 110 in 

Greenthread LLC v. Intel Corp., Case No. 6:22-cv-00105-ADA (W.D. Tex.). The District of 

Oregon similarly adopted these rulings. See Dkt. 44 in Greenthread, LLC v. Intel Corp., Case no. 

3:22-cv-02001-JR. 

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reasonable investigation of the structure and operation of the OmniVision Accused Products. 

Greenthread reserves the right to modify this description, including, for example, on the basis of 

information about the OmniVision Accused Products that it obtains during discovery. 

52. Defendant’s infringement has damaged and continues to damage Greenthread in an 

amount yet to be determined, of at least a reasonable royalty. 

53. As alleged above and in Exhibit 8, the products analyzed in Exhibit 8 meet each 

and every one of the claim limitations of at least one claim of the ’195 Patent. 

54. As alleged above, the products analyzed in Exhibit 8 are exemplary of the 

OmniVision Accused Products. 

55. As alleged above, Defendant has infringed and continue to infringe at least one 

claim of the ’195 Patent by making, using, offering to sell, selling within the United States, and/or 

importing into the United States OmniVision Accused Products. 

56. As alleged above, Defendant induces infringement of at least one claim of the ’195 

Patent by designing and marketing infringing products for sale, use, and importation into the 

United States. 

57. Defendant’s infringement has damaged and continues to damage Greenthread in an 

amount yet to be determined, of at least a reasonable royalty. 

COUNT II: INFRINGEMENT OF U.S. PATENT NO. 9,190,502 

58. Greenthread incorporates by reference and re-alleges all of the foregoing 

paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein. 

59. The following allegations are based on publicly available information and a 

reasonable investigation of the structure and operation of the OmniVision Accused Products. 

Greenthread reserves the right to modify this description, including, for example, on the basis of 

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information about the OmniVision Accused Products that it obtains during discovery. 

60. As alleged above and in Exhibit 8, the products analyzed in Exhibit 8 meet each 

and every one of the claim limitations of at least one claim of the ’502 Patent. 

61. As alleged above, the products analyzed in Exhibit 8 are exemplary of the 

OmniVision Accused Products. 

62. As alleged above, Defendant has infringed and continue to infringe at least one 

claim of the ’502 Patent by making, using, offering to sell, selling within the United States, and/or 

importing into the United States OmniVision Accused Products. 

63. As alleged above, Defendant induces infringement of at least one claim of the ’502 

Patent by designing and marketing infringing products for sale, use, and importation into the 

United States. 

64. Defendant’s infringement has damaged and continues to damage Greenthread in an 

amount yet to be determined, of at least a reasonable royalty. 

COUNT III: INFRINGEMENT OF U.S. PATENT NO. 10,510,842 

65. Greenthread incorporates by reference and re-alleges all of the foregoing 

paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein. 

66. The following allegations are based on publicly available information and a 

reasonable investigation of the structure and operation of the OmniVision Accused Products. 

Greenthread reserves the right to modify this description, including, for example, on the basis of 

information about the OmniVision Accused Products that it obtains during discovery. 

67. As alleged above and in Exhibits 8, the products analyzed in Exhibit 8 meet each 

and every one of the claim limitations of at least one claim of the ’842 Patent. 

68. As alleged above, the products analyzed in Exhibit 8 are exemplary of the 

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OmniVision Accused Products. 

69. As alleged above, Defendant has infringed and continue to infringe at least one 

claim of the ’842 Patent by making, using, offering to sell, selling within the United States, and/or 

importing into the United States OmniVision Accused Products. 

70. As alleged above, Defendant induces infringement of at least one claim of the ’842 

Patent by designing and marketing infringing products for sale, use, and importation into the 

United States. 

71. Defendant’s infringement has damaged and continues to damage Greenthread in an 

amount yet to be determined, of at least a reasonable royalty. 

COUNT IV: INFRINGEMENT OF U.S. PATENT NO. 10,734,481 

72. Greenthread incorporates by reference and re-alleges all of the foregoing 

paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein. 

73. The following allegations are based on publicly available information and a 

reasonable investigation of the structure and operation of the OmniVision Accused Products. 

Greenthread reserves the right to modify this description, including, for example, on the basis of 

information about the OmniVision Accused Products that it obtains during discovery. 

74. As alleged above and in Exhibits 8, the products analyzed in Exhibit 8 meet each 

and every one of the claim limitations of at least one claim of the ’481 Patent. 

75. As alleged above, the products analyzed in Exhibit 8 are exemplary of the 

OmniVision Accused Products. 

76. As alleged above, Defendant has infringed and continue to infringe at least one 

claim of the ’481 Patent by making, using, offering to sell, selling within the United States, and/or 

importing into the United States OmniVision Accused Products. 

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77. As alleged above, Defendant induces infringement of at least one claim of the ’481 

Patent by designing and marketing infringing products for sale, use, and importation into the 

United States. 

78. Defendant’s infringement has damaged and continues to damage Greenthread in an 

amount yet to be determined, of at least a reasonable royalty. 

COUNT V: INFRINGEMENT OF U.S. PATENT NO. 11,121,222 

79. Greenthread incorporates by reference and re-alleges all of the foregoing 

paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein. 

80. The following allegations are based on publicly available information and a 

reasonable investigation of the structure and operation of the OmniVision Accused Products. 

Greenthread reserves the right to modify this description, including, for example, on the basis of 

information about the OmniVision Accused Products that it obtains during discovery. 

81. As alleged above and in Exhibit 8, the products analyzed in Exhibit 8 meet each 

and every one of the claim limitations of at least one claim of the ’222 Patent. 

82. As alleged above, the products analyzed in Exhibit 8 are exemplary of the 

OmniVision Accused Products. 

83. As alleged above, Defendant has infringed and continue to infringe at least one 

claim of the ’222 Patent by making, using, offering to sell, selling within the United States, and/or 

importing into the United States OmniVision Accused Products. 

84. As alleged above, Defendant induces infringement of at least one claim of the ’222 

Patent by designing and marketing infringing products for sale, use, and importation into the 

United States. 

85. Defendant’s infringement has damaged and continues to damage Greenthread in an 

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amount yet to be determined, of at least a reasonable royalty. 

COUNT VI: INFRINGEMENT OF U.S. PATENT NO. 11,316,014 

86. Greenthread incorporates by reference and re-alleges all of the foregoing 

paragraphs of this Complaint and exhibits attached hereto as if fully set forth herein. 

87. The following allegations are based on publicly available information and a 

reasonable investigation of the structure and operation of the OmniVision Accused Products. 

Greenthread reserves the right to modify this description, including, for example, on the basis of 

information about the OmniVision Accused Products that it obtains during discovery. 

88. As alleged above and in Exhibits 8, the products analyzed in Exhibit 8 meet each 

and every one of the claim limitations of at least one claim of the ’014 Patent. 

89. As alleged above, the products analyzed in Exhibit 8 are exemplary of the 

OmniVision Accused Products. 

90. As alleged above, Defendant has infringed and continue to infringe at least one 

claim of the ’014 Patent by making, using, offering to sell, selling within the United States, and/or 

importing into the United States OmniVision Accused Products. 

91. As alleged above, Defendant induces infringement of at least one claim of the ’014 

Patent by designing and marketing infringing products for sale, use, and importation into the 

United States. 

92. Defendant’s infringement has damaged and continues to damage Greenthread in an 

amount yet to be determined, of at least a reasonable royalty. 

DAMAGES 

93. As a result of OmniVision’s acts of infringement, Greenthread has suffered and 

continues to suffer actual and consequential damages. However, Greenthread does not yet know 

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the full extent of the infringement and the amount of damages cannot be ascertained except through 

discovery and special accounting. To the fullest extent permitted by law, Greenthread seeks 

recovery of damages at least for reasonable royalties, unjust enrichment, and benefits received by 

Defendant as a result of using the patented technology. Greenthread further seeks any other 

damages to which Greenthread is entitled under law or in equity. 

DEMAND FOR JURY TRIAL 

94. Greenthread hereby demands a jury trial for all issues so triable. 

PRAYER FOR RELIEF 

WHEREFORE, Greenthread respectfully requests that this Court enter judgment in its 

favor as follows: 

A. That Judgment be entered that OmniVision has infringed one or more claims of 

the Greenthread Patents, literally and under the doctrine of equivalents; 

B. That, in accordance with 35 U.S.C. § 283, OmniVision and all its affiliates, 

employees, agents, officers, directors, attorneys, successors, and assigns and all those acting on 

behalf of or in active concert or participation with any of them, be preliminarily and permanently 

enjoined from (1) infringing the Greenthread Patents and (2) making, using, selling, and offering 

for sale, or importing into the United States, the OmniVision Accused Products; 

C. An award of damages sufficient to compensate Greenthread for OmniVision’s 

infringement under 35 U.S.C. § 284; 

D. That the case be found exceptional under 35 U.S.C. § 285 and that Greenthread be 

awarded its reasonable attorneys’ fees; 

E. Costs and expenses in this action; 

F. Damages for pre-issuance infringement under 35 U.S.C. § 154(d); 

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G. An award of prejudgment and post-judgment interest; and 

H. Such other and further relief as the Court may deem just and proper. 

 

Dated: May 10, 2023. MCKOOL SMITH, P.C. 

/s/ Alan L. Whitehurst 

Alan L. Whitehurst 

D.C. Bar No. 484873 

awhitehurst@mckoolsmith.com 

Nicholas T. Matich 

D.C. Bar No. 1024907 

nmatich@mckoolsmith.com 

Arvind Jairam 

D.C. Bar No. 1017133

ajairam@mckoolsmith.com 

MCKOOL SMITH, P.C. 

1999 K Street NW, Suite 600 

Washington, DC 20006 

Telephone: 202-370-8300 

Telecopier: 202-370-8344 

Samuel F. Baxter 

Texas Bar No. 01938000 

sbaxter@mckoolsmith.com 

Jennifer Truelove 

Texas Bar No. 24012906 

jtruelove@mckoolsmith.com 

MCKOOL SMITH, P.C. 

104 East Houston Street, Suite 300 

Marshall, TX 75670 

Telephone: 903-923-9000 

Telecopier: 903-923-9099 

 

John B. Campbell 

Texas Bar No. 24036314 

jcampbell@mckoolsmith.com 

MCKOOL SMITH, P.C.

303 Colorado Street, Suite 2100 

Austin, TX 78701 

Telephone: 512-692-8700 

Telecopier: 512-692-8744 

Neil Ozarkar 

Texas Bar No. 24079096 

Case 2:23-cv-00212-JRG Document 1 Filed 05/10/23 Page 23 of 24 PageID #: 23
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nozarkar@mckoolsmith.com 

MCKOOL SMITH, P.C.

600 Travis Street, Suite 7000 

Houston, TX 77002 

Telephone: 713-485-7300 

Telecopier: 713-485-7344 

Emily Tate (Admission Pending)

New York Bar No. 5769153 

etate@mckoolsmith.com 

MCKOOL SMITH, P.C.

One Manhattan West 

395 9th Avenue, 50th Floor 

New York, NY 10001 

Telephone: 212-402-9400 

Telecopier: 212-402-9444 

ATTORNEYS FOR PLAINTIFF 

GREENTHREAD, LLC 

 

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