EXHIBIT C 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 1 of 90 PageID #: 455
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

NETWORK SYSTEM TECHNOLOGIES, LLC,

Plaintiff,

v.

TEXAS INSTRUMENTS INCORPORATED; 

FORD MOTOR COMPANY; VOLKSWAGEN

AG; AUDI AG,

Defendants.

)

)

)

)

)

)

)

)

)

)

)

)

)

Civil Action No. 2:22-cv-482

JURY TRIAL DEMANDED

COMPLAINT

Plaintiff Network System Technologies, LLC (“NST” or “Plaintiff”), by and through its 

attorneys, demands a trial by jury on all issues so triable, and for its complaint against Texas 

Instruments Incorporated, Ford Motor Company, Volkswagen AG, and Audi AG (collectively, 

“Defendants”), alleges as follows:

NATURE OF THE ACTION

1. This is a civil action for patent infringement under the patent laws of the United 

States, Title 35, United States Code, Section 271, et seq., involving the follow United States 

Patents (collectively, “Asserted Patents”) and seeking damages and injunctive relief as provided 

in 35 U.S.C. §§ 281 and 283-285.

U.S. Patent No. 7,366,818 (Exhibit 1, “’818 patent”)

U.S. Patent No. 7,373,449 (Exhibit 2, “’449 patent”)

U.S. Patent No. 7,594,052 (Exhibit 3, “’052 patent”)

U.S. Patent No. 7,769,893 (Exhibit 4, “’9893 patent”)

U.S. Patent No. 8,072,893 (Exhibit 5, “’2893 patent”)

U.S. Patent No. 8,086,800 (Exhibit 6, “’800 patent”)

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 2 of 90 PageID #: 456 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 1 of 89 PageID #: 1
2

THE PARTIES

2. Plaintiff is a limited liability company formed under the laws of Delaware, with a 

principal place of business at 533 Congress Street, Portland, ME 04101. Plaintiff is the owner by 

assignment of the Asserted Patents.

3. On information and belief, Texas Instruments Incorporated (“TI”) is a corporation 

organized and existing under the laws of Delaware, having a principal place of business at 12500 

TI Boulevard, Dallas, Texas 75243. On information and belief, TI has business locations in this 

Judicial District at 6412 U.S. Highway 75, Sherman, Texas 75090; 300 W. Renner Road, 

Richardson, Texas 75080; and 2501 S. State Highway 121 Bus., Lewisville, Texas 75067.

1

 

Further, on information and belief, TI is building new semiconductor wafer fabrication plants in 

this Judicial District in Sherman, Texas, an investment which could reach $30 billion and create 

3,000 jobs.2

 On information and belief, TI may be served in Texas via its registered agent, CT 

Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201.

4. On information and belief, Ford Motor Company (“Ford”) is a corporation 

organized and existing under the laws of Delaware, having a principal place of business at 1 

American Road, Dearborn, Michigan 48126. On information and belief, Ford has a business 

location in this Judicial District at 5700 Granite Parkway, Suite 1000, Plano, Texas 75024.3 Ford 

describes this office as “its Central Market Area Office” and “the principal office of Ford in the 

State of Texas,” where “the decision makers for [Ford] within this state conduct the daily affairs 

of the organization.” Ford Motor Co. v. Johnson, 473 S.W.3d 925, 927 (Tex. App. 2015). On 

1 See Defendant Texas Instruments Incorporated’s Answer and Counterclaims to Plaintiff’s Complaint for Patent 

Infringement, MIMO Research, LLC v. Texas Instruments Incorporated, 5:22-cv-00083, Dkt. No. 9 at 3-4 (E.D. 

Tex. Sept. 6, 2022).

2 https://www.ti.com/about-ti/company/ti-at-a-glance/manufacturing/sherman.html (last visited December 19, 2022); 

https://news.ti.com/texas-instruments-breaks-ground-on-new-300-mm-semiconductor-wafer-fabrication-plants-insherman-texas (last visited December 19, 2022). 3 https://www.granitepark.com/directory (last visited December 19, 2022).

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 3 of 90 PageID #: 457 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 2 of 89 PageID #: 2
3

information and belief, Ford may be served in Texas via its registered agent, CT Corporation 

System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201.

5. On information and belief, Volkswagen AG is a company organized and existing 

under the laws of Germany, having a principal place of business at Berliner Ring 2, 38440 

Wolfsburg, Niedersachsen, Germany. On information and belief, Audi AG (“Audi”) is a wholly 

owned subsidiary of Volkswagen AG, having a principal place of business at Auto-Union-Str. 1, 

85057 Ingolstadt, Bayern, Germany.4

 (Volkswagen AG and Audi AG will be collectively referred 

to as “Volkswagen”.)

6. On information and belief, the Defendants are engaged in making, using, offering 

for sale, selling, importing, or otherwise providing, within the United States and in particular the 

State of Texas and this Judicial District, directly or indirectly, system-on-a-chip products (“SoCs”) 

and/or products containing SoCs with features and functionalities that infringe the Asserted 

Patents.

JURISDICTION AND VENUE

7. This Court has jurisdiction over the subject matter of this action pursuant to 28 

U.S.C. §§ 1331 and 1338(a).

8. Each Defendant is subject to this Court’s personal jurisdiction consistent with the 

principles of due process and the Texas Long Arm Statute. Tex. Civ. Prac. & Rem. Code §§ 17.041, 

et seq.

9. Jurisdiction and venue for this action are proper in this Judicial District.

10. This Court has personal jurisdiction over Defendants at least because, through a 

4

 Defendant Audi AG and Volkswagen AG’s Answer and Defenses to Complaint and Counterclaims, Wildcat 

Licensing WI LLC v. Audi AG et al, DDE-1-19-cv-00833, Dkt. 27 at 3 (D. Del. Oct. 16, 2020) (admitting that Audi 

AG is a subsidiary of Volkswagen AG).

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 4 of 90 PageID #: 458 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 3 of 89 PageID #: 3
4

respective Defendant’s own acts and/or through the acts of each other Defendant acting as its agent, 

representative, or alter ego, they (i) have a presence or regular and established place of business in 

the State of Texas and this Judicial District; (ii) have purposefully availed themselves of the rights 

and benefits of the laws of the State of Texas and this Judicial District; (iii) have done and are 

doing substantial business in the State of Texas and this Judicial District, directly or through 

intermediaries, both generally and, on information and belief, with respect to the allegations in this 

Complaint, including their one or more acts of infringement in the State of Texas and this Judicial 

District; (iv) maintain continuous and systematic contacts in the State of Texas and this Judicial 

District; and/or (v) place products alleged to be infringing in this Complaint in the stream of 

commerce, directly or through intermediaries, with awareness that those products are likely 

destined for use, offer for sale, sale, and/or importation in the State of Texas and this Judicial 

District.

11. For example, Defendants have authorized retailers and distributors in the State of 

Texas and this Judicial District for the products alleged to be infringing in this Complaint, and 

Defendants have derived substantial revenues from their infringing acts occurring within the State 

of Texas and this Judicial District.

12. Defendants have established sufficient minimum contacts with the State of Texas 

and this Judicial District such that they should reasonably and fairly anticipate being brought into 

court in the State of Texas and this Judicial District without offending traditional notions of fair 

play and substantial justice; and Defendants have purposefully directed activities at residents of 

the State of Texas and this Judicial District. Moreover, the patent infringement claims alleged 

herein arise out of or are related to one or more of the foregoing activities. On information and 

belief, a substantial part of the events giving rise to Plaintiff’s claims, including acts of patent 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 5 of 90 PageID #: 459 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 4 of 89 PageID #: 4
5

infringement, have occurred in the State of Texas and this Judicial District.

13. Venue is proper in this Judicial District as to Defendants under 28 U.S.C. §§ 

1391(b) and (c) and 1400(b). 

14. Venue is proper as to Volkswagen because, on information and belief, they are

foreign entities, as identified above in paragraph 5. 28 U.S.C. § 1391(c); In re HTC Corp., 889 

F.3d 1349, 1357 (Fed. Cir. 2018) (holding that “[t]he Court’s recent decision in TC Heartland does 

not alter” the alien-venue rule). 

15. Venue is proper as to TI and Ford because, on information and belief, they have

committed acts of infringement and each have a regular and established place of business in this 

Judicial District, as identified above in paragraphs 3 and 4. 28 U.S.C. § 1400(b).

JOINDER

16. Joinder is proper under at least Federal Rule of Civil Procedure 20 and 35 U.S.C. 

§ 299 at least because Defendants’ infringing conduct alleged herein arises out of the same 

transaction, occurrence, or series of transactions or occurrences relating to the making, using, 

importing into the United States, offering for sale, or selling of the same accused product or 

process, and questions of fact common to all Defendants will arise in this action.

17. On information and belief, the accused products are either the accused TI SoCs (as 

in the case of TI) or products containing the accused TI SoCs (as in the case of the remaining 

Defendants), and thus the TI SoCs are common to all Defendants’ infringement of the Asserted 

Patents. On information and belief, all Defendants infringe the Asserted Patents by, for example, 

making, using, importing, offering for sale, and selling TI SoCs, whether alone or integrated into 

other products. Stated differently, on information and belief, each of the Defendants’ accused 

products infringes the same Asserted Patents by using TI SoCs—meaning that all accused products 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 6 of 90 PageID #: 460 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 5 of 89 PageID #: 5
6

use identically sourced components and that there is overlap of the accused products’ and 

processes’ development and manufacture. Thus, on information and belief, common SoC

technology is a defining characteristic for each of the Defendant’s infringement, and the factual 

question of infringement will substantially overlap for all Defendants. 

18. Further, on information and belief, Ford and Volkswagen purchase or otherwise 

obtain the TI SoCs from TI, and there are licensing or technology agreements between TI and Ford

and between TI and Volkswagen. 

THE ASSERTED PATENTS

19. The Asserted Patents result from extensive research and development by Philips 

Semiconductors, a subsidiary of Koninklijke Philips N.V. (“Philips”) that included VLSI 

Technology, Inc., which Philips acquired in 1999. Prior to being spun off in 2006 as NXP 

Semiconductors N.V. (“NXP”), Philips Semiconductors was one of the largest semiconductor 

companies in the world. Each of the Asserted Patents predate the NXP spin-off and were retained 

by Philips until all right, title, and interest in the Asserted Patents were transferred to Plaintiff.

U.S. Patent No. 7,366,818

20. Plaintiff is the lawful owner of all right, title, and interest in United States Patent 

No. 7,366,818 (“’818 patent”), entitled “INTEGRATED CIRCUIT COMPRISING A 

PLURALITY OF PROCESSING MODULES AND A NETWORK AND METHOD FOR 

EXCHANGING DATA USING SAME,” including the right to sue and to recover for infringement 

thereof. The ’818 patent was duly and legally issued on April 29, 2008, naming Andrei Radulescu 

and Kees Gerard Willem Goossens as inventors. A copy of the ʼ818 patent is attached hereto as 

Exhibit 1.

21. The ’818 patent has 7 claims: 1 independent claim and 6 dependent claims.

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 7 of 90 PageID #: 461 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 6 of 89 PageID #: 6
7

22. The ’818 patent covers SoCs that have an interface that comprises a dropping means 

for dropping data exchanged by two modules and where the interface can control the dropping of 

data and therefore completion of message transactions.

23. The claims of the ʼ818 patent, including claim 1 (reproduced below), recite at least 

these inventive concepts of the ’818 patent.

1. Integrated circuit comprising a plurality of processing modules (M, S) said 

modules being disposed on the same chip, and a network (N; RN) arranged for 

providing at least one connection between a first and at least one second module 

(M, S),

wherein said modules communicate via a network on chip, and

wherein said connection supports transactions comprising outgoing messages 

from the first module to the second modules and return messages from the 

second modules to the first module, the integrated circuit comprising at least 

one dropping means (DM) for dropping data exchanged by said first and second 

module (M, S), and

at least one interface means (ANIP, PNIP) for managing the interface between 

a module (M, S) and the network (N, RN),

wherein said interface means (ANIP, PNIP) comprises a first dropping means 

(DM) for dropping data, and

wherein the dropping of data and therefore the transaction completion can be 

controlled by the interface means.

(Exhibit 1, ’818 patent at claim 1.) The subject matter described and claimed by the ’818 patent, 

including the integrated circuit of claim 1, was an improvement in the functionality, performance, 

and efficiency of integrated circuits and the connections and communication networks thereof and 

was novel and not well-understood, routine, or conventional at the time of the ’818 patent. 

24. Defendants had knowledge of the ’818 patent at least as of the date of this 

Complaint.

25. The ’818 patent was developed and patented by Philips Semiconductors, one of the 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 8 of 90 PageID #: 462 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 7 of 89 PageID #: 7
8

largest semiconductor companies in the world. Because of the size and prominence of Philips in 

the tight-knit semiconductor industry, industry participants, including, on information and belief, 

Defendants, monitored patenting activity by Philips and reviewed, and were aware of shortly after 

their publication, at least the U.S. published patent applications and patents obtained by Philips in 

the semiconductor space, including the ’818 patent. On information and belief, such industry 

participants, including Defendants, considered Philips’ U.S. published patent applications and 

patents in the semiconductor space, including the ’818 patent, and such Philips U.S. published 

patent applications and patents’ actual or potential applicability to their own current products and 

product roadmaps, including the products described herein.

26. The ’818 patent is widely and publicly known, and frequently referenced, in the 

tight-knit semiconductor industry, having been cited during prosecution of approximately 76 

patent applications assigned to industry leaders such as Intel Corporation, Arm Limited, NEC 

Corporation, IBM Corporation, and others.5

27. On information and belief, Defendants sought to develop their products and product 

roadmaps, including the products described herein, in ways that would not infringe U.S. patents in 

the semiconductor space. 

28. Therefore, on information and belief, Defendants monitored U.S. published patent 

applications and patents obtained by Philips in the semiconductor space in around the years 2006-

2012.

29. On information and belief, Defendants were aware of and considered the ’818 

patent, and its actual or potential applicability to their own current products and product roadmaps, 

including the products described herein.

5 https://patents.google.com/patent/US7366818B2/en?oq=7%2c366%2c818 (last visited December 19, 2022).

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 9 of 90 PageID #: 463 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 8 of 89 PageID #: 8
9

30. On information and belief, Defendants have expertise in the subject matter of the 

’818 patent and possesses sufficient technical competence to understand the scope of such patent.

31. By virtue of Philips’ and the ’818 patent’s fame in the semiconductor industry, the 

patent’s inclusion in the Philips Semiconductor portfolio, and Defendants’ desires to develop noninfringing products and product roadmaps, Defendants had actual knowledge of the ’818 patent 

around the time it issued or its U.S. application published, and in no event later than the date of 

this Complaint.

U.S. Patent No. 7,373,449

32. Plaintiff is the lawful owner of all right, title, and interest in United States Patent 

No. 7,373,449 (“’449 patent”), entitled “APPARATUS AND METHOD FOR 

COMMUNICATING IN AN INTEGRATED CIRCUIT,” including the right to sue and to recover 

for infringement thereof. The ’449 patent was duly and legally issued on May 13, 2008, naming 

Andrei Radulescu and Kees Gerard Willem Goossens as inventors. A copy of the ʼ449 patent is 

attached hereto as Exhibit 2.

33. The ’449 patent has 18 claims: 2 independent claims and 16 dependent claims.

34. The ’449 patent covers SoCs that have a resource manager that manages network 

resources by determining whether the resources (i.e., communication channels and connection 

properties) are available.

35. The claims of the ʼ449 patent, including claim 10 (reproduced below), recite at least 

these inventive concepts of the ’449 patent.

10. Method for exchanging messages in an integrated circuit comprising a 

plurality of modules, the messages between the modules being exchanged over 

connections via a network, wherein said connections comprises a set of 

communication channels each having a set of connection properties, any 

communication channel being independently configurable, wherein said 

connection through the network supports transactions comprising at least one 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 10 of 90 PageID #: 464 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 9 of 89 PageID #: 9
10

of outgoing messages from the first module to the second module and return

messages from the second module to the first module and further comprising 

the steps of:

the first module issuing a request for a connection with the second module to a 

communication manager, wherein the request comprises desired connection 

properties associated with the sets of communication channels;

the communication manager forwarding the request to a resource manager;

the resource manager determining whether a target connection with the desired 

connection properties is available;

the resource manager responding with the availability of the target connection 

to the communication manager; and

the target connection between the first and second module being established 

based on the available properties of said communication channels of said 

connection.

(Exhibit 2, ’449 patent at claim 10.) The subject matter described and claimed by the ’449 patent, 

including the method for exchanging messages in an integrated circuit of claim 10, was an 

improvement in the functionality, performance, and efficiency of integrated circuits and the 

connections and communication networks thereof and was novel and not well-understood, routine, 

or conventional at the time of the ’449 patent. 

36. Defendants had knowledge of the ’449 patent at least as of the date of this 

Complaint.

37. The ’449 patent was developed and patented by Philips Semiconductors, one of the 

largest semiconductor companies in the world. Because of the size and prominence of Philips in 

the tight-knit semiconductor industry, industry participants, including, on information and belief, 

Defendants, monitored patenting activity by Philips and reviewed, and were aware of shortly after 

their publication, at least the U.S. published patent applications and patents obtained by Philips in 

the semiconductor space, including the ’449 patent. On information and belief, such industry 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 11 of 90 PageID #: 465 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 10 of 89 PageID #: 10
11

participants, including Defendants, considered Philips’ U.S. published patent applications and 

patents in the semiconductor space, including the ’449 patent, and such Philips U.S. published 

patent applications and patents’ actual or potential applicability to their own current products and 

product roadmaps, including the products described herein.

38. The ’449 patent is widely and publicly known, and frequently referenced, in the 

tight-knit semiconductor industry, having been cited during prosecution of approximately 76 

patent applications assigned to industry leaders such as Intel Corporation, Arm Limited, NEC 

Corporation, IBM Corporation, and others.6

39. On information and belief, Defendants sought to develop their products and product 

roadmaps, including the products described herein, in ways that would not infringe U.S. patents in 

the semiconductor space. 

40. Therefore, on information and belief, Defendants monitored U.S. published patent 

applications and patents obtained by Philips in the semiconductor space in around the years 2006-

2012.

41. On information and belief, Defendants were aware of and considered the ’449 

patent, and its actual or potential applicability to their own current products and product roadmaps, 

including the products described herein.

42. On information and belief, Defendants have expertise in the subject matter of the 

’449 patent and possesses sufficient technical competence to understand the scope of such patent.

43. By virtue of Philips’ and the ’449 patent’s fame in the semiconductor industry, the 

patent’s inclusion in the Philips Semiconductor portfolio, and Defendants’ desires to develop noninfringing products and product roadmaps, Defendants had actual knowledge of the ’449 patent 

6 https://patents.google.com/patent/US7373449B2/en?oq=7%2c373%2c449 (last visited December 19, 2022).

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 12 of 90 PageID #: 466 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 11 of 89 PageID #: 11
12

around the time it issued or its U.S. application published, and in no event later than the date of 

this Complaint.

U.S. Patent No. 7,594,052

44. Plaintiff is the lawful owner of all right, title, and interest in United States Patent 

No. 7,594,052 (“’052 patent”), entitled “INTEGRATED CIRCUIT AND METHOD OF 

COMMUNICATION SERVICE MAPPING,” including the right to sue and to recover for 

infringement thereof. The ’052 patent was duly and legally issued on September 22, 2009, naming 

Andrei Radulescu and Kees Gerard Willem Goossens as inventors. A copy of the ʼ052 patent is 

attached hereto as Exhibit 3.

45. The ’052 patent has 7 claims: 3 independent claims and 4 dependent claims.

46. The ’052 patent covers SoCs that offer differentiated intermodular communication 

services based on connections with corresponding properties. The covered SoCs map a requested 

communication service to a connection based on communication and connection properties.

47. The claims of the ’052 patent, including claim 6 (reproduced below), recite at least 

these inventive concepts of the ’052 patent.

6. Method of communication service mapping in an integrated circuit, having a 

plurality of processing modules (M, S), wherein at least one first of said processing 

modules (M) requests at least one communication service to at least one second 

processing module (S) based on specific communication properties and at least one 

communication service identification, wherein said at least one communication 

service identification comprises at least one communication thread or at least one 

address range, said address range for identifying one or more second processing 

modules (S) or a memory region within said one or more second processing 

modules (S), comprising the steps of:

coupling said plurality of processing modules (M, S) by an interconnect means (N) 

and

enabling a connection based communication having a set of connection properties,

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 13 of 90 PageID #: 467 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 12 of 89 PageID #: 12
13

controlling the communication between said at least one first of said plurality of 

processing modules (M) and said interconnect means (N) by at least one network 

interface (NI) associated to said at least one first of said processing modules,

mapping the requested at least one communication service based on said specific 

communication properties to a connection based on a set of connection properties 

according to said at least one communication service identification.

(Exhibit 3, ’052 patent at claim 6.) The subject matter described and claimed by the ’052 patent, 

including the method of communication service mapping in an integrated circuit of claim 6, was 

an improvement in the functionality, performance, and efficiency of integrated circuits and the 

connections and communication networks thereof and was novel and not well-understood, routine, 

or conventional at the time of the ’052 patent. 

48. Defendants had knowledge of the ’052 patent at least as of the date of this 

Complaint.

49. The ’052 patent was developed and patented by Philips Semiconductors, one of the 

largest semiconductor companies in the world. Because of the size and prominence of Philips in 

the tight-knit semiconductor industry, industry participants, including, on information and belief, 

Defendants, monitored patenting activity by Philips and reviewed, and were aware of shortly after 

their publication, at least the U.S. published patent applications and patents obtained by Philips in 

the semiconductor space, including the ’052 patent. On information and belief, such industry 

participants, including Defendants, considered Philips’ U.S. published patent applications and 

patents in the semiconductor space, including the ’052 patent, and such Philips U.S. published 

patent applications and patents’ actual or potential applicability to their own current products and 

product roadmaps, including the products described herein.

50. The ’052 patent is widely and publicly known, and frequently referenced, in the 

tight-knit semiconductor industry, having been cited during prosecution of approximately 19 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 14 of 90 PageID #: 468 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 13 of 89 PageID #: 13
14

patent applications assigned to industry leaders such as Samsung Electronics Co. and others.7

51. On information and belief, Defendants sought to develop their products and product 

roadmaps, including the products described herein, in ways that would not infringe U.S. patents in 

the semiconductor space. 

52. Therefore, on information and belief, Defendants monitored U.S. published patent 

applications and patents obtained by Philips in the semiconductor space in around the years 2006-

2012.

53. On information and belief, Defendants were aware of and considered the ’052 

patent, and its actual or potential applicability to their own current products and product roadmaps, 

including the products described herein.

54. On information and belief, Defendants have expertise in the subject matter of the 

’052 patent and possesses sufficient technical competence to understand the scope of such patent.

55. By virtue of Philips’ and the ’052 patent’s fame in the semiconductor industry, the 

patent’s inclusion in the Philips Semiconductor portfolio, and Defendants’ desires to develop noninfringing products and product roadmaps, Defendants had actual knowledge of the ’052 patent 

around the time it issued or its U.S. application published, and in no event later than the date of 

this Complaint.

U.S. Patent No. 7,769,893

56. Plaintiff is the lawful owner of all right, title, and interest in United States Patent 

No. 7,769,893 (“’9893 patent”), entitled “INTEGRATED CIRCUIT AND METHOD FOR 

ESTABLISHING TRANSACTIONS,” including the right to sue and to recover for infringement 

thereof. The ’9893 patent was duly and legally issued on August 3, 2010, naming Kees Gerard 

7 https://patents.google.com/patent/US7594052B2/en?oq=7%2c594%2c052 (last visited December 19, 2022).

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 15 of 90 PageID #: 469 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 14 of 89 PageID #: 14
15

Willem Goossens as inventor. A copy of the ʼ9893 patent is attached hereto as Exhibit 4.

57. The ’9893 patent has 11 claims: 2 independent claims and 9 dependent claims.

58. The ’9893 patent covers SoCs that use an address translation unit, which is part of 

a network interface, for address mapping, where the address translation unit determines both the 

location of a message receiving module and a location within the message receiving module.

59. The claims of the ’9893 patent, including claim 4 (reproduced below), recite at least 

these inventive concepts of the ’9893 patent.

4. A method for exchanging messages in an integrated circuit comprising a 

plurality of modules, the messages between the plurality of modules being 

exchanged via a network wherein a message issued by an addressing module M 

comprises:

first information indicative of a location of an addressed message receiving 

module S within the network and is comprised of (1) a connection identifier 

identifying two or more message receiving modules S and (2) an identifier of a 

passive network interface means associated with the addressed message 

receiving module S, and second information indicative of a particular location 

within the addressed message receiving module S, such as a memory, or a 

register address, the method including the steps of:

(a) issuing from said addressing module M a message request including said 

first information, said second information, and data and/or connection 

properties to an address translation unit included as part of an active network 

interface module associated with said addressing module M,

(b) arranging, at said address translation unit, the first and the second 

information comprising said issued message as a single address,

(c) determining, at said address translation unit, which message receiving 

module S is being addressed in said message request issued from said 

addressing module M based on said single address, and

(d) further determining, at said address translation unit, the particular location 

within the addressed message receiving module S based on said single address.

(Exhibit 4, ’9893 patent at claim 4.) The subject matter described and claimed by the ’9893 patent, 

including the method for exchanging messages in an integrated circuit of claim 4, was an 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 16 of 90 PageID #: 470 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 15 of 89 PageID #: 15
16

improvement in the functionality, performance, and efficiency of integrated circuits and the 

connections and communication networks thereof and was novel and not well-understood, routine, 

or conventional at the time of the ’9893 patent. 

60. Defendants had knowledge of the ’9893 patent at least as of the date of this 

Complaint.

61. The ’9893 patent was developed and patented by Philips Semiconductors, one of 

the largest semiconductor companies in the world. Because of the size and prominence of Philips 

in the tight-knit semiconductor industry, industry participants, including, on information and 

belief, Defendants, monitored patenting activity by Philips and reviewed, and were aware of 

shortly after their publication, at least the U.S. published patent applications and patents obtained 

by Philips in the semiconductor space, including the ’9893 patent. On information and belief, such 

industry participants, including Defendants, considered Philips’ U.S. published patent applications 

and patents in the semiconductor space, including the ’9893 patent, and such Philips U.S. 

published patent applications and patents’ actual or potential applicability to their own current 

products and product roadmaps, including the products described herein.

62. The ’9893 patent is widely and publicly known, and frequently referenced, in the 

tight-knit semiconductor industry, having been cited during prosecution of approximately 76 

patent applications assigned to industry leaders such as Intel Corporation, Arm Limited, NEC 

Corporation, IBM Corporation, and others.8

63. On information and belief, Defendants sought to develop their products and product 

roadmaps, including the products described herein, in ways that would not infringe U.S. patents in 

the semiconductor space. 

8 https://patents.google.com/patent/US7769893B2/en?oq=7%2c769%2c893 (last visited December 19, 2022).

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 17 of 90 PageID #: 471 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 16 of 89 PageID #: 16
17

64. Therefore, on information and belief, Defendants monitored U.S. published patent 

applications and patents obtained by Philips in the semiconductor space in around the years 2006-

2012.

65. On information and belief, Defendants were aware of and considered the ’9893 

patent, and its actual or potential applicability to their own current products and product roadmaps, 

including the products described herein.

66. On information and belief, Defendants have expertise in the subject matter of the 

’9893 patent and possesses sufficient technical competence to understand the scope of such patent.

67. By virtue of Philips’ and the ’9893 patent’s fame in the semiconductor industry, the 

patent’s inclusion in the Philips Semiconductor portfolio, and Defendants’ desires to develop noninfringing products and product roadmaps, Defendants had actual knowledge of the ’9893 patent 

around the time it issued or its U.S. application published, and in no event later than the date of 

this Complaint.

U.S. Patent No. 8,072,893

68. Plaintiff is the lawful owner of all right, title, and interest in United States Patent 

No. 8,072,893 (“’2893 patent”), entitled “INTEGRATED CIRCUIT WITH DATA 

COMMUNICATION NETWORK AND IC DESIGN METHOD,” including the right to sue and 

to recover for infringement thereof. The ’2893 patent was duly and legally issued on December 

6, 2011, naming John Dielissen and Edwin Rijpkema as inventors. A copy of the ʼ2893 patent is 

attached hereto as Exhibit 5.

69. The ’2893 patent has 12 claims: 5 independent claims and 7 dependent claims.

70. The ’2893 patent covers SoCs that improve data communication speed and 

frequency synchronization between processing units through the use of packetized data

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 18 of 90 PageID #: 472 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 17 of 89 PageID #: 17
18

(comprising N data elements) and introduction of a delay (of M*N cycles) on a communication

channel for communication synchronization, with such delay correlated to the size (N) of the data 

packet.

71. The claims of the ʼ2893 patent, including claims 1 and 10 (reproduced below), 

recite at least these inventive concepts of the ʼ2893 patent.

1. An integrated circuit comprising:

a plurality of functional blocks; and

a data communication network comprising a plurality of network stations being 

interconnected via a plurality of communication channels for communicating data 

packages between the functional blocks, each data package comprising N data 

elements including a data element comprising routing information for the network 

stations, N being an integer of at least two, the plurality of network stations 

comprising a plurality of data routers and a plurality of network interfaces, each of 

the data routers being coupled to a functional block via a network interface, the data 

communication network comprising a first network station and a second network 

station interconnected through a first communication channel, the data 

communication network further comprising M*N data storage elements, M being a 

positive integer, the data communication introducing a delay of M*N cycles on the 

first communication channel when the data communication network identifies the 

first communication channel as having a data transfer delay exceeding a predefined 

delay threshold.

10. A method of designing an integrated circuit comprising a plurality of functional 

blocks, and a data communication network comprising a plurality of network 

stations being interconnected via a plurality of communication channels for 

communicating data packages between the functional blocks, each data package 

comprising N data elements including a data element comprising routing 

information for the network stations, N being an integer of at least two, the plurality 

of network stations comprising a plurality of data routers and a plurality of network 

interfaces, each of the data routers being coupled to a functional block via a network 

interface; the method comprising the acts of:

identifying a first communication channel between a first network station and a 

second network station that has a data transfer delay exceeding a predefined delay 

threshold; and

in response to the identifying act, inserting M*N data storage elements into the data 

communication network, M being a positive integer, for introducing a delay of 

M*N cycles on the first communication channel.

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 19 of 90 PageID #: 473 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 18 of 89 PageID #: 18
19

(Exhibit 5, ʼ2893 patent at claims 1 and 10.) The subject matter described and claimed by the 

ʼ2893 patent, including the integrated circuit of claim 1 and method of designing an integrated 

circuit of claim 10, was an improvement in the functionality, performance, and efficiency of 

integrated circuits and the connections and communication networks thereof and was novel and 

not well-understood, routine, or conventional at the time of the ʼ2893 patent.

72. Defendants had knowledge of the ʼ2893 patent at least as of the date of this 

Complaint.

73. The ʼ2893 patent was developed and patented by Philips Semiconductors, one of 

the largest semiconductor companies in the world. Because of the size and prominence of Philips 

in the tight-knit semiconductor industry, industry participants, including, on information and 

belief, Defendants, monitored patenting activity by Philips and reviewed, and were aware of 

shortly after their publication, at least the U.S. published patent applications and patents obtained 

by Philips in the semiconductor space, including the ʼ2893 patent. On information and belief, such 

industry participants, including Defendants, considered Philips’ U.S. published patent applications 

and patents in the semiconductor space, including the ʼ2893 patent, and such Philips U.S. 

published patent applications and patents’ actual or potential applicability to their own current 

products and product roadmaps, including the products described herein.

74. The ’2893 patent is widely and publicly known, and frequently referenced, in the 

tight-knit semiconductor industry, having been cited during prosecution of approximately 13 

patent applications assigned to industry leaders such as Intel Corporation and others.9

75. On information and belief, Defendants sought to develop their products and product 

roadmaps, including the products described herein, in ways that would not infringe U.S. patents in 

9 https://patents.google.com/patent/US8072893B2/en?oq=8%2c072%2c893 (last visited December 19, 2022).

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 20 of 90 PageID #: 474 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 19 of 89 PageID #: 19
20

the semiconductor space. 

76. Therefore, on information and belief, Defendants monitored U.S. published patent 

applications and patents obtained by Philips in the semiconductor space in around the years 2006-

2012.

77. On information and belief, Defendants were aware of and considered the ’2893 

patent, and its actual or potential applicability to their own current products and product roadmaps, 

including the products described herein.

78. On information and belief, Defendants have expertise in the subject matter of the 

’2893 patent and possesses sufficient technical competence to understand the scope of such patent.

79. By virtue of Philips’ and the ’2893 patent’s fame in the semiconductor industry, the 

patent’s inclusion in the Philips Semiconductor portfolio, and Defendants’ desires to develop noninfringing products and product roadmaps, Defendants had actual knowledge of the ’9893 patent 

around the time it issued or its U.S. application published, and in no event later than the date of 

this Complaint.

U.S. Patent No. 8,086,800

80. Plaintiff is the lawful owner of all right, title, and interest in United States Patent 

No. 8,086,800 (“’800 patent”), entitled “INTEGRATED CIRCUIT AND METHOD FOR 

BUFFERING TO OPTIMIZE BURST LENGTH IN NETWORKS ON CHIPS,” including the 

right to sue and to recover for infringement thereof. The ’800 patent was duly and legally issued 

on December 27, 2011, naming Andrei Radulescu and Kees Gerard Willem Goossens as inventors. 

A copy of the ʼ800 patent is attached hereto as Exhibit 6.

81. The ’800 patent has 21 claims: 4 independent claims and 17 dependent claims.

82. The ’800 patent covers SoCs that employ data buffering at requesting (master) and 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 21 of 90 PageID #: 475 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 20 of 89 PageID #: 20
21

responding (slave) modules and where each module has a network interface with a wrapper that 

buffers data into optimal amounts for transfer.

83. The claims of the ʼ800 patent, including claim 10 (reproduced below), recite at least 

these inventive concepts of the ’800 patent.

10. A method for buffering data in an integrated circuit having a plurality of 

processing modules being connected with an interconnect through interface 

units, wherein a first processing module communicates to a second processing 

module using transactions, the method comprising the acts of:

configuring the first processing module having a first memory as a master the 

provides requests;

configuring the second processing module having a second memory as a slave 

the provides responses to the requests;

connecting the master to a master interface unit of the interface units;

connecting the master interface unit to the interconnect so that the master 

interface unit is between the master and the interconnect;

connecting the slave to a slave interface unit of the interface units;

connecting the slave interface unit to the interconnect so that the slave interface 

unit is between the slave and the interconnect;

determining by a master determination unit of the master interface unit a first 

optimal amount of data to be buffered by a master wrapper of the master 

interface unit;

determining by a slave determination unit of the slave interface unit a second 

optimal amount of data to be buffered by a slave wrapper of the slave interface 

unit;

buffering by the slave wrapper of the slave interface unit data from the slave to 

be transferred over the interconnect until a first optimal amount of data is 

buffered;

transferring the buffered data from the slave wrapper to the master wrapper 

when said first optimal amount of data has been buffered by the slave wrapper;

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 22 of 90 PageID #: 476 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 21 of 89 PageID #: 21
22

buffering by the master wrapper of the master interface unit data from the 

master to be transferred over the interconnect until a second optimal amount of 

data is buffered by the master wrapper;

transferring the buffered data from the master wrapper to the slave wrapper 

when said second optimal amount of data has been buffered by the master 

wrapper,

wherein at least one of the first determination unit and the second determination 

unit is further configured to determine an optimal moment for sending the data 

in said first wrapper or said second wrapper according to communication 

properties of the communication between the master and the slave, wherein the 

communication properties include ordering of data transport, flow control 

including when a remote buffer is reserved for a connection, then a data 

producer will be allowed to send data only when it is guaranteed that space is

available for the produced data at the remote buffer, throughput where a lower 

bound on throughput is guaranteed, latency where an upper bound for latency 

is guaranteed, lossiness including dropping of data, transmission termination, 

transaction completion, data correctness, priority, and data delivery.

(Exhibit 6, ’800 patent at claim 10.) The subject matter described and claimed by the ’800 patent, 

including the method for buffering data in an integrated circuit of claim 10, was an improvement 

in the functionality, performance, and efficiency of integrated circuits and the connections and 

communication networks thereof and was novel and not well-understood, routine, or conventional 

at the time of the ’800 patent. 

84. Defendants had knowledge of the ’800 patent at least as of the date of this 

Complaint.

85. The ’800 patent was developed and patented by Philips Semiconductors, one of the 

largest semiconductor companies in the world. Because of the size and prominence of Philips in 

the tight-knit semiconductor industry, industry participants, including, on information and belief, 

Defendants, monitored patenting activity by Philips and reviewed, and were aware of shortly after 

their publication, at least the U.S. published patent applications and patents obtained by Philips in 

the semiconductor space, including the ’800 patent. On information and belief, such industry 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 23 of 90 PageID #: 477 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 22 of 89 PageID #: 22
23

participants, including Defendants, considered Philips’ U.S. published patent applications and 

patents in the semiconductor space, including the ’800 patent, and such Philips U.S. published 

patent applications and patents’ actual or potential applicability to their own current products and 

product roadmaps, including the products described herein.

86. On information and belief, Defendants sought to develop their products and product 

roadmaps, including the products described herein, in ways that would not infringe U.S. patents in 

the semiconductor space. 

87. Therefore, on information and belief, Defendants monitored U.S. published patent 

applications and patents obtained by Philips in the semiconductor space in around the years 2006-

2012.

88. On information and belief, Defendants were aware of and considered the ’800 

patent, and its actual or potential applicability to their own current products and product roadmaps, 

including the products described herein.

89. On information and belief, Defendants have expertise in the subject matter of the 

’800 patent and possesses sufficient technical competence to understand the scope of such patent.

90. By virtue of Philips’ and the ’800 patent’s fame in the semiconductor industry, the 

patent’s inclusion in the Philips Semiconductor portfolio, and Defendants’ desires to develop noninfringing products and product roadmaps, Defendants had actual knowledge of the ’800 patent 

around the time it issued or its U.S. application published, and in no event later than the date of 

this Complaint.

BACKGROUND OF DEFENDANTS’ INFRINGING CONDUCT 

91. Plaintiff incorporates by reference the allegations contained in paragraphs 1 to 90

above.

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 24 of 90 PageID #: 478 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 23 of 89 PageID #: 23
24

92. SoCs are widely used in consumer electronics or computing devices, including 

smartphones, laptops, tablets, and embedded systems such as vehicle infotainment devices and 

advanced driver assistance systems. SoCs are complex integrated circuits that may incorporate 

multiple processors, memory units, and interfaces onto a single chip.

93. As SoCs have developed over time, more processing cores and other IP blocks were

incorporated into SoCs, resulting in increased intermodular connections and a greater need for 

intra-SoC communication efficiency. Thus, intra-SoC communication designs have moved from 

prior interconnect technologies (e.g., bus or point-to-point designs) to network interconnects, 

which provide advantages compared to other forms of intra-SoC communication, such as fewer 

wires, lower routing congestion, and decreased SoC die area, all leading to: smaller devices; 

increased IP block density, which results in more powerful devices; increased power efficiency, 

which enables better battery life; decreased thermal load, which leads to longer system life; and 

improved system performance. Therefore, interconnect efficiency—driven by the pioneering 

innovations claimed in the Asserted Patents—is now a dominant factor in determining overall SoC 

system performance, size, and cost.

94. As discussed above, the Asserted Patents relate to fundamental innovations in 

SoCs, including how the multitude of processors, memories, and other functional units residing on 

an SoC are interconnected and communicate with each other.

95. The Defendants are a leading semiconductor company (TI) and leading automobile 

companies (Ford and Volkswagen). On information and belief, TI provides SoCs that are 

incorporated into Ford and Volkswagen’s products. On information and belief, TI’s SoCs include 

Arteris interconnect technology and/or a derivative thereof.

10 Further, on information and belief, 

10 https://www.arteris.com/customers (last visited December 19, 2022) (identifying TI as an Arteris customer and 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 25 of 90 PageID #: 479 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 24 of 89 PageID #: 24
25

Ford and Volkswagen provide products that contain TI SoCs including Arteris interconnect 

technology and/or a derivative thereof.

11 Thus, on information and belief, Defendants make, use, 

sell, offer for sale, and/or import, or have otherwise made, used, sold, offered for sale, and/or 

imported, SoCs including Arteris interconnect technology and/or a derivative thereof, and/or 

products containing such SoCs.

96. As set forth in the charts appended hereto, the TI SoCs, including their 

incorporation of Arteris interconnect technology and/or a derivative thereof, as well as products 

incorporating the TI SoCs, infringe each of the Asserted Patents.

97. On information and belief, TI’s products that infringe the Asserted Patents 

(collectively, “TI Accused Products”) include the following: 

TI Accused Products

• TI Jacinto processors including, for example, the 

OMAP, TDA and DRA families of processors

• TI SimpleLink processors including, for example, 

the CC26xx and CC13xx processors

• TI integrated circuits containing Arteris 

interconnect technology and/or a derivative thereof

• Phones, tablets, computers, laptops and 

Chromebooks containing TI processors or other TI 

integrated circuits containing Arteris interconnect 

technology and/or a derivative thereof

• Vehicles and components thereof containing TI 

stating: “Texas Instruments has used Arteris® IP technology for over a decade. [Arteris] technology is used in the 

Jacinto 5/6 and TDA2x / TDA3x advanced driver-assistance system (ADAS) and infotainment SoCs, the CC26xx / 

CC13xx SimpleLink IoT SoCs, and the OMAP 4 / OMAP 5 SoCs.”); see also 

https://news.thomasnet.com/fullstory/arteris-flexnoc-network-on-chip-technology-designed-into-majority-ofmobile-socs-20009449 (last visited December 19, 2022) (Arteris FlexNoC was incorporated into over 60% of SoCs 

deployed in smartphones and tablets). 11 https://www.prnewswire.com/news-releases/tis-innovative-automotive-infotainment-platform-enables-ford-toredefine-the-user-experience-in-fords-sync-3-300016382.html (last visited December 19, 2022) (stating that “[TI] 

and Ford Motor Company have collaborated on an infotainment solution” and that Ford’s infotainment system 

“incorporates TI's OMAPTM 5 processor, a member of the ‘Jacinto’ family of automotive processors”); 

https://seekingalpha.com/article/4513926-texas-instruments-automotive-growth-continues (last visited December 

19, 2022) (identifying Ford and Volkswagen as customers of TI’s automotive SoCs for infotainment systems, 

including the Jacinto SoC product family); https://www.prnewswire.com/news-releases/more-than-150-millionautomotive-processors-from-texas-instruments-drive-innovation-in-the-automotive-market-enabling-a-safer-andmore-connected-driving-experience-300382846.html (last visited December 19, 2022) (stating that TI’s “‘Jacinto’ 

family of processors is powering infotainment systems” for Ford and Volkswagen vehicles).

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 26 of 90 PageID #: 480 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 25 of 89 PageID #: 25
26

Jacinto processors or other TI integrated circuits 

containing Arteris interconnect technology and/or a 

derivative thereof

• Virtual Reality, Augmented Reality and wearable 

products containing TI processors or other TI 

integrated circuits containing Arteris interconnect 

technology and/or a derivative thereof

• IoT, Audio, Wireless Network and Smart Home 

products containing SimpleLink processors or other 

TI integrated circuits containing Arteris 

interconnect technology and/or a derivative thereof

98. The above-listed TI Accused Products are non-limiting. Additional products of TI

may infringe the Asserted Patents, and the above-listed TI Accused Products may infringe 

additional patents.

99. TI has infringed and continues to infringe the Asserted Patents by making, using, 

selling, offering to sell, and/or importing, without license or authority, the TI Accused Products as 

alleged herein, which embody or use the inventions claimed in the Asserted Patents literally or 

under the doctrine of equivalents.

100. Comparisons of claims of the Asserted Patents to exemplary products of the TI

Accused Products are attached as Exhibit 7 (ʼ818 patent), Exhibit 8 (ʼ449 patent), Exhibit 9 (ʼ052 

patent), Exhibit 10 (ʼ9893 patent), Exhibit 11 (ʼ2893), and Exhibit 12 (ʼ800 patent), which are 

incorporated herein by reference. 

101. TI has induced infringement and continues to induce infringement of the Asserted 

Patents by actively and knowingly inducing others to make, use, sell, offer to sell, and/or import, 

without license or authority, the TI Accused Products as alleged herein, which embody or use the 

inventions claimed in the Asserted Patents literally or under the doctrine of equivalents.

102. TI markets, advertises, offers for sale, and/or otherwise promotes the TI Accused 

Products and, on information and belief, does so to actively and knowingly induce, encourage, 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 27 of 90 PageID #: 481 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 26 of 89 PageID #: 26
27

instruct, and aid one or more persons in the United States to make, use, sell, offer to sell and/or 

import the TI Accused Products. For example, TI, or an entity under TI’s direction or control, 

advertises, offers for sale, and/or otherwise promotes the TI Accused Products on its website.12 

TI, or one or more related entities, further publishes and distributes data sheets, manuals, and 

guides for the TI Accused Products.13 Therein, on information and belief, TI describes and touts 

the use of the subject matter claimed in the Asserted Patents, as described and alleged herein.

103. TI has contributorily infringed and continues to contributorily infringe the Asserted 

Patents by selling or offering to sell TI Accused Products, knowing them to be especially made or 

especially adapted for practicing the inventions of the Asserted Patents and not a staple article or 

commodity of commerce suitable for substantial non-infringing use.

104. On information and belief, and as alleged above, TI has known of the existence of 

the Asserted Patents and their applicability to TI’s Accused Products, and its acts of infringement 

have been willful and in disregard for the Asserted Patents, without any reasonable basis for 

believing that it had a right to engage in the infringing conduct, at least as of the dates of knowledge 

of the Asserted Patents alleged above, and no later than the date of this Complaint.

105. On information and belief, Ford’s products that infringe the Asserted Patents 

(collectively, “Ford Accused Products”) include the following: 

12 See, e.g., https://www.ti.com/lit/pdf/spry313 (last visited December 19, 2022) (Jacinto 6 marketing white paper); 

https://www.ti.com/lit/pdf/spry250 (last visited December 19, 2022) (discussing TDA2x in marketing white paper); 

https://www.ti.com/lit/pdf/spry272 (last visited December 19, 2022) (TDA3x marketing white paper); 

https://www.ti.com/lit/pdf/szzp146 (last visited December 19, 2022) (CC13xx/CC26xx new product update 

presentation); https://www.ti.com/lit/pdf/swpt034 (last visited December 19, 2022) (OMAP 4 product bulletin); and 

https://www.ti.com/lit/pdf/swct010 (last visited December 19, 2022) (OMAP 5 product bulletin). 13 See, e.g., https://www.ti.com/lit/pdf/sprui29g (last visited December 19, 2022) (TDA2x manual); 

https://training.ti.com/tda2-and-tda3-processors-training-series (last visited December 19, 2022) (TDA2x and 

TDA3x training materials); https://www.ti.com/lit/pdf/swru439m (last visited December 19, 2022) (CC26xx / 

CC13xx guide); 

https://www.ti.com/lit/ug/spruif7c/spruif7c.pdf?ts=1638387986460&ref_url=https%253A%252F%252Fw (last 

visited December 19, 2022) (DRA79x manual discussing DRA794).

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 28 of 90 PageID #: 482 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 27 of 89 PageID #: 27
28

Ford Accused Products

• Ford vehicles and components thereof 

containing Jacinto processors or other TI 

integrated circuits, including for example, 

the Ford SYNC3 infotainment system and 

Ford Explorer vehicle

• Lincoln vehicles and components thereof 

containing Jacinto processors or other TI 

integrated circuits

106. The above-listed Ford Accused Products are non-limiting. Additional products of 

Ford may infringe the Asserted Patents, and the above-listed Ford Accused Products may infringe 

additional patents.

107. On information and belief, the Ford Accused Products include TI SoCs with Arteris 

interconnect technology and/or a derivative thereof.

108. Ford has infringed and continues to infringe the Asserted Patents by making, using, 

selling, offering to sell, and/or importing, without license or authority, the Ford Accused Products 

as alleged herein, which embody or use the inventions claimed in the Asserted Patents literally or 

under the doctrine of equivalents.

109. Comparison of claims of the Asserted Patents to an exemplary product of the Ford 

Accused Products are attached as Exhibit 13 (ʼ818 patent), Exhibit 14 (ʼ449 patent), Exhibit 15

(ʼ052 patent), Exhibit 16 (ʼ9893 patent), Exhibit 17 (ʼ2893) and Exhibit 18 (ʼ800 patent), which 

are incorporated herein by reference. 

110. Ford has induced infringement and continues to induce infringement of the 

Asserted Patents by actively and knowingly inducing others to make, use, sell, offer to sell, and/or 

import, without license or authority, the Ford Accused Products as alleged herein, which embody 

or use the inventions claimed in the Asserted Patents literally or under the doctrine of equivalents.

111. Ford markets, advertises, offers for sale, and/or otherwise promotes the Ford 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 29 of 90 PageID #: 483 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 28 of 89 PageID #: 28
29

Accused Products and, on information and belief, does so to actively and knowingly induce, 

encourage, instruct, and aid one or more persons in the United States to make, use, sell, offer to 

sell and/or import the Ford Accused Products. For example, Ford, or an entity under Ford’s 

direction or control, advertises, offers for sale, and/or otherwise promotes the Ford Accused 

Products on its website.14 Ford, or one or more related entities, further publishes and distributes 

data sheets, manuals, and guides for the Ford Accused Products.15 Therein, on information and 

belief, Ford describes and touts the use of the subject matter claimed in the Asserted Patents, as 

described and alleged herein.

112. Ford has contributorily infringed and continues to contributorily infringe the 

Asserted Patents by selling or offering to sell Ford Accused Products, knowing them to be 

especially made or especially adapted for practicing the inventions of the Asserted Patents and not 

a staple article or commodity of commerce suitable for substantial non-infringing use.

113. On information and belief, and as alleged above, Ford has known of the existence 

of the Asserted Patents and their applicability to Ford’s Accused Products, and its acts of 

infringement have been willful and in disregard for the Asserted Patents, without any reasonable 

basis for believing that it had a right to engage in the infringing conduct, at least as of the dates of 

knowledge of the Asserted Patents alleged above, and no later than the date of this Complaint.

114. On information and belief, Volkswagen’s products that infringe the Asserted 

Patents (collectively, “Volkswagen Accused Products”) include the following: 

14 See, e.g., https://www.ford.com/technology/sync/?gnav=footer-aboutford (last visited December 19, 2022) 

(advertising the SYNC3 and other SYNC infotainment systems); and https://www.ford.com/suvs/explorer/pricingand-incentives/?gnav=vhpnav-io (last visited December 19, 2022) (Ford Explorer Pricing and Incentives webpage). 15 See, e.g., https://www.ford.com/support/how-tos/sync/sync-3/ (last visited December 19, 2022) (providing 

numerous product support articles for SYNC3); https://www.ford.com/suvs/explorer/models/explorer/ (last visited 

December 19, 2022) (Ford Explorer overview and specifications); and 

https://www.ford.com/suvs/explorer/features/technology/#pasrk_assist (last visited December 19, 2022) (Ford 

Explorer park assist feature overview).

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 30 of 90 PageID #: 484 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 29 of 89 PageID #: 29
30

Volkswagen Accused Products

• VW vehicles and components thereof 

containing Jacinto processors or other TI 

integrated circuits, including for example, 

the MIB 3 infotainment system and the VW 

Jetta

• Audi vehicles and components thereof 

containing Jacinto processors or other TI 

integrated circuits, including for example, 

the MIB 3 infotainment system and the Audi 

A4

115. The above-listed Volkswagen Accused Products are non-limiting. Additional 

products of Volkswagen may infringe the Asserted Patents, and the above-listed Volkswagen 

Accused Products may infringe additional patents.

116. On information and belief, the Volkswagen Accused Products include TI SoCs with 

Arteris interconnect technology and/or a derivative thereof.

117. Volkswagen has infringed and continues to infringe the Asserted Patents by 

making, using, selling, offering to sell, and/or importing, without license or authority, the 

Volkswagen Accused Products as alleged herein, which embody or use the inventions claimed in 

the Asserted Patents literally or under the doctrine of equivalents.

118. Comparison of claims of the Asserted Patents to exemplary products of the 

Volkswagen Accused Products are attached as Exhibits 19 and 25 (ʼ818 patent), Exhibits 20 and 

26 (ʼ449 patent), Exhibits 21 and 27 (ʼ052 patent), Exhibits 22 and 28 (ʼ9893 patent), Exhibits 23

and 29 (ʼ2893), and Exhibits 24 and 30 (ʼ800 patent), which are incorporated herein by reference. 

119. Volkswagen has induced infringement and continues to induce infringement of the 

Asserted Patents by actively and knowingly inducing others to make, use, sell, offer to sell, and/or 

import, without license or authority, the Volkswagen Accused Products as alleged herein, which 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 31 of 90 PageID #: 485 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 30 of 89 PageID #: 30
31

embody or use the inventions claimed in the Asserted Patents literally or under the doctrine of 

equivalents.

120. Volkswagen markets, advertises, offers for sale, and/or otherwise promotes the 

Volkswagen Accused Products and, on information and belief, does so to actively and knowingly 

induce, encourage, instruct, and aid one or more persons in the United States to make, use, sell, 

offer to sell and/or import the Volkswagen Accused Products. For example, Volkswagen, or an 

entity under Volkswagen’s direction or control, advertises, offers for sale, and/or otherwise 

promotes the Volkswagen Accused Products on its website.16 Volkswagen, or one or more related 

entities, further publishes and distributes data sheets, manuals, and guides for the Volkswagen 

Accused Products.17 Therein, on information and belief, Volkswagen describes and touts the use 

of the subject matter claimed in the Asserted Patents, as described and alleged herein.

121. Volkswagen has contributorily infringed and continues to contributorily infringe 

the Asserted Patents by selling or offering to sell Volkswagen Accused Products, knowing them 

to be especially made or especially adapted for practicing the inventions of the Asserted Patents 

and not a staple article or commodity of commerce suitable for substantial non-infringing use.

122. On information and belief, and as alleged above, Volkswagen has known of the 

existence of the Asserted Patents and their applicability to Volkswagen’s Accused Products, and 

its acts of infringement have been willful and in disregard for the Asserted Patents, without any 

16 See, e.g., https://www.vw.com/en/models/taos.html (last visited December 19, 2022)(displaying offers for sale of 

2023 Taos that includes driver assistance systems); and https://www.vw.com/en/iq-drive.html (last visited December 

19, 2022) (displaying list of VW cars that utilize Volkswagen IQ.Drive); https://media.audiusa.com/enus/releases/409 (last visited December 19, 2022) (press release listing Audi models including MIB 3 infotainment 

system). . 17 See, e.g., https://www.vw.com/en/newsroom/discover-vw/iq-drive-fall.html (last visited December 19, 

2022)(discussing owner’s manuals for VW cars); and https://www.vw.com/en/iq-drive.html (last visited December 

19, 2022) (providing further guidance on IQ.Drive); https://media.audiusa.com/en-us/releases/409 (last visited 

December 19, 2022) (press release listing Audi models including MIB 3 infotainment system); 

http://ownersmanual.audiusa.com/ (last visited December 19, 2022) (database of online owner’s manuals, “The Audi 

Online Owner’s Manual features Owner’s, Radio and Navigation Manuals for Audi vehicles from model year 2008 

to current.”).

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 32 of 90 PageID #: 486 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 31 of 89 PageID #: 31
32

reasonable basis for believing that it had a right to engage in the infringing conduct, at least as of 

the dates of knowledge of the Asserted Patents alleged above, and no later than the date of this 

Complaint.

123. On information and belief, the TI Accused Products, Ford Accused Products, and 

Volkswagen Accused Products all include SoC technology that infringes each of the Asserted 

Patents. 

COUNT I – INFRINGEMENT OF U.S. PATENT NO. 7,366,818

124. Plaintiff incorporates by reference the allegations contained in paragraphs 1 to 123

above.

125. On information and belief, TI has made, used, offered for sale, sold, and/or 

imported products, including within this Judicial District, including at least the TI Accused 

Products, that infringe, either literally or under the doctrine of equivalents, one or more claims of 

the ʼ818 patent in violation of 35 U.S.C. § 271(a), including claim 1. Comparison of claim 1 of 

the ’818 patent to an exemplary product of the TI Accused Products is attached as Exhibit 7, which 

is incorporated herein by reference. 

126. On information and belief, with knowledge of the ʼ818 patent, TI has actively 

induced and continues to induce the direct infringement of one or more claims of the ʼ818 patent, 

including claim 1, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of its 

products, including at least the TI Accused Products, by selling, providing support for, providing 

instructions for use of, and/or otherwise encouraging its customers and/or end-users to directly 

infringe, either literally and/or under the doctrine of equivalents, one or more claims of the ʼ818 

patent, including claim 1, with the intent to encourage those customers and/or end users to infringe 

the ʼ818 patent.

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 33 of 90 PageID #: 487 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 32 of 89 PageID #: 32
33

127. By way of example, on information and belief, TI actively induces infringement of 

the ʼ818 patent by encouraging, instructing, and aiding one or more persons in the United States, 

including but not limited to customers and/or end users who test, operate, and use TI’s products, 

including at least the TI Accused Products, to make, use, sell, offer to sell, and/or import TI’s 

products, including at least the TI Accused Products, in a manner that infringes at least one claim 

of the ʼ818 patent, including claim 1. For example, as described above, TI actively markets, 

advertises, offers for sale, and/or otherwise promotes the TI Accused Products by publishing and 

distributing data sheets, manuals, and guides for the TI Accused Products. Therein, on information 

and belief, TI describes and touts the use of the subject matter claimed in the ʼ818 patent. 

128. On information and belief, with knowledge of the ʼ818 patent, TI also contributed 

to, and continues to contribute to, the infringement of one or more claims of the ʼ818 patent, 

including claim 1, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or importing 

the TI Accused Products, knowing them to be especially made or especially adapted for practicing 

the inventions of the ’818 patent and not a staple article or commodity of commerce suitable for 

substantial non-infringing use. This is evidenced by, among other things, the design, 

configuration, and functionality of the TI Accused Products, which are especially made or 

especially adapted for use in infringement of the ’818 patent when used for their normal and 

intended purpose. This is also evidenced by, among other things, TI’s informational and 

promotional materials described above, which describe the normal use and intended purpose of 

the TI Accused Products and demonstrate that the TI Accused Products are especially made or 

especially adapted for a use that infringes the ʼ818 patent. 

129. On information and belief, as a result of TI’s inducement of, and/or contribution to, 

infringement, its customers and/or end users made, used, sold, offered for sale, or imported, and 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 34 of 90 PageID #: 488 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 33 of 89 PageID #: 33
34

continue to make, use, sell, offer to sell, or import, TI’s products, including the TI Accused 

Products, in ways that directly infringe one or more claims of the ʼ818 patent, including claim 1. 

On information and belief, TI had actual knowledge of its customers’ and/or end users’ direct 

infringement at least by virtue of their sales, instruction, and/or otherwise promotion of TI’s 

products, including the TI Accused Products, at least as of the dates of knowledge of the ’818 

patent alleged above, and no later than the date of this Complaint.

130. On information and belief, with knowledge of the ʼ818 patent, TI has willfully, 

deliberately, and intentionally infringed the ʼ818 patent, at least as of the dates of knowledge of 

the ’818 patent alleged above, and no later than the date of this Complaint, and continues to 

willfully, deliberately, and intentionally infringe the ʼ818 patent. On information and belief, TI 

had actual knowledge of the ʼ818 patent and TI’s infringement of the ʼ818 patent at least as of the 

dates of knowledge of the ’818 patent alleged above, and no later than the date of this Complaint. 

On information and belief, after acquiring that knowledge, TI continued to directly and indirectly 

infringe the ʼ818 patent as set forth above. On information and belief, TI knew or should have 

known that its conduct amounted to infringement of the ʼ818 patent at least because TI was aware

of the ʼ818 patent and TI’s infringement of the ʼ818 patent at least as of the dates of knowledge of 

the ’818 patent alleged above, and no later than the date of this Complaint. TI was aware of its 

infringement by virtue of the ’818 patent’s fame in the semiconductor industry, TI’s expertise in 

the subject matter of the ’818 patent, TI’s technical competence to understand the scope of the 

’818 patent, and TI’s intimate familiarity with its Accused Products. Additionally, TI was aware 

of the ʼ818 patent, and TI’s infringement of the ʼ818 patent, at least as of the date of this Complaint 

because Plaintiff notified TI of such.

131. On information and belief, TI will continue to infringe the ʼ818 patent unless and 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 35 of 90 PageID #: 489 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 34 of 89 PageID #: 34
35

until it is enjoined by this Court. TI, by way of its infringing activities, has caused and continues 

to cause Plaintiff to suffer damages in an amount to be determined, and has caused and is causing 

Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against TI’s acts of 

infringement and, unless TI is enjoined from its infringement of the ʼ818 patent, Plaintiff will 

continue to suffer irreparable harm.

132. Plaintiff is entitled to recover from TI damages at least in an amount adequate to 

compensate for its infringement of the ʼ818 patent, which amount has yet to be determined, 

together with interest and costs fixed by the Court.

133. On information and belief, Ford has made, used, offered for sale, sold, and/or 

imported products, including within this Judicial District, including at least the Ford Accused 

Products, that infringe, either literally or under the doctrine of equivalents, one or more claims of 

the ʼ818 patent in violation of 35 U.S.C. § 271(a), including claim 1. A comparison of claim 1 of 

the ’818 patent to an exemplary product of the Ford Accused Products is attached as Exhibit 13, 

which is incorporated herein by reference. 

134. On information and belief, with knowledge of the ʼ818 patent, Ford has actively 

induced and continues to induce the direct infringement of one or more claims of the ʼ818 patent, 

including claim 1, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of its 

products, including at least the Ford Accused Products, by selling, providing support for, providing 

instructions for use of, and/or otherwise encouraging its customers and/or end-users to directly 

infringe, either literally and/or under the doctrine of equivalents, one or more claims of the ʼ818 

patent, including claim 1, with the intent to encourage those customers and/or end users to infringe 

the ʼ818 patent.

135. By way of example, on information and belief, Ford actively induces infringement 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 36 of 90 PageID #: 490 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 35 of 89 PageID #: 35
36

of the ʼ818 patent by encouraging, instructing, and aiding one or more persons in the United States, 

including but not limited to customers and/or end users who test, operate, and use Ford’s products, 

including at least the Ford Accused Products, to make, use, sell, offer to sell, and/or import Ford’s 

products, including at least the Ford Accused Products, in a manner that infringes at least one claim 

of the ʼ818 patent, including claim 1. For example, as described above, Ford actively markets, 

advertises, offers for sale, and/or otherwise promotes the Ford Accused Products by publishing 

and distributing data sheets, manuals, and guides for the Ford Accused Products. Therein, on 

information and belief, Ford describes and touts the use of the subject matter claimed in the ʼ818 

patent. 

136. On information and belief, with knowledge of the ʼ818 patent, Ford also contributed 

to, and continues to contribute to, the infringement of one or more claims of the ʼ818 patent, 

including claim 1, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or importing 

the Ford Accused Products, knowing them to be especially made or especially adapted for 

practicing the inventions of the ’818 patent and not a staple article or commodity of commerce 

suitable for substantial non-infringing use. This is evidenced by, among other things, the design, 

configuration, and functionality of the Ford Accused Products, which are especially made or 

especially adapted for use in infringement of the ’818 patent when used for their normal and 

intended purpose. This is also evidenced by, among other things, Ford’s informational and 

promotional materials described above, which describe the normal use and intended purpose of 

the Ford Accused Products and demonstrate that the Ford Accused Products are especially made 

or especially adapted for a use that infringes the ʼ818 patent. 

137. On information and belief, as a result of Ford’s inducement of, and/or contribution 

to, infringement, its customers and/or end users made, used, sold, offered for sale, or imported, 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 37 of 90 PageID #: 491 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 36 of 89 PageID #: 36
37

and continue to make, use, sell, offer to sell, or import, Ford’s products, including the Ford 

Accused Products, in ways that directly infringe one or more claims of the ʼ818 patent, including 

claim 1. On information and belief, Ford had actual knowledge of its customers’ and/or end users’ 

direct infringement at least by virtue of their sales, instruction, and/or otherwise promotion of

Ford’s products, including the Ford Accused Products, at least as of the dates of knowledge of the 

’818 patent alleged above, and no later than the date of this Complaint.

138. On information and belief, with knowledge of the ʼ818 patent, Ford has willfully, 

deliberately, and intentionally infringed the ʼ818 patent, at least as of the dates of knowledge of 

the ’818 patent alleged above, and no later than the date of this Complaint, and continues to 

willfully, deliberately, and intentionally infringe the ʼ818 patent. On information and belief, Ford 

had actual knowledge of the ʼ818 patent and Ford’s infringement of the ʼ818 patent at least as of 

the dates of knowledge of the ’818 patent alleged above, and no later than the date of this 

Complaint. On information and belief, after acquiring that knowledge, Ford continued to directly 

and indirectly infringe the ʼ818 patent as set forth above. On information and belief, Ford knew 

or should have known that its conduct amounted to infringement of the ʼ818 patent at least because 

Ford was aware of the ʼ818 patent and Ford’s infringement of the ʼ818 patent at least as of the 

dates of knowledge of the ’818 patent alleged above, and no later than the date of this Complaint. 

Ford was aware of its infringement by virtue of the ’818 patent’s fame in the semiconductor 

industry, Ford’s expertise in the subject matter of the ’818 patent, Ford’s technical competence to 

understand the scope of the ’818 patent, and Ford’s intimate familiarity with its Accused Products. 

Additionally, Ford was aware of the ʼ818 patent, and Ford’s infringement of the ʼ818 patent, at 

least as of the date of this Complaint because Plaintiff notified Ford of such.

139. On information and belief, Ford will continue to infringe the ʼ818 patent unless and 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 38 of 90 PageID #: 492 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 37 of 89 PageID #: 37
38

until it is enjoined by this Court. Ford, by way of its infringing activities, has caused and continues 

to cause Plaintiff to suffer damages in an amount to be determined, and has caused and is causing 

Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against Ford’s acts of 

infringement and, unless Ford is enjoined from its infringement of the ʼ818 patent, Plaintiff will 

continue to suffer irreparable harm.

140. Plaintiff is entitled to recover from Ford damages at least in an amount adequate to 

compensate for its infringement of the ʼ818 patent, which amount has yet to be determined, 

together with interest and costs fixed by the Court.

141. On information and belief, Volkswagen has made, used, offered for sale, sold, 

and/or imported products, including within this Judicial District, including at least the Volkswagen 

Accused Products, that infringe, either literally or under the doctrine of equivalents, one or more 

claims of the ʼ818 patent in violation of 35 U.S.C. § 271(a), including claim 1. Comparisons of 

claim 1 of the ’818 patent to exemplary products of the Volkswagen Accused Products are attached 

as Exhibits 19 and 25, which are incorporated herein by reference. 

142. On information and belief, with knowledge of the ʼ818 patent, Volkswagen has 

actively induced and continues to induce the direct infringement of one or more claims of the ʼ818 

patent, including claim 1, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of 

its products, including at least the Volkswagen Accused Products, by selling, providing support 

for, providing instructions for use of, and/or otherwise encouraging its customers and/or end-users 

to directly infringe, either literally and/or under the doctrine of equivalents, one or more claims of 

the ʼ818 patent, including claim 1, with the intent to encourage those customers and/or end users 

to infringe the ʼ818 patent.

143. By way of example, on information and belief, Volkswagen actively induces 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 39 of 90 PageID #: 493 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 38 of 89 PageID #: 38
39

infringement of the ʼ818 patent by encouraging, instructing, and aiding one or more persons in the 

United States, including but not limited to customers and/or end users who test, operate, and use 

Volkswagen’s products, including at least the Volkswagen Accused Products, to make, use, sell, 

offer to sell, and/or import Volksagen’s products, including at least the Volkswagen Accused 

Products, in a manner that infringes at least one claim of the ʼ818 patent, including claim 1. For 

example, as described above, Volkswagen actively markets, advertises, offers for sale, and/or 

otherwise promotes the Volkswagen Accused Products by publishing and distributing data sheets, 

manuals, and guides for the Volkswagen Accused Products. Therein, on information and belief, 

Volkswagen describes and touts the use of the subject matter claimed in the ʼ818 patent. 

144. On information and belief, with knowledge of the ʼ818 patent, Volkswagen also 

contributed to, and continues to contribute to, the infringement of one or more claims of the ʼ818 

patent, including claim 1, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or 

importing the Volkswagen Accused Products, knowing them to be especially made or especially 

adapted for practicing the inventions of the ’818 patent and not a staple article or commodity of 

commerce suitable for substantial non-infringing use. This is evidenced by, among other things, 

the design, configuration, and functionality of the Volkswagen Accused Products, which are 

especially made or especially adapted for use in infringement of the ’818 patent when used for 

their normal and intended purpose. This is also evidenced by, among other things, Volkswagen’s 

informational and promotional materials described above, which describe the normal use and 

intended purpose of the Volkswagen Accused Products and demonstrate that the Volkswagen 

Accused Products are especially made or especially adapted for a use that infringes the ʼ818 patent. 

145. On information and belief, as a result of Volkswagen’s inducement of, and/or 

contribution to, infringement, its customers and/or end users made, used, sold, offered for sale, or 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 40 of 90 PageID #: 494 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 39 of 89 PageID #: 39
40

imported, and continue to make, use, sell, offer to sell, or import, Volkswagen’s products, 

including the Volkswagen Accused Products, in ways that directly infringe one or more claims of 

the ʼ818 patent, including claim 1. On information and belief, Volkswagen had actual knowledge 

of its customers’ and/or end users’ direct infringement at least by virtue of their sales, instruction, 

and/or otherwise promotion of Volkswagen’s products, including the Volkswagen Accused 

Products, at least as of the dates of knowledge of the ’818 patent alleged above, and no later than 

the date of this Complaint.

146. On information and belief, with knowledge of the ʼ818 patent, Volkswagen has 

willfully, deliberately, and intentionally infringed the ʼ818 patent, at least as of the dates of 

knowledge of the ’818 patent alleged above, and no later than the date of this Complaint, and 

continues to willfully, deliberately, and intentionally infringe the ʼ818 patent. On information and 

belief, Volkswagen had actual knowledge of the ʼ818 patent and Volkswagen’s infringement of 

the ʼ818 patent at least as of the dates of knowledge of the ’818 patent alleged above, and no later 

than the date of this Complaint. On information and belief, after acquiring that knowledge, 

Volkswagen continued to directly and indirectly infringe the ʼ818 patent as set forth above. On 

information and belief, Volkswagen knew or should have known that its conduct amounted to 

infringement of the ʼ818 patent at least because Volkswagen was aware of the ʼ818 patent and 

Volkswagen’s infringement of the ʼ818 patent at least as of the dates of knowledge of the ’818 

patent alleged above, and no later than the date of this Complaint. Volkswagen was aware of its 

infringement by virtue of the ’818 patent’s fame in the semiconductor industry, Volkswagen’s 

expertise in the subject matter of the ’818 patent, Volkswagen’s technical competence to 

understand the scope of the ’818 patent, and Volkswagen’s intimate familiarity with its Accused 

Products. Additionally, Volkswagen was aware of the ʼ818 patent, and Volkswagen’s 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 41 of 90 PageID #: 495 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 40 of 89 PageID #: 40
41

infringement of the ʼ818 patent, at least as of the date of this Complaint because Plaintiff notified 

Volkswagen of such.

147. On information and belief, Volkswagen will continue to infringe the ʼ818 patent 

unless and until it is enjoined by this Court. Volkswagen, by way of its infringing activities, has 

caused and continues to cause Plaintiff to suffer damages in an amount to be determined, and has 

caused and is causing Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against 

Volkswagen’s acts of infringement and, unless Volkswagen is enjoined from its infringement of 

the ʼ818 patent, Plaintiff will continue to suffer irreparable harm.

148. Plaintiff is entitled to recover from Volkswagen damages at least in an amount 

adequate to compensate for its infringement of the ʼ818 patent, which amount has yet to be 

determined, together with interest and costs fixed by the Court.

COUNT II – INFRINGEMENT OF U.S. PATENT NO. 7,373,449

149. Plaintiff incorporates by reference the allegations contained in paragraphs 1 to 148

above.

150. On information and belief, TI has made, used, offered for sale, sold, and/or 

imported products, including within this Judicial District, including at least the TI Accused 

Products, that infringe, either literally or under the doctrine of equivalents, one or more claims of 

the ʼ449 patent in violation of 35 U.S.C. § 271(a), including claim 10. Comparison of claim 10 of 

the ʼ449 patent to an exemplary product of the TI Accused Products is attached as Exhibit 8, which 

is incorporated herein by reference. 

151. On information and belief, with knowledge of the ʼ449 patent, TI has actively 

induced and continues to induce the direct infringement of one or more claims of the ʼ449 patent, 

including claim 10, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of its 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 42 of 90 PageID #: 496 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 41 of 89 PageID #: 41
42

products, including at least the TI Accused Products, by selling, providing support for, providing 

instructions for use of, and/or otherwise encouraging its customers and/or end-users to directly 

infringe, either literally and/or under the doctrine of equivalents, one or more claims of the ʼ449 

patent, including claim 10, with the intent to encourage those customers and/or end users to 

infringe the ʼ449 patent.

152. By way of example, on information and belief, TI actively induces infringement of 

the ʼ449 patent by encouraging, instructing, and aiding one or more persons in the United States, 

including but not limited to customers and/or end users who test, operate, and use TI’s products, 

including at least the TI Accused Products, to make, use, sell, offer to sell, and/or import TI’s 

products, including at least the TI Accused Products, in a manner that infringes at least one claim 

of the ʼ449 patent, including claim 10. For example, as described above, TI actively markets, 

advertises, offers for sale, and/or otherwise promotes the TI Accused Products by publishing and 

distributing data sheets, manuals, and guides for the TI Accused Products. Therein, on information 

and belief, TI describes and touts the use of the subject matter claimed in the ʼ449 patent. 

153. On information and belief, with knowledge of the ʼ449 patent, TI also contributed 

to, and continues to contribute to, the infringement of one or more claims of the ʼ449 patent, 

including claim 10, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or importing 

the TI Accused Products, knowing them to be especially made or especially adapted for practicing 

the inventions of the ʼ449 patent and not a staple article or commodity of commerce suitable for 

substantial non-infringing use. This is evidenced by, among other things, the design, 

configuration, and functionality of the TI Accused Products, which are especially made or 

especially adapted for use in infringement of the ʼ449 patent when used for their normal and 

intended purpose. This is also evidenced by, among other things, TI’s informational and 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 43 of 90 PageID #: 497 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 42 of 89 PageID #: 42
43

promotional materials described above, which describe the normal use and intended purpose of 

the TI Accused Products and demonstrate that the TI Accused Products are especially made or 

especially adapted for a use that infringes the ʼ449 patent. 

154. On information and belief, as a result of TI’s inducement of, and/or contribution to, 

infringement, its customers and/or end users made, used, sold, offered for sale, or imported, and 

continue to make, use, sell, offer to sell, or import, TI’s products, including the TI Accused 

Products, in ways that directly infringe one or more claims of the ʼ449 patent, including claim 10. 

On information and belief, TI had actual knowledge of its customers’ and/or end users’ direct 

infringement at least by virtue of their sales, instruction, and/or otherwise promotion of TI’s 

products, including the TI Accused Products, at least as of the dates of knowledge of the ’449 

patent alleged above, and no later than the date of this Complaint.

155. On information and belief, with knowledge of the ʼ449 patent, TI has willfully, 

deliberately, and intentionally infringed the ʼ449 patent, at least as of the dates of knowledge of 

the ’449 patent alleged above, and no later than the date of this Complaint, and continues to 

willfully, deliberately, and intentionally infringe the ʼ449 patent. On information and belief, TI 

had actual knowledge of the ʼ449 patent and TI’s infringement of the ʼ449 patent at least as of the 

dates of knowledge of the ’449 patent alleged above, and no later than the date of this Complaint. 

On information and belief, after acquiring that knowledge, TI continued to directly and indirectly 

infringe the ʼ449 patent as set forth above. On information and belief, TI knew or should have 

known that its conduct amounted to infringement of the ʼ449 patent at least because TI was aware 

of the ʼ449 patent and TI’s infringement of the ʼ449 patent at least as of the dates of knowledge of 

the ’449 patent alleged above, and no later than the date of this Complaint. TI was aware of its 

infringement by virtue of the ’449 patent’s fame in the semiconductor industry, TI’s expertise in 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 44 of 90 PageID #: 498 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 43 of 89 PageID #: 43
44

the subject matter of the ’449 patent, TI’s technical competence to understand the scope of the 

’449 patent, and TI’s intimate familiarity with its Accused Products. Additionally, TI was aware 

of the ʼ449 patent, and TI’s infringement of the ʼ449 patent, at least as of the date of this Complaint 

because Plaintiff notified TI of such.

156. On information and belief, TI will continue to infringe the ʼ449 patent unless and 

until it is enjoined by this Court. TI, by way of its infringing activities, has caused and continues 

to cause Plaintiff to suffer damages in an amount to be determined, and has caused and is causing 

Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against TI’s acts of 

infringement and, unless TI is enjoined from its infringement of the ʼ449 patent, Plaintiff will 

continue to suffer irreparable harm.

157. Plaintiff is entitled to recover from TI damages at least in an amount adequate to 

compensate for its infringement of the ʼ449 patent, which amount has yet to be determined, 

together with interest and costs fixed by the Court.

158. On information and belief, Ford has made, used, offered for sale, sold, and/or 

imported products, including within this Judicial District, including at least the Ford Accused 

Products, that infringe, either literally or under the doctrine of equivalents, one or more claims of 

the ʼ449 patent in violation of 35 U.S.C. § 271(a), including claim 10. A comparison of claim 10

of the ʼ449 patent to an exemplary product of the Ford Accused Products is attached as Exhibit 14, 

which is incorporated herein by reference. 

159. On information and belief, with knowledge of the ʼ449 patent, Ford has actively 

induced and continues to induce the direct infringement of one or more claims of the ʼ449 patent, 

including claim 10, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of its 

products, including at least the Ford Accused Products, by selling, providing support for, providing 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 45 of 90 PageID #: 499 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 44 of 89 PageID #: 44
45

instructions for use of, and/or otherwise encouraging its customers and/or end-users to directly 

infringe, either literally and/or under the doctrine of equivalents, one or more claims of the ʼ449 

patent, including claim 10, with the intent to encourage those customers and/or end users to 

infringe the ʼ449 patent.

160. By way of example, on information and belief, Ford actively induces infringement 

of the ʼ449 patent by encouraging, instructing, and aiding one or more persons in the United States, 

including but not limited to customers and/or end users who test, operate, and use Ford’s products, 

including at least the Ford Accused Products, to make, use, sell, offer to sell, and/or import Ford’s 

products, including at least the Ford Accused Products, in a manner that infringes at least one claim 

of the ʼ449 patent, including claim 10. For example, as described above, Ford actively markets, 

advertises, offers for sale, and/or otherwise promotes the Ford Accused Products by publishing 

and distributing data sheets, manuals, and guides for the Ford Accused Products. Therein, on 

information and belief, Ford describes and touts the use of the subject matter claimed in the ʼ449 

patent. 

161. On information and belief, with knowledge of the ʼ449 patent, Ford also contributed 

to, and continues to contribute to, the infringement of one or more claims of the ʼ449 patent, 

including claim 10, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or importing 

the Ford Accused Products, knowing them to be especially made or especially adapted for 

practicing the inventions of the ʼ449 patent and not a staple article or commodity of commerce 

suitable for substantial non-infringing use. This is evidenced by, among other things, the design, 

configuration, and functionality of the Ford Accused Products, which are especially made or 

especially adapted for use in infringement of the ʼ449 patent when used for their normal and 

intended purpose. This is also evidenced by, among other things, Ford’s informational and 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 46 of 90 PageID #: 500 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 45 of 89 PageID #: 45
46

promotional materials described above, which describe the normal use and intended purpose of

the Ford Accused Products and demonstrate that the Ford Accused Products are especially made 

or especially adapted for a use that infringes the ʼ449 patent. 

162. On information and belief, as a result of Ford’s inducement of, and/or contribution 

to, infringement, its customers and/or end users made, used, sold, offered for sale, or imported, 

and continue to make, use, sell, offer to sell, or import, Ford’s products, including the Ford 

Accused Products, in ways that directly infringe one or more claims of the ʼ449 patent, including 

claim 10. On information and belief, Ford had actual knowledge of its customers’ and/or end 

users’ direct infringement at least by virtue of their sales, instruction, and/or otherwise promotion 

of Ford’s products, including the Ford Accused Products, at least as of the dates of knowledge of 

the ’449 patent alleged above, and no later than the date of this Complaint.

163. On information and belief, with knowledge of the ʼ449 patent, Ford has willfully, 

deliberately, and intentionally infringed the ʼ449 patent, at least as of the dates of knowledge of 

the ’449 patent alleged above, and no later than the date of this Complaint, and continues to 

willfully, deliberately, and intentionally infringe the ʼ449 patent. On information and belief, Ford 

had actual knowledge of the ʼ449 patent and Ford’s infringement of the ʼ449 patent at least as of 

the dates of knowledge of the ’449 patent alleged above, and no later than the date of this 

Complaint. On information and belief, after acquiring that knowledge, Ford continued to directly 

and indirectly infringe the ʼ449 patent as set forth above. On information and belief, Ford knew 

or should have known that its conduct amounted to infringement of the ʼ449 patent at least because 

Ford was aware of the ʼ449 patent and Ford’s infringement of the ʼ449 patent at least as of the 

dates of knowledge of the ’449 patent alleged above, and no later than the date of this Complaint. 

Ford was aware of its infringement by virtue of the ’449 patent’s fame in the semiconductor 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 47 of 90 PageID #: 501 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 46 of 89 PageID #: 46
47

industry, Ford’s expertise in the subject matter of the ’449 patent, Ford’s technical competence to 

understand the scope of the ’449 patent, and Ford’s intimate familiarity with its Accused Products. 

Additionally, Ford was aware of the ʼ449 patent, and Ford’s infringement of the ʼ449 patent, at 

least as of the date of this Complaint because Plaintiff notified Ford of such.

164. On information and belief, Ford will continue to infringe the ʼ449 patent unless and 

until it is enjoined by this Court. Ford, by way of its infringing activities, has caused and continues 

to cause Plaintiff to suffer damages in an amount to be determined, and has caused and is causing

Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against Ford’s acts of 

infringement and, unless Ford is enjoined from its infringement of the ʼ449 patent, Plaintiff will 

continue to suffer irreparable harm.

165. Plaintiff is entitled to recover from Ford damages at least in an amount adequate to 

compensate for its infringement of the ʼ449 patent, which amount has yet to be determined, 

together with interest and costs fixed by the Court.

166. On information and belief, Volkswagen has made, used, offered for sale, sold, 

and/or imported products, including within this Judicial District, including at least the Volkswagen 

Accused Products, that infringe, either literally or under the doctrine of equivalents, one or more 

claims of the ʼ449 patent in violation of 35 U.S.C. § 271(a), including claim 10. Comparisons of 

claim 10 of the ʼ449 patent to exemplary products of the Volkswagen Accused Products are

attached as Exhibits 20 and 26, which are incorporated herein by reference. 

167. On information and belief, with knowledge of the ʼ449 patent, Volkswagen has 

actively induced and continues to induce the direct infringement of one or more claims of the ʼ449 

patent, including claim 10, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of 

its products, including at least the Volkswagen Accused Products, by selling, providing support 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 48 of 90 PageID #: 502 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 47 of 89 PageID #: 47
48

for, providing instructions for use of, and/or otherwise encouraging its customers and/or end-users 

to directly infringe, either literally and/or under the doctrine of equivalents, one or more claims of 

the ʼ449 patent, including claim 10, with the intent to encourage those customers and/or end users 

to infringe the ʼ449 patent.

168. By way of example, on information and belief, Volkswagen actively induces 

infringement of the ʼ449 patent by encouraging, instructing, and aiding one or more persons in the 

United States, including but not limited to customers and/or end users who test, operate, and use 

Volkswagen’s products, including at least the Volkswagen Accused Products, to make, use, sell, 

offer to sell, and/or import Volkswagen’s products, including at least the Volkswagen Accused 

Products, in a manner that infringes at least one claim of the ʼ449 patent, including claim 10. For 

example, as described above, Volkswagen actively markets, advertises, offers for sale, and/or 

otherwise promotes the Volkswagen Accused Products by publishing and distributing data sheets, 

manuals, and guides for the Volkswagen Accused Products. Therein, on information and belief, 

Volkswagen describes and touts the use of the subject matter claimed in the ʼ449 patent. 

169. On information and belief, with knowledge of the ʼ449 patent, Volkswagen also 

contributed to, and continues to contribute to, the infringement of one or more claims of the ʼ449 

patent, including claim 10, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or 

importing the Volkswagen Accused Products, knowing them to be especially made or especially 

adapted for practicing the inventions of the ʼ449 patent and not a staple article or commodity of 

commerce suitable for substantial non-infringing use. This is evidenced by, among other things, 

the design, configuration, and functionality of the Volkswagen Accused Products, which are 

especially made or especially adapted for use in infringement of the ʼ449 patent when used for 

their normal and intended purpose. This is also evidenced by, among other things, Volkswagen’s 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 49 of 90 PageID #: 503 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 48 of 89 PageID #: 48
49

informational and promotional materials described above, which describe the normal use and 

intended purpose of the Volkswagen Accused Products and demonstrate that the Volkswagen 

Accused Products are especially made or especially adapted for a use that infringes the ʼ449 patent. 

170. On information and belief, as a result of Volkswagen’s inducement of, and/or 

contribution to, infringement, its customers and/or end users made, used, sold, offered for sale, or 

imported, and continue to make, use, sell, offer to sell, or import, Volkswagen’s products, 

including the Volkswagen Accused Products, in ways that directly infringe one or more claims of 

the ʼ449 patent, including claim 10. On information and belief, Volkswagen had actual knowledge 

of its customers’ and/or end users’ direct infringement at least by virtue of their sales, instruction, 

and/or otherwise promotion of Volkswagen’s products, including the Volkswagen Accused 

Products, at least as of the dates of knowledge of the ’449 patent alleged above, and no later than 

the date of this Complaint.

171. On information and belief, with knowledge of the ʼ449 patent, Volkswagen has 

willfully, deliberately, and intentionally infringed the ʼ449 patent, at least as of the dates of 

knowledge of the ’449 patent alleged above, and no later than the date of this Complaint, and 

continues to willfully, deliberately, and intentionally infringe the ʼ449 patent. On information and 

belief, Volkswagen had actual knowledge of the ʼ449 patent and Volkswagen’s infringement of 

the ʼ449 patent at least as of the dates of knowledge of the ’449 patent alleged above, and no later 

than the date of this Complaint. On information and belief, after acquiring that knowledge, 

Volkswagen continued to directly and indirectly infringe the ʼ449 patent as set forth above. On 

information and belief, Volkswagen knew or should have known that its conduct amounted to 

infringement of the ʼ449 patent at least because Volkswagen was aware of the ʼ449 patent and 

Volkswagen’s infringement of the ʼ449 patent at least as of the dates of knowledge of the ’449 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 50 of 90 PageID #: 504 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 49 of 89 PageID #: 49
50

patent alleged above, and no later than the date of this Complaint. Volkswagen was aware of its 

infringement by virtue of the ’449 patent’s fame in the semiconductor industry, Volkswagen’s 

expertise in the subject matter of the ’449 patent, Volkswagen’s technical competence to 

understand the scope of the ’449 patent, and Volkswagen’s intimate familiarity with its Accused 

Products. Additionally, Volkswagen was aware of the ʼ449 patent, and Volkswagen’s 

infringement of the ʼ449 patent, at least as of the date of this Complaint because Plaintiff notified 

Volkswagen of such.

172. On information and belief, Volkswagen will continue to infringe the ʼ449 patent 

unless and until it is enjoined by this Court. Volkswagen , by way of its infringing activities, has 

caused and continues to cause Plaintiff to suffer damages in an amount to be determined, and has 

caused and is causing Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against 

Volkswagen’s acts of infringement and, unless Volkswagen is enjoined from its infringement of 

the ʼ449 patent, Plaintiff will continue to suffer irreparable harm.

173. Plaintiff is entitled to recover from Volkswagen damages at least in an amount 

adequate to compensate for its infringement of the ʼ449 patent, which amount has yet to be 

determined, together with interest and costs fixed by the Court.

COUNT III – INFRINGEMENT OF U.S. PATENT NO. 7,594,052

174. Plaintiff incorporates by reference the allegations contained in paragraphs 1 to 173

above.

175. On information and belief, TI has made, used, offered for sale, sold, and/or 

imported products, including within this Judicial District, including at least the TI Accused 

Products, that infringe, either literally or under the doctrine of equivalents, one or more claims of 

the ʼ052 patent in violation of 35 U.S.C. § 271(a), including claim 6. Comparison of claim 6 of 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 51 of 90 PageID #: 505 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 50 of 89 PageID #: 50
51

the ʼ052 patent to an exemplary product of the TI Accused Products is attached as Exhibit 9, which 

is incorporated herein by reference. 

176. On information and belief, with knowledge of the ʼ052 patent, TI has actively 

induced and continues to induce the direct infringement of one or more claims of the ʼ052 patent, 

including claim 6, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of its 

products, including at least the TI Accused Products, by selling, providing support for, providing 

instructions for use of, and/or otherwise encouraging its customers and/or end-users to directly 

infringe, either literally and/or under the doctrine of equivalents, one or more claims of the ʼ052 

patent, including claim 6, with the intent to encourage those customers and/or end users to infringe 

the ʼ052 patent.

177. By way of example, on information and belief, TI actively induces infringement of 

the ʼ052 patent by encouraging, instructing, and aiding one or more persons in the United States, 

including but not limited to customers and/or end users who test, operate, and use TI’s products, 

including at least the TI Accused Products, to make, use, sell, offer to sell, and/or import TI’s 

products, including at least the TI Accused Products, in a manner that infringes at least one claim 

of the ʼ052 patent, including claim 6. For example, as described above, TI actively markets, 

advertises, offers for sale, and/or otherwise promotes the TI Accused Products by publishing and 

distributing data sheets, manuals, and guides for the TI Accused Products. Therein, on information 

and belief, TI describes and touts the use of the subject matter claimed in the ʼ052 patent. 

178. On information and belief, with knowledge of the ʼ052 patent, TI also contributed 

to, and continues to contribute to, the infringement of one or more claims of the ʼ052 patent, 

including claim 6, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or importing 

the TI Accused Products, knowing them to be especially made or especially adapted for practicing 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 52 of 90 PageID #: 506 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 51 of 89 PageID #: 51
52

the inventions of the ʼ052 patent and not a staple article or commodity of commerce suitable for 

substantial non-infringing use. This is evidenced by, among other things, the design, 

configuration, and functionality of the TI Accused Products, which are especially made or 

especially adapted for use in infringement of the ʼ052 patent when used for their normal and 

intended purpose. This is also evidenced by, among other things, TI’s informational and 

promotional materials described above, which describe the normal use and intended purpose of 

the TI Accused Products and demonstrate that the TI Accused Products are especially made or 

especially adapted for a use that infringes the ʼ052 patent. 

179. On information and belief, as a result of TI’s inducement of, and/or contribution to, 

infringement, its customers and/or end users made, used, sold, offered for sale, or imported, and 

continue to make, use, sell, offer to sell, or import, TI’s products, including the TI Accused 

Products, in ways that directly infringe one or more claims of the ʼ052 patent, including claim 6. 

On information and belief, TI had actual knowledge of its customers’ and/or end users’ direct 

infringement at least by virtue of their sales, instruction, and/or otherwise promotion of TI’s 

products, including the TI Accused Products, at least as of the dates of knowledge of the ’052 

patent alleged above, and no later than the date of this Complaint.

180. On information and belief, with knowledge of the ʼ052 patent, TI has willfully, 

deliberately, and intentionally infringed the ʼ052 patent, at least as of the dates of knowledge of 

the ’052 patent alleged above, and no later than the date of this Complaint, and continues to 

willfully, deliberately, and intentionally infringe the ʼ052 patent. On information and belief, TI 

had actual knowledge of the ʼ052 patent and TI’s infringement of the ʼ052 patent at least as of the 

dates of knowledge of the ’052 patent alleged above, and no later than the date of this Complaint. 

On information and belief, after acquiring that knowledge, TI continued to directly and indirectly 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 53 of 90 PageID #: 507 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 52 of 89 PageID #: 52
53

infringe the ʼ052 patent as set forth above. On information and belief, TI knew or should have 

known that its conduct amounted to infringement of the ʼ052 patent at least because TI was aware 

of the ʼ052 patent and TI’s infringement of the ʼ052 patent at least as of the dates of knowledge of 

the ’052 patent alleged above, and no later than the date of this Complaint. TI was aware of its 

infringement by virtue of the ’052 patent’s fame in the semiconductor industry, TI’s expertise in 

the subject matter of the ’052 patent, TI’s technical competence to understand the scope of the 

’052 patent, and TI’s intimate familiarity with its Accused Products. Additionally, TI was aware 

of the ʼ052 patent, and TI’s infringement of the ʼ052 patent, at least as of the date of this Complaint 

because Plaintiff notified TI of such.

181. On information and belief, TI will continue to infringe the ʼ052 patent unless and 

until it is enjoined by this Court. TI, by way of its infringing activities, has caused and continues 

to cause Plaintiff to suffer damages in an amount to be determined, and has caused and is causing 

Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against TI’s acts of 

infringement and, unless TI is enjoined from its infringement of the ʼ052 patent, Plaintiff will 

continue to suffer irreparable harm.

182. Plaintiff is entitled to recover from TI damages at least in an amount adequate to 

compensate for its infringement of the ʼ052 patent, which amount has yet to be determined, 

together with interest and costs fixed by the Court.

183. On information and belief, Ford has made, used, offered for sale, sold, and/or 

imported products, including within this Judicial District, including at least the Ford Accused 

Products, that infringe, either literally or under the doctrine of equivalents, one or more claims of 

the ʼ052 patent in violation of 35 U.S.C. § 271(a), including claim 6. A comparison of claim 6 of 

the ʼ052 patent to an exemplary product of the Ford Accused Products is attached as Exhibit 15, 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 54 of 90 PageID #: 508 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 53 of 89 PageID #: 53
54

which is incorporated herein by reference. 

184. On information and belief, with knowledge of the ʼ052 patent, Ford has actively 

induced and continues to induce the direct infringement of one or more claims of the ʼ052 patent, 

including claim 6, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of its 

products, including at least the Ford Accused Products, by selling, providing support for, providing 

instructions for use of, and/or otherwise encouraging its customers and/or end-users to directly 

infringe, either literally and/or under the doctrine of equivalents, one or more claims of the ʼ052 

patent, including claim 6, with the intent to encourage those customers and/or end users to infringe 

the ʼ052 patent.

185. By way of example, on information and belief, Ford actively induces infringement 

of the ʼ052 patent by encouraging, instructing, and aiding one or more persons in the United States, 

including but not limited to customers and/or end users who test, operate, and use Ford’s products, 

including at least the Ford Accused Products, to make, use, sell, offer to sell, and/or import Ford’s 

products, including at least the Ford Accused Products, in a manner that infringes at least one claim 

of the ʼ052 patent, including claim 6. For example, as described above, Ford actively markets, 

advertises, offers for sale, and/or otherwise promotes the Ford Accused Products by publishing 

and distributing data sheets, manuals, and guides for the Ford Accused Products. Therein, on 

information and belief, Ford describes and touts the use of the subject matter claimed in the ʼ052 

patent. 

186. On information and belief, with knowledge of the ʼ052 patent, Ford also contributed 

to, and continues to contribute to, the infringement of one or more claims of the ʼ052 patent, 

including claim 6, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or importing 

the Ford Accused Products, knowing them to be especially made or especially adapted for 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 55 of 90 PageID #: 509 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 54 of 89 PageID #: 54
55

practicing the inventions of the ʼ052 patent and not a staple article or commodity of commerce 

suitable for substantial non-infringing use. This is evidenced by, among other things, the design, 

configuration, and functionality of the Ford Accused Products, which are especially made or 

especially adapted for use in infringement of the ʼ052 patent when used for their normal and 

intended purpose. This is also evidenced by, among other things, Ford’s informational and 

promotional materials described above, which describe the normal use and intended purpose of 

the Ford Accused Products and demonstrate that the Ford Accused Products are especially made 

or especially adapted for a use that infringes the ʼ052 patent. 

187. On information and belief, as a result of Ford’s inducement of, and/or contribution 

to, infringement, its customers and/or end users made, used, sold, offered for sale, or imported, 

and continue to make, use, sell, offer to sell, or import, Ford’s products, including the Ford 

Accused Products, in ways that directly infringe one or more claims of the ʼ052 patent, including 

claim 6. On information and belief, Ford had actual knowledge of its customers’ and/or end users’ 

direct infringement at least by virtue of their sales, instruction, and/or otherwise promotion of 

Ford’s products, including the Ford Accused Products, at least as of the dates of knowledge of the 

’052 patent alleged above, and no later than the date of this Complaint.

188. On information and belief, with knowledge of the ʼ052 patent, Ford has willfully, 

deliberately, and intentionally infringed the ʼ052 patent, at least as of the dates of knowledge of 

the ’052 patent alleged above, and no later than the date of this Complaint, and continues to 

willfully, deliberately, and intentionally infringe the ʼ052 patent. On information and belief, Ford 

had actual knowledge of the ʼ052 patent and Ford’s infringement of the ʼ052 patent at least as of 

the dates of knowledge of the ’052 patent alleged above, and no later than the date of this 

Complaint. On information and belief, after acquiring that knowledge, Ford continued to directly 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 56 of 90 PageID #: 510 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 55 of 89 PageID #: 55
56

and indirectly infringe the ʼ052 patent as set forth above. On information and belief, Ford knew 

or should have known that its conduct amounted to infringement of the ʼ052 patent at least because 

Ford was aware of the ʼ052 patent and Ford’s infringement of the ʼ052 patent at least as of the 

dates of knowledge of the ’052 patent alleged above, and no later than the date of this Complaint. 

Ford was aware of its infringement by virtue of the ’052 patent’s fame in the semiconductor 

industry, Ford’s expertise in the subject matter of the ’052 patent, Ford’s technical competence to 

understand the scope of the ’052 patent, and Ford’s intimate familiarity with its Accused Products. 

Additionally, Ford was aware of the ʼ052 patent, and Ford’s infringement of the ʼ052 patent, at 

least as of the date of this Complaint because Plaintiff notified Ford of such.

189. On information and belief, Ford will continue to infringe the ʼ052 patent unless and 

until it is enjoined by this Court. Ford, by way of its infringing activities, has caused and continues 

to cause Plaintiff to suffer damages in an amount to be determined, and has caused and is causing 

Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against Ford’s acts of 

infringement and, unless Ford is enjoined from its infringement of the ʼ052 patent, Plaintiff will 

continue to suffer irreparable harm.

190. Plaintiff is entitled to recover from Ford damages at least in an amount adequate to 

compensate for its infringement of the ʼ052 patent, which amount has yet to be determined, 

together with interest and costs fixed by the Court.

191. On information and belief, Volkswagen has made, used, offered for sale, sold, 

and/or imported products, including within this Judicial District, including at least the Volkswagen 

Accused Products, that infringe, either literally or under the doctrine of equivalents, one or more 

claims of the ʼ052 patent in violation of 35 U.S.C. § 271(a), including claim 6. Comparisons of 

claim 6 of the ʼ052 patent to exemplary products of the Volkswagen Accused Products are attached 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 57 of 90 PageID #: 511 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 56 of 89 PageID #: 56
57

as Exhibits 21 and 27, which are incorporated herein by reference. 

192. On information and belief, with knowledge of the ʼ052 patent, Volkswagen has 

actively induced and continues to induce the direct infringement of one or more claims of the ʼ052 

patent, including claim 6, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of 

its products, including at least the Volkswagen Accused Products, by selling, providing support 

for, providing instructions for use of, and/or otherwise encouraging its customers and/or end-users 

to directly infringe, either literally and/or under the doctrine of equivalents, one or more claims of 

the ʼ052 patent, including claim 6, with the intent to encourage those customers and/or end users 

to infringe the ʼ052 patent.

193. By way of example, on information and belief, Volkswagen actively induces 

infringement of the ʼ052 patent by encouraging, instructing, and aiding one or more persons in the 

United States, including but not limited to customers and/or end users who test, operate, and use 

Volkswagen’s products, including at least the Volkswagen Accused Products, to make, use, sell, 

offer to sell, and/or import Volkswagen’s products, including at least the Volkswagen Accused 

Products, in a manner that infringes at least one claim of the ʼ052 patent, including claim 6. For 

example, as described above, Volkswagen actively markets, advertises, offers for sale, and/or 

otherwise promotes the Volkswagen Accused Products by publishing and distributing data sheets, 

manuals, and guides for the Volkswagen Accused Products. Therein, on information and belief, 

Volkswagen describes and touts the use of the subject matter claimed in the ʼ052 patent. 

194. On information and belief, with knowledge of the ʼ052 patent, Volkswagen also 

contributed to, and continues to contribute to, the infringement of one or more claims of the ʼ052 

patent, including claim 6, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or 

importing the Volkswagen Accused Products, knowing them to be especially made or especially 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 58 of 90 PageID #: 512 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 57 of 89 PageID #: 57
58

adapted for practicing the inventions of the ʼ052 patent and not a staple article or commodity of 

commerce suitable for substantial non-infringing use. This is evidenced by, among other things, 

the design, configuration, and functionality of the Volkswagen Accused Products, which are 

especially made or especially adapted for use in infringement of the ʼ052 patent when used for 

their normal and intended purpose. This is also evidenced by, among other things, Volkswagen’s 

informational and promotional materials described above, which describe the normal use and 

intended purpose of the Volkswagen Accused Products and demonstrate that the Volkswagen 

Accused Products are especially made or especially adapted for a use that infringes the ʼ052 patent. 

195. On information and belief, as a result of Volkswagen’s inducement of, and/or 

contribution to, infringement, its customers and/or end users made, used, sold, offered for sale, or 

imported, and continue to make, use, sell, offer to sell, or import, Volkswagen’s products, 

including the Volkswagen Accused Products, in ways that directly infringe one or more claims of 

the ʼ052 patent, including claim 6. On information and belief, Volkswagen had actual knowledge 

of its customers’ and/or end users’ direct infringement at least by virtue of their sales, instruction, 

and/or otherwise promotion of Volkswagen’s products, including the Volkswagen Accused 

Products, at least as of the dates of knowledge of the ’052 patent alleged above, and no later than 

the date of this Complaint.

196. On information and belief, with knowledge of the ʼ052 patent, Volkswagen has 

willfully, deliberately, and intentionally infringed the ʼ052 patent, at least as of the dates of 

knowledge of the ’052 patent alleged above, and no later than the date of this Complaint, and 

continues to willfully, deliberately, and intentionally infringe the ʼ052 patent. On information and 

belief, Volkswagen had actual knowledge of the ʼ052 patent and Volkswagen’s infringement of 

the ʼ052 patent at least as of the dates of knowledge of the ’052 patent alleged above, and no later 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 59 of 90 PageID #: 513 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 58 of 89 PageID #: 58
59

than the date of this Complaint. On information and belief, after acquiring that knowledge, 

Volkswagen continued to directly and indirectly infringe the ʼ052 patent as set forth above. On 

information and belief, Volkswagen knew or should have known that its conduct amounted to 

infringement of the ʼ052 patent at least because Volkswagen was aware of the ʼ052 patent and 

Volkswagen’s infringement of the ʼ052 patent at least as of the dates of knowledge of the ’052 

patent alleged above, and no later than the date of this Complaint. Volkswagen was aware of its 

infringement by virtue of the ’052 patent’s fame in the semiconductor industry, Volkswagen’s 

expertise in the subject matter of the ’052 patent, Volkswagen’s technical competence to 

understand the scope of the ’052 patent, and Volkswagen’s intimate familiarity with its Accused 

Products. Additionally, Volkswagen was aware of the ʼ052 patent, and Volkswagen’s 

infringement of the ʼ052 patent, at least as of the date of this Complaint because Plaintiff notified 

Volkswagen of such.

197. On information and belief, Volkswagen will continue to infringe the ʼ052 patent

unless and until it is enjoined by this Court. Volkswagen, by way of its infringing activities, has 

caused and continues to cause Plaintiff to suffer damages in an amount to be determined, and has 

caused and is causing Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against 

Volkswagen’s acts of infringement and, unless Volkswagen is enjoined from its infringement of 

the ʼ052 patent, Plaintiff will continue to suffer irreparable harm.

198. Plaintiff is entitled to recover from Volkswagen damages at least in an amount 

adequate to compensate for its infringement of the ʼ052 patent, which amount has yet to be 

determined, together with interest and costs fixed by the Court.

COUNT IV – INFRINGEMENT OF U.S. PATENT NO. 7,769,893

199. Plaintiff incorporates by reference the allegations contained in paragraphs 1 to 198

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 60 of 90 PageID #: 514 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 59 of 89 PageID #: 59
60

above.

200. On information and belief, TI has made, used, offered for sale, sold, and/or 

imported products, including within this Judicial District, including at least the TI Accused 

Products, that infringe, either literally or under the doctrine of equivalents, one or more claims of 

the ʼ9893 patent in violation of 35 U.S.C. § 271(a), including claim 4. Comparison of claim 4 of 

the ʼ9893 patent to an exemplary product of the TI Accused Products is attached as Exhibit 10, 

which is incorporated herein by reference. 

201. On information and belief, with knowledge of the ʼ9893 patent, TI has actively 

induced and continues to induce the direct infringement of one or more claims of the ʼ9893 patent, 

including claim 4, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of its 

products, including at least the TI Accused Products, by selling, providing support for, providing 

instructions for use of, and/or otherwise encouraging its customers and/or end-users to directly 

infringe, either literally and/or under the doctrine of equivalents, one or more claims of the ʼ9893 

patent, including claim 4, with the intent to encourage those customers and/or end users to infringe 

the ʼ9893 patent.

202. By way of example, on information and belief, TI actively induces infringement of 

the ʼ9893 patent by encouraging, instructing, and aiding one or more persons in the United States, 

including but not limited to customers and/or end users who test, operate, and use TI’s products, 

including at least the TI Accused Products, to make, use, sell, offer to sell, and/or import TI’s 

products, including at least the TI Accused Products, in a manner that infringes at least one claim 

of the ʼ9893 patent, including claim 4. For example, as described above, TI actively markets, 

advertises, offers for sale, and/or otherwise promotes the TI Accused Products by publishing and 

distributing data sheets, manuals, and guides for the TI Accused Products. Therein, on information 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 61 of 90 PageID #: 515 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 60 of 89 PageID #: 60
61

and belief, TI describes and touts the use of the subject matter claimed in the ʼ9893 patent. 

203. On information and belief, with knowledge of the ʼ9893 patent, TI also contributed 

to, and continues to contribute to, the infringement of one or more claims of the ʼ9893 patent, 

including claim 4, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or importing 

the TI Accused Products, knowing them to be especially made or especially adapted for practicing 

the inventions of the ʼ9893 patent and not a staple article or commodity of commerce suitable for 

substantial non-infringing use. This is evidenced by, among other things, the design, 

configuration, and functionality of the TI Accused Products, which are especially made or 

especially adapted for use in infringement of the ʼ9893 patent when used for their normal and 

intended purpose. This is also evidenced by, among other things, TI’s informational and 

promotional materials described above, which describe the normal use and intended purpose of 

the TI Accused Products and demonstrate that the TI Accused Products are especially made or 

especially adapted for a use that infringes the ʼ9893 patent. 

204. On information and belief, as a result of TI’s inducement of, and/or contribution to, 

infringement, its customers and/or end users made, used, sold, offered for sale, or imported, and 

continue to make, use, sell, offer to sell, or import, TI’s products, including the TI Accused 

Products, in ways that directly infringe one or more claims of the ʼ9893 patent, including claim 4. 

On information and belief, TI had actual knowledge of its customers’ and/or end users’ direct 

infringement at least by virtue of their sales, instruction, and/or otherwise promotion of TI’s 

products, including the TI Accused Products, at least as of the dates of knowledge of the ʼ9893 

patent alleged above, and no later than the date of this Complaint.

205. On information and belief, with knowledge of the ʼ9893 patent, TI has willfully, 

deliberately, and intentionally infringed the ʼ9893 patent, at least as of the dates of knowledge of 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 62 of 90 PageID #: 516 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 61 of 89 PageID #: 61
62

the ʼ9893 patent alleged above, and no later than the date of this Complaint, and continues to 

willfully, deliberately, and intentionally infringe the ʼ9893 patent. On information and belief, TI 

had actual knowledge of the ʼ9893 patent and TI’s infringement of the ʼ9893 patent at least as of 

the dates of knowledge of the ʼ9893 patent alleged above, and no later than the date of this 

Complaint. On information and belief, after acquiring that knowledge, TI continued to directly 

and indirectly infringe the ʼ9893 patent as set forth above. On information and belief, TI knew or 

should have known that its conduct amounted to infringement of the ʼ9893 patent at least because 

TI was aware of the ʼ9893 patent and TI’s infringement of the ʼ9893 patent at least as of the dates 

of knowledge of the ʼ9893 patent alleged above, and no later than the date of this Complaint. TI 

was aware of its infringement by virtue of the ’9893 patent’s fame in the semiconductor industry, 

TI’s expertise in the subject matter of the ’9893 patent, TI’s technical competence to understand 

the scope of the ’9893 patent, and TI’s intimate familiarity with its Accused Products. 

Additionally, TI was aware of the ʼ9893 patent, and TI’s infringement of the ʼ9893 patent, at least 

as of the date of this Complaint because Plaintiff notified TI of such.

206. On information and belief, TI will continue to infringe the ʼ9893 patent unless and 

until it is enjoined by this Court. TI, by way of its infringing activities, has caused and continues 

to cause Plaintiff to suffer damages in an amount to be determined, and has caused and is causing 

Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against TI’s acts of 

infringement and, unless TI is enjoined from its infringement of the ʼ9893 patent, Plaintiff will 

continue to suffer irreparable harm.

207. Plaintiff is entitled to recover from TI damages at least in an amount adequate to 

compensate for its infringement of the ʼ9893 patent, which amount has yet to be determined, 

together with interest and costs fixed by the Court.

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 63 of 90 PageID #: 517 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 62 of 89 PageID #: 62
63

208. On information and belief, Ford has made, used, offered for sale, sold, and/or 

imported products, including within this Judicial District, including at least the Ford Accused 

Products, that infringe, either literally or under the doctrine of equivalents, one or more claims of 

the ʼ9893 patent in violation of 35 U.S.C. § 271(a), including claim 4. A comparison of claim 4

of the ʼ9893 patent to an exemplary product of the Ford Accused Products is attached as Exhibit 

16, which is incorporated herein by reference. 

209. On information and belief, with knowledge of the ʼ9893 patent, Ford has actively 

induced and continues to induce the direct infringement of one or more claims of the ʼ9893 patent, 

including claim 4, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of its 

products, including at least the Ford Accused Products, by selling, providing support for, providing 

instructions for use of, and/or otherwise encouraging its customers and/or end-users to directly 

infringe, either literally and/or under the doctrine of equivalents, one or more claims of the ʼ9893 

patent, including claim 4, with the intent to encourage those customers and/or end users to infringe 

the ʼ9893 patent.

210. By way of example, on information and belief, Ford actively induces infringement 

of the ʼ9893 patent by encouraging, instructing, and aiding one or more persons in the United 

States, including but not limited to customers and/or end users who test, operate, and use Ford’s 

products, including at least the Ford Accused Products, to make, use, sell, offer to sell, and/or 

import Ford’s products, including at least the Ford Accused Products, in a manner that infringes 

at least one claim of the ʼ9893 patent, including claim 4. For example, as described above, Ford 

actively markets, advertises, offers for sale, and/or otherwise promotes the Ford Accused Products 

by publishing and distributing data sheets, manuals, and guides for the Ford Accused Products. 

Therein, on information and belief, Ford describes and touts the use of the subject matter claimed 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 64 of 90 PageID #: 518 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 63 of 89 PageID #: 63
64

in the ʼ9893 patent. 

211. On information and belief, with knowledge of the ʼ9893 patent, Ford also 

contributed to, and continues to contribute to, the infringement of one or more claims of the ʼ9893 

patent, including claim 4, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or 

importing the Ford Accused Products, knowing them to be especially made or especially adapted 

for practicing the inventions of the ʼ9893 patent and not a staple article or commodity of commerce 

suitable for substantial non-infringing use. This is evidenced by, among other things, the design, 

configuration, and functionality of the Ford Accused Products, which are especially made or 

especially adapted for use in infringement of the ʼ9893 patent when used for their normal and 

intended purpose. This is also evidenced by, among other things, Ford’s informational and 

promotional materials described above, which describe the normal use and intended purpose of 

the Ford Accused Products and demonstrate that the Ford Accused Products are especially made 

or especially adapted for a use that infringes the ʼ9893 patent. 

212. On information and belief, as a result of Ford’s inducement of, and/or contribution 

to, infringement, its customers and/or end users made, used, sold, offered for sale, or imported, 

and continue to make, use, sell, offer to sell, or import, Ford’s products, including the Ford 

Accused Products, in ways that directly infringe one or more claims of the ʼ9893 patent, including 

claim 4. On information and belief, Ford had actual knowledge of its customers’ and/or end users’ 

direct infringement at least by virtue of their sales, instruction, and/or otherwise promotion of 

Ford’s products, including the Ford Accused Products, at least as of the dates of knowledge of the 

ʼ9893 patent alleged above, and no later than the date of this Complaint.

213. On information and belief, with knowledge of the ʼ9893 patent, Ford has willfully, 

deliberately, and intentionally infringed the ʼ9893 patent, at least as of the dates of knowledge of 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 65 of 90 PageID #: 519 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 64 of 89 PageID #: 64
65

the ʼ9893 patent alleged above, and no later than the date of this Complaint, and continues to 

willfully, deliberately, and intentionally infringe the ʼ9893 patent. On information and belief, Ford 

had actual knowledge of the ʼ9893 patent and Ford’s infringement of the ʼ9893 patent at least as 

of the dates of knowledge of the ʼ9893 patent alleged above, and no later than the date of this 

Complaint. On information and belief, after acquiring that knowledge, Ford continued to directly 

and indirectly infringe the ʼ9893 patent as set forth above. On information and belief, Ford knew 

or should have known that its conduct amounted to infringement of the ʼ9893 patent at least 

because Ford was aware of the ʼ9893 patent and Ford’s infringement of the ʼ9893 patent at least 

as of the dates of knowledge of the ʼ9893 patent alleged above, and no later than the date of this 

Complaint. Ford was aware of its infringement by virtue of the ’9893 patent’s fame in the 

semiconductor industry, Ford’s expertise in the subject matter of the ’9893 patent, Ford’s technical 

competence to understand the scope of the ’9893 patent, and Ford’s intimate familiarity with its 

Accused Products. Additionally, Ford was aware of the ʼ9893 patent, and Ford’s infringement of 

the ʼ9893 patent, at least as of the date of this Complaint because Plaintiff notified Ford of such.

214. On information and belief, Ford will continue to infringe the ʼ9893 patent unless 

and until it is enjoined by this Court. Ford, by way of its infringing activities, has caused and 

continues to cause Plaintiff to suffer damages in an amount to be determined, and has caused and 

is causing Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against Ford’s acts 

of infringement and, unless Ford is enjoined from its infringement of the ʼ9893 patent, Plaintiff 

will continue to suffer irreparable harm.

215. Plaintiff is entitled to recover from Ford damages at least in an amount adequate to 

compensate for its infringement of the ʼ9893 patent, which amount has yet to be determined, 

together with interest and costs fixed by the Court.

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 66 of 90 PageID #: 520 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 65 of 89 PageID #: 65
66

216. On information and belief, Volkswagen has made, used, offered for sale, sold, 

and/or imported products, including within this Judicial District, including at least the Volkswagen 

Accused Products, that infringe, either literally or under the doctrine of equivalents, one or more 

claims of the ʼ9893 patent in violation of 35 U.S.C. § 271(a), including claim 4. Comparisons of 

claim 4 of the ʼ9893 patent to exemplary products of the Volkswagen Accused Products are

attached as Exhibits 22 and 28, which are incorporated herein by reference. 

217. On information and belief, with knowledge of the ʼ9893 patent, Volkswagen has 

actively induced and continues to induce the direct infringement of one or more claims of the ʼ9893 

patent, including claim 4, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of 

its products, including at least the Volkswagen Accused Products, by selling, providing support 

for, providing instructions for use of, and/or otherwise encouraging its customers and/or end-users 

to directly infringe, either literally and/or under the doctrine of equivalents, one or more claims of 

the ʼ9893 patent, including claim 4, with the intent to encourage those customers and/or end users 

to infringe the ʼ9893 patent.

218. By way of example, on information and belief, Volkswagen actively induces 

infringement of the ʼ9893 patent by encouraging, instructing, and aiding one or more persons in 

the United States, including but not limited to customers and/or end users who test, operate, and 

use Volkswagen’s products, including at least the Volkswagen Accused Products, to make, use, 

sell, offer to sell, and/or import Volkswagen’s products, including at least the Volkswagen 

Accused Products, in a manner that infringes at least one claim of the ʼ9893 patent, including claim 

4. For example, as described above, Volkswagen actively markets, advertises, offers for sale, 

and/or otherwise promotes the Volkswagen’s Accused Products by publishing and distributing 

data sheets, manuals, and guides for the Volkswagen Accused Products. Therein, on information 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 67 of 90 PageID #: 521 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 66 of 89 PageID #: 66
67

and belief, Volkswagen describes and touts the use of the subject matter claimed in the ʼ9893 

patent. 

219. On information and belief, with knowledge of the ʼ9893 patent, Volkswagen also 

contributed to, and continues to contribute to, the infringement of one or more claims of the ʼ9893 

patent, including claim 4, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or 

importing the Volkswagen Accused Products, knowing them to be especially made or especially 

adapted for practicing the inventions of the ʼ9893 patent and not a staple article or commodity of 

commerce suitable for substantial non-infringing use. This is evidenced by, among other things, 

the design, configuration, and functionality of the Volkswagen Accused Products, which are 

especially made or especially adapted for use in infringement of the ʼ9893 patent when used for 

their normal and intended purpose. This is also evidenced by, among other things, Volkswagen’s 

informational and promotional materials described above, which describe the normal use and 

intended purpose of the Volkswagen Accused Products and demonstrate that the Volkswagen 

Accused Products are especially made or especially adapted for a use that infringes the ʼ9893 

patent. 

220. On information and belief, as a result of Volkswagen’s inducement of, and/or 

contribution to, infringement, its customers and/or end users made, used, sold, offered for sale, or 

imported, and continue to make, use, sell, offer to sell, or import, Volkswagen’s products, 

including the Volkswagen Accused Products, in ways that directly infringe one or more claims of 

the ʼ9893 patent, including claim 4. On information and belief, Volkswagen had actual knowledge 

of its customers’ and/or end users’ direct infringement at least by virtue of their sales, instruction, 

and/or otherwise promotion of Volkswagen’s products, including the Volkswagen Accused 

Products, at least as of the dates of knowledge of the ʼ9893 patent alleged above, and no later than 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 68 of 90 PageID #: 522 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 67 of 89 PageID #: 67
68

the date of this Complaint.

221. On information and belief, with knowledge of the ʼ9893 patent, Volkswagen has 

willfully, deliberately, and intentionally infringed the ʼ9893 patent, at least as of the dates of 

knowledge of the ʼ9893 patent alleged above, and no later than the date of this Complaint, and 

continues to willfully, deliberately, and intentionally infringe the ʼ9893 patent. On information 

and belief, Volkswagen had actual knowledge of the ʼ9893 patent and Volkswagen’s infringement 

of the ʼ9893 patent at least as of the dates of knowledge of the ʼ9893 patent alleged above, and no 

later than the date of this Complaint. On information and belief, after acquiring that knowledge, 

Volkswagen continued to directly and indirectly infringe the ʼ9893 patent as set forth above. On 

information and belief, Volkswagen knew or should have known that its conduct amounted to 

infringement of the ʼ9893 patent at least because Volkswagen was aware of the ʼ9893 patent and 

Volkswagen’s infringement of the ʼ9893 patent at least as of the dates of knowledge of the ʼ9893 

patent alleged above, and no later than the date of this Complaint. Volkswagen was aware of its 

infringement by virtue of the ’9893 patent’s fame in the semiconductor industry, Volkswagen’s 

expertise in the subject matter of the ’9893 patent, Volkswagen’s technical competence to 

understand the scope of the ’9893 patent, and Volkswagen’s intimate familiarity with its Accused 

Products. Additionally, Volkswagen was aware of the ʼ9893 patent, and Volkswagen’s 

infringement of the ʼ9893 patent, at least as of the date of this Complaint because Plaintiff notified 

Volkswagen of such.

222. On information and belief, Volkswagen will continue to infringe the ʼ9893 patent 

unless and until it is enjoined by this Court. Volkswagen , by way of its infringing activities, has 

caused and continues to cause Plaintiff to suffer damages in an amount to be determined, and has 

caused and is causing Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 69 of 90 PageID #: 523 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 68 of 89 PageID #: 68
69

Volkswagen’s acts of infringement and, unless Volkswagen is enjoined from its infringement of 

the ʼ9893 patent, Plaintiff will continue to suffer irreparable harm.

223. Plaintiff is entitled to recover from Volkswagen damages at least in an amount 

adequate to compensate for its infringement of the ʼ9893 patent, which amount has yet to be 

determined, together with interest and costs fixed by the Court.

COUNT V – INFRINGEMENT OF U.S. PATENT NO. 8,072,893

224. Plaintiff incorporates by reference the allegations contained in paragraphs 1 to 223

above.

225. On information and belief, TI has made, used, offered for sale, sold, and/or 

imported products, including within this Judicial District, including at least the TI Accused 

Products, made or designed by processes that infringe, either literally or under the doctrine of 

equivalents, one or more claims of the ʼ2893 patent in violation of 35 U.S.C. § 271(a) and/or § 

271(g), including claim 10. Comparison of claim 10 of the ʼ2893 patent to an exemplary product 

of the TI Accused Products made or designed by infringing processes is attached as Exhibit 11, 

which is incorporated herein by reference. 

226. On information and belief, with knowledge of the ʼ2893 patent, TI has actively 

induced and continues to induce the direct infringement of one or more claims of the ʼ2893 patent, 

including claim 10, in violation of 35 U.S.C. § 271(b), by its suppliers, customers, and/or end users 

of its products, including at least the TI Accused Products, by selling, designing, providing support 

for, providing designs and/or specifications for, providing instructions for use of, and/or otherwise 

encouraging its suppliers, customers, and/or end-users to directly infringe, either literally and/or 

under the doctrine of equivalents, one or more claims of the ʼ2893 patent, including claim 10, with 

the intent to encourage those customers and/or end users to infringe the ʼ2893 patent.

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 70 of 90 PageID #: 524 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 69 of 89 PageID #: 69
70

227. By way of example, on information and belief, TI actively induces infringement of 

the ʼ2893 patent by encouraging, instructing, and aiding one or more persons in the United States, 

including but not limited to suppliers who supply and/or design components (for example, 

semiconductor IPs) of, test, operate, and/or use TI’s products, including at least the TI Accused 

Products or components thereof (for example, semiconductor IPs), to make, use, sell, offer to sell, 

and/or import TI’s products, including at least the TI Accused Products or components thereof (for 

example, semiconductor IPs), in a manner that infringes at least one claim of the ʼ2893 patent, 

including claim 10. For example, as described above, TI actively markets, advertises, offers for 

sale, and/or otherwise promotes the TI Accused Products by publishing and distributing data 

sheets, manuals, and guides for the TI Accused Products. Additionally, on information and belief, 

TI provides its suppliers with specifications and/or designs for components, including by way of 

example, semiconductor IPs, for the TI Accused Products. Therein, TI describes, encourages, and 

touts the use of the subject matter claimed in the ʼ2893 patent. 

228. On information and belief, with knowledge of the ʼ2893 patent, TI also contributed 

to, and continues to contribute to, the infringement of one or more claims of the ʼ2893 patent, 

including claim 10, in violation of 35 U.S.C. § 271(c), by providing specifications and/or designs 

for the TI Accused Products or components thereof (for example, semiconductor IPs), knowing 

them to be especially made or especially adapted for practicing the inventions of the ʼ2893 patent 

and not a staple article or commodity of commerce suitable for substantial non-infringing use. 

This is evidenced by, among other things, the design, configuration, and functionality of the 

specifications and/or designs for TI Accused Products or components thereof (for example, 

semiconductor IPs), which are especially made or especially adapted for use in infringement of the 

ʼ2893 patent when used for their normal and intended purpose. This is also evidenced by, among 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 71 of 90 PageID #: 525 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 70 of 89 PageID #: 70
71

other things, the normal use and intended purpose of the specifications and/or designs for the TI 

Accused Products or components thereof (for example, semiconductor IPs), which demonstrate 

that the specifications and/or designs for the TI Accused Products or components thereof (for 

example, semiconductor IPs) are especially made or especially adapted for a use that infringes the 

ʼ2893 patent. 

229. On information and belief, as a result of TI’s inducement of, and/or contribution to, 

infringement, its suppliers, customers, and/or end users designed, made, used, sold, offered for 

sale, or imported, and continue to make, use, sell, offer to sell, or import, TI’s products or 

components thereof (for example, semiconductor IPs), including the TI Accused Products, in ways 

that directly infringe one or more claims of the ʼ2893 patent, including claim 10. On information 

and belief, TI had actual knowledge of its suppliers’, customers’, and/or end users’ direct 

infringement at least by virtue of their sales, instruction, and/or otherwise promotion of TI’s 

products, including the TI Accused Products or components thereof (for example, semiconductor 

IPs), at least as of the dates of knowledge of the ʼ2893 patent alleged above, and no later than the 

date of this Complaint.

230. On information and belief, with knowledge of the ʼ2893 patent, TI has willfully, 

deliberately, and intentionally infringed the ʼ2893 patent, at least as of the dates of knowledge of 

the ʼ2893 patent alleged above, and no later than the date of this Complaint, and continues to 

willfully, deliberately, and intentionally infringe the ʼ2893 patent. On information and belief, TI 

had actual knowledge of the ʼ2893 patent and TI’s infringement of the ʼ2893 patent at least as of 

the dates of knowledge of the ʼ2893 patent alleged above, and no later than the date of this 

Complaint. On information and belief, after acquiring that knowledge, TI continued to directly 

and indirectly infringe the ʼ2893 patent as set forth above. On information and belief, TI knew or 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 72 of 90 PageID #: 526 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 71 of 89 PageID #: 71
72

should have known that its conduct amounted to infringement of the ʼ2893 patent at least because 

TI was aware of the ʼ2893 patent and TI’s infringement of the ʼ2893 patent at least as of the dates 

of knowledge of the ʼ2893 patent alleged above, and no later than the date of this Complaint. TI 

was aware of its infringement by virtue of the ’2893 patent’s fame in the semiconductor industry, 

TI’s expertise in the subject matter of the ’2893 patent, TI’s technical competence to understand 

the scope of the ’2893 patent, and TI’s intimate familiarity with its Accused Products. 

Additionally, TI was aware of the ʼ2893 patent, and TI’s infringement of the ʼ2893 patent, at least 

as of the date of this Complaint because Plaintiff notified TI of such.

231. On information and belief, TI will continue to infringe the ʼ2893 patent unless and 

until it is enjoined by this Court. TI, by way of its infringing activities, has caused and continues 

to cause Plaintiff to suffer damages in an amount to be determined, and has caused and is causing 

Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against TI’s acts of 

infringement and, unless TI is enjoined from its infringement of the ʼ2893 patent, Plaintiff will 

continue to suffer irreparable harm.

232. Plaintiff is entitled to recover from TI damages at least in an amount adequate to 

compensate for its infringement of the ʼ2893 patent, which amount has yet to be determined, 

together with interest and costs fixed by the Court.

233. On information and belief, Ford has made, used, offered for sale, sold, and/or 

imported products, including within this Judicial District, including at least the Ford Accused 

Products, that infringe, either literally or under the doctrine of equivalents, one or more claims of 

the ʼ2893 patent in violation of 35 U.S.C. § 271(a), including claim 1. A comparison of claim 1

of the ʼ2893 patent to an exemplary product of the Ford Accused Products is attached as Exhibit 

17, which is incorporated herein by reference. 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 73 of 90 PageID #: 527 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 72 of 89 PageID #: 72
73

234. On information and belief, with knowledge of the ʼ2893 patent, Ford has actively 

induced and continues to induce the direct infringement of one or more claims of the ʼ2893 patent, 

including claim 1, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of its 

products, including at least the Ford Accused Products, by selling, providing support for, providing 

instructions for use of, and/or otherwise encouraging its customers and/or end-users to directly 

infringe, either literally and/or under the doctrine of equivalents, one or more claims of the ʼ2893 

patent, including claim 1, with the intent to encourage those customers and/or end users to infringe 

the ʼ2893 patent.

235. By way of example, on information and belief, Ford actively induces infringement 

of the ʼ2893 patent by encouraging, instructing, and aiding one or more persons in the United 

States, including but not limited to customers and/or end users who test, operate, and use Ford’s 

products, including at least the Ford Accused Products, to make, use, sell, offer to sell, and/or 

import Ford’s products, including at least the Ford Accused Products, in a manner that infringes 

at least one claim of the ʼ2893 patent, including claim 1. For example, as described above, Ford 

actively markets, advertises, offers for sale, and/or otherwise promotes the Ford Accused Products 

by publishing and distributing data sheets, manuals, and guides for the Ford Accused Products. 

Therein, on information and belief, Ford describes and touts the use of the subject matter claimed 

in the ʼ2893 patent. 

236. On information and belief, with knowledge of the ʼ2893 patent, Ford also 

contributed to, and continues to contribute to, the infringement of one or more claims of the ʼ2893 

patent, including claim 1, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or 

importing the Ford Accused Products, knowing them to be especially made or especially adapted 

for practicing the inventions of the ʼ2893 patent and not a staple article or commodity of commerce 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 74 of 90 PageID #: 528 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 73 of 89 PageID #: 73
74

suitable for substantial non-infringing use. This is evidenced by, among other things, the design, 

configuration, and functionality of the Ford Accused Products, which are especially made or 

especially adapted for use in infringement of the ʼ2893 patent when used for their normal and 

intended purpose. This is also evidenced by, among other things, Ford’s informational and 

promotional materials described above, which describe the normal use and intended purpose of 

the Ford Accused Products and demonstrate that the Ford Accused Products are especially made 

or especially adapted for a use that infringes the ʼ2893 patent. 

237. On information and belief, as a result of Ford’s inducement of, and/or contribution 

to, infringement, its customers and/or end users made, used, sold, offered for sale, or imported, 

and continue to make, use, sell, offer to sell, or import, Ford’s products, including the Ford 

Accused Products, in ways that directly infringe one or more claims of the ʼ2893 patent, including 

claim 1. On information and belief, Ford had actual knowledge of its customers’ and/or end users’ 

direct infringement at least by virtue of their sales, instruction, and/or otherwise promotion of 

Ford’s products, including the Ford Accused Products, at least as of the dates of knowledge of the 

ʼ2893 patent alleged above, and no later than the date of this Complaint.

238. On information and belief, with knowledge of the ʼ2893 patent, Ford has willfully, 

deliberately, and intentionally infringed the ʼ2893 patent, at least as of the dates of knowledge of 

the ʼ2893 patent alleged above, and no later than the date of this Complaint, and continues to 

willfully, deliberately, and intentionally infringe the ʼ2893 patent. On information and belief, Ford 

had actual knowledge of the ʼ2893 patent and Ford’s infringement of the ʼ2893 patent at least as 

of the dates of knowledge of the ʼ2893 patent alleged above, and no later than the date of this 

Complaint. On information and belief, after acquiring that knowledge, Ford continued to directly 

and indirectly infringe the ʼ2893 patent as set forth above. On information and belief, Ford knew 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 75 of 90 PageID #: 529 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 74 of 89 PageID #: 74
75

or should have known that its conduct amounted to infringement of the ʼ2893 patent at least 

because Ford was aware of the ʼ2893 patent and Ford’s infringement of the ʼ2893 patent at least 

as of the dates of knowledge of the ʼ2893 patent alleged above, and no later than the date of this 

Complaint. Ford was aware of its infringement by virtue of the ’2893 patent’s fame in the 

semiconductor industry, Ford’s expertise in the subject matter of the ’2893 patent, Ford’s technical 

competence to understand the scope of the ’2893 patent, and Ford’s intimate familiarity with its 

Accused Products. Additionally, Ford was aware of the ʼ2893 patent, and Ford’s infringement of 

the ʼ2893 patent, at least as of the date of this Complaint because Plaintiff notified Ford of such.

239. On information and belief, Ford will continue to infringe the ʼ2893 patent unless 

and until it is enjoined by this Court. Ford, by way of its infringing activities, has caused and 

continues to cause Plaintiff to suffer damages in an amount to be determined, and has caused and 

is causing Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against Ford’s acts 

of infringement and, unless Ford is enjoined from its infringement of the ʼ2893 patent, Plaintiff 

will continue to suffer irreparable harm.

240. Plaintiff is entitled to recover from Ford damages at least in an amount adequate to 

compensate for its infringement of the ʼ2893 patent, which amount has yet to be determined, 

together with interest and costs fixed by the Court.

241. On information and belief, Volkswagen has made, used, offered for sale, sold, 

and/or imported products, including within this Judicial District, including at least the Volkswagen 

Accused Products, that infringe, either literally or under the doctrine of equivalents, one or more 

claims of the ʼ2893 patent in violation of 35 U.S.C. § 271(a), including claim 1. Comparisons of 

claim 1 of the ʼ2893 patent to exemplary products of the Volkswagen Accused Products are

attached as Exhibits 23 and 29, which are incorporated herein by reference. 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 76 of 90 PageID #: 530 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 75 of 89 PageID #: 75
76

242. On information and belief, with knowledge of the ʼ2893 patent, Volkswagen has 

actively induced and continues to induce the direct infringement of one or more claims of the ʼ2893 

patent, including claim 1, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of 

its products, including at least the Volkswagen Accused Products, by selling, providing support 

for, providing instructions for use of, and/or otherwise encouraging its customers and/or end-users 

to directly infringe, either literally and/or under the doctrine of equivalents, one or more claims of 

the ʼ2893 patent, including claim 1, with the intent to encourage those customers and/or end users 

to infringe the ʼ2893 patent.

243. By way of example, on information and belief, Volkswagen actively induces 

infringement of the ʼ2893 patent by encouraging, instructing, and aiding one or more persons in 

the United States, including but not limited to customers and/or end users who test, operate, and 

use Volkswagen’s products, including at least the Volkswagen Accused Products, to make, use, 

sell, offer to sell, and/or import Volkswagen’s products, including at least the Volkswagen 

Accused Products, in a manner that infringes at least one claim of the ʼ2893 patent, including claim 

1. For example, as described above, Volkswagen actively markets, advertises, offers for sale, 

and/or otherwise promotes the Volkswagen Accused Products by publishing and distributing data 

sheets, manuals, and guides for the Volkswagen Accused Products. Therein, on information and 

belief, Volkswagen describes and touts the use of the subject matter claimed in the ʼ2893 patent. 

244. On information and belief, with knowledge of the ʼ2893 patent, Volkswagen also 

contributed to, and continues to contribute to, the infringement of one or more claims of the ʼ2893 

patent, including claim 1, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or 

importing the Volkswagen Accused Products, knowing them to be especially made or especially 

adapted for practicing the inventions of the ʼ2893 patent and not a staple article or commodity of 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 77 of 90 PageID #: 531 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 76 of 89 PageID #: 76
77

commerce suitable for substantial non-infringing use. This is evidenced by, among other things, 

the design, configuration, and functionality of the Volkswagen Accused Products, which are 

especially made or especially adapted for use in infringement of the ʼ2893 patent when used for 

their normal and intended purpose. This is also evidenced by, among other things, Volkswagen’s 

informational and promotional materials described above, which describe the normal use and 

intended purpose of the Volkswagen Accused Products and demonstrate that the Volkswagen 

Accused Products are especially made or especially adapted for a use that infringes the ʼ2893 

patent. 

245. On information and belief, as a result of Volkswagen’s inducement of, and/or 

contribution to, infringement, its customers and/or end users made, used, sold, offered for sale, or 

imported, and continue to make, use, sell, offer to sell, or import, Volkswagen’s products, 

including the Volkswagen Accused Products, in ways that directly infringe one or more claims of 

the ʼ2893 patent, including claim 1. On information and belief, Volkswagen had actual knowledge 

of its customers’ and/or end users’ direct infringement at least by virtue of their sales, instruction, 

and/or otherwise promotion of Volkswagen’s products, including the Volkswagen Accused 

Products, at least as of the dates of knowledge of the ʼ2893 patent alleged above, and no later than 

the date of this Complaint.

246. On information and belief, with knowledge of the ʼ2893 patent, Volkswagen has 

willfully, deliberately, and intentionally infringed the ʼ2893 patent, at least as of the dates of 

knowledge of the ʼ2893 patent alleged above, and no later than the date of this Complaint, and 

continues to willfully, deliberately, and intentionally infringe the ʼ2893 patent. On information 

and belief, Volkswagen had actual knowledge of the ʼ2893 patent and Volkswagen’s infringement 

of the ʼ2893 patent at least as of the dates of knowledge of the ʼ2893 patent alleged above, and no 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 78 of 90 PageID #: 532 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 77 of 89 PageID #: 77
78

later than the date of this Complaint. On information and belief, after acquiring that knowledge, 

Volkswagen continued to directly and indirectly infringe the ʼ2893 patent as set forth above. On 

information and belief, Volkswagen knew or should have known that its conduct amounted to 

infringement of the ʼ2893 patent at least because Volkswagen was aware of the ʼ2893 patent and 

Volkswagen’s infringement of the ʼ2893 patent at least as of the dates of knowledge of the ʼ2893 

patent alleged above, and no later than the date of this Complaint. Volkswagen was aware of its 

infringement by virtue of the ’2893 patent’s fame in the semiconductor industry, Volkswagen’s 

expertise in the subject matter of the ’2893 patent, Volkswagen’s technical competence to 

understand the scope of the ’2893 patent, and Volkswagen’s intimate familiarity with its Accused 

Products. Additionally, Volkswagen was aware of the ʼ2893 patent, and Volkswagen’s 

infringement of the ʼ2893 patent, at least as of the date of this Complaint because Plaintiff notified 

Volkswagen of such.

247. On information and belief, Volkswagen will continue to infringe the ʼ2893 patent 

unless and until it is enjoined by this Court. Volkswagen, by way of its infringing activities, has 

caused and continues to cause Plaintiff to suffer damages in an amount to be determined, and has 

caused and is causing Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against 

Volkswagen’s acts of infringement and, unless Volkswagen is enjoined from its infringement of 

the ʼ2893 patent, Plaintiff will continue to suffer irreparable harm.

248. Plaintiff is entitled to recover from Volkswagen damages at least in an amount 

adequate to compensate for its infringement of the ʼ2893 patent, which amount has yet to be 

determined, together with interest and costs fixed by the Court.

COUNT VI – INFRINGEMENT OF U.S. PATENT NO. 8,086,800

249. Plaintiff incorporates by reference the allegations contained in paragraphs 1 to 248

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 79 of 90 PageID #: 533 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 78 of 89 PageID #: 78
79

above.

250. On information and belief, TI has made, used, offered for sale, sold, and/or 

imported products, including within this Judicial District, including at least the TI Accused 

Products, that infringe, either literally or under the doctrine of equivalents, one or more claims of 

the ʼ800 patent in violation of 35 U.S.C. § 271(a), including claim 10. Comparison of claim 10 of 

the ʼ800 patent to an exemplary product of the TI Accused Products is attached as Exhibit 12, 

which is incorporated herein by reference. 

251. On information and belief, with knowledge of the ʼ800 patent, TI has actively 

induced and continues to induce the direct infringement of one or more claims of the ʼ800 patent, 

including claim 10, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of its 

products, including at least the TI Accused Products, by selling, providing support for, providing 

instructions for use of, and/or otherwise encouraging its customers and/or end-users to directly 

infringe, either literally and/or under the doctrine of equivalents, one or more claims of the ʼ800 

patent, including claim 10, with the intent to encourage those customers and/or end users to 

infringe the ʼ800 patent.

252. By way of example, on information and belief, TI actively induces infringement of

the ʼ800 patent by encouraging, instructing, and aiding one or more persons in the United States, 

including but not limited to customers and/or end users who test, operate, and use TI’s products, 

including at least the TI Accused Products, to make, use, sell, offer to sell, and/or import TI’s 

products, including at least the TI Accused Products, in a manner that infringes at least one claim 

of the ʼ800 patent, including claim 10. For example, as described above, TI actively markets, 

advertises, offers for sale, and/or otherwise promotes the TI Accused Products by publishing and 

distributing data sheets, manuals, and guides for the TI Accused Products. Therein, on information 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 80 of 90 PageID #: 534 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 79 of 89 PageID #: 79
80

and belief, TI describes and touts the use of the subject matter claimed in the ʼ800 patent. 

253. On information and belief, with knowledge of the ʼ800 patent, TI also contributed 

to, and continues to contribute to, the infringement of one or more claims of the ʼ800 patent, 

including claim 10, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or importing 

the TI Accused Products, knowing them to be especially made or especially adapted for practicing 

the inventions of the ʼ800 patent and not a staple article or commodity of commerce suitable for 

substantial non-infringing use. This is evidenced by, among other things, the design, 

configuration, and functionality of the TI Accused Products, which are especially made or 

especially adapted for use in infringement of the ʼ800 patent when used for their normal and 

intended purpose. This is also evidenced by, among other things, TI’s informational and 

promotional materials described above, which describe the normal use and intended purpose of 

the TI Accused Products and demonstrate that the TI Accused Products are especially made or 

especially adapted for a use that infringes the ʼ800 patent. 

254. On information and belief, as a result of TI’s inducement of, and/or contribution to, 

infringement, its customers and/or end users made, used, sold, offered for sale, or imported, and 

continue to make, use, sell, offer to sell, or import, TI’s products, including the TI Accused 

Products, in ways that directly infringe one or more claims of the ʼ800 patent, including claim 10. 

On information and belief, TI had actual knowledge of its customers’ and/or end users’ direct 

infringement at least by virtue of their sales, instruction, and/or otherwise promotion of TI’s 

products, including the TI Accused Products, at least as of the dates of knowledge of the ʼ800 

patent alleged above, and no later than the date of this Complaint.

255. On information and belief, with knowledge of the ʼ800 patent, TI has willfully, 

deliberately, and intentionally infringed the ʼ800 patent, at least as of the dates of knowledge of 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 81 of 90 PageID #: 535 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 80 of 89 PageID #: 80
81

the ʼ800 patent alleged above, and no later than the date of this Complaint, and continues to 

willfully, deliberately, and intentionally infringe the ʼ800 patent. On information and belief, TI 

had actual knowledge of the ʼ800 patent and TI’s infringement of the ʼ800 patent at least as of the 

dates of knowledge of the ʼ800 patent alleged above, and no later than the date of this Complaint. 

On information and belief, after acquiring that knowledge, TI continued to directly and indirectly 

infringe the ʼ800 patent as set forth above. On information and belief, TI knew or should have

known that its conduct amounted to infringement of the ʼ800 patent at least because TI was aware 

of the ʼ800 patent and TI’s infringement of the ʼ800 patent at least as of the dates of knowledge of 

the ʼ800 patent alleged above, and no later than the date of this Complaint. TI was aware of its 

infringement by virtue of the ’800 patent’s fame in the semiconductor industry, TI’s expertise in 

the subject matter of the ’800 patent, TI’s technical competence to understand the scope of the 

’800 patent, and TI’s intimate familiarity with its Accused Products. Additionally, TI was aware 

of the ʼ800 patent, and TI’s infringement of the ʼ800 patent, at least as of the date of this Complaint 

because Plaintiff notified TI of such.

256. On information and belief, TI will continue to infringe the ʼ800 patent unless and 

until it is enjoined by this Court. TI, by way of its infringing activities, has caused and continues 

to cause Plaintiff to suffer damages in an amount to be determined, and has caused and is causing 

Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against TI’s acts of 

infringement and, unless TI is enjoined from its infringement of the ʼ800 patent, Plaintiff will 

continue to suffer irreparable harm.

257. Plaintiff is entitled to recover from TI damages at least in an amount adequate to 

compensate for its infringement of the ʼ800 patent, which amount has yet to be determined, 

together with interest and costs fixed by the Court.

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 82 of 90 PageID #: 536 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 81 of 89 PageID #: 81
82

258. On information and belief, Ford has made, used, offered for sale, sold, and/or 

imported products, including within this Judicial District, including at least the Ford Accused 

Products, that infringe, either literally or under the doctrine of equivalents, one or more claims of 

the ʼ800 patent in violation of 35 U.S.C. § 271(a), including claim 10. A comparison of claim 10

of the ʼ800 patent to an exemplary product of the Ford Accused Products is attached as Exhibit 18, 

which is incorporated herein by reference. 

259. On information and belief, with knowledge of the ʼ800 patent, Ford has actively 

induced and continues to induce the direct infringement of one or more claims of the ʼ800 patent, 

including claim 10, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of its 

products, including at least the Ford Accused Products, by selling, providing support for, providing 

instructions for use of, and/or otherwise encouraging its customers and/or end-users to directly 

infringe, either literally and/or under the doctrine of equivalents, one or more claims of the ʼ800 

patent, including claim 10, with the intent to encourage those customers and/or end users to 

infringe the ʼ800 patent.

260. By way of example, on information and belief, Ford actively induces infringement 

of the ʼ800 patent by encouraging, instructing, and aiding one or more persons in the United States, 

including but not limited to customers and/or end users who test, operate, and use Ford’s products, 

including at least the Ford Accused Products, to make, use, sell, offer to sell, and/or import Ford’s 

products, including at least the Ford Accused Products, in a manner that infringes at least one claim 

of the ʼ800 patent, including claim 10. For example, as described above, Ford actively markets, 

advertises, offers for sale, and/or otherwise promotes the Ford Accused Products by publishing 

and distributing data sheets, manuals, and guides for the Ford Accused Products. Therein, on 

information and belief, Ford describes and touts the use of the subject matter claimed in the ʼ800 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 83 of 90 PageID #: 537 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 82 of 89 PageID #: 82
83

patent. 

261. On information and belief, with knowledge of the ʼ800 patent, Ford also contributed 

to, and continues to contribute to, the infringement of one or more claims of the ʼ800 patent, 

including claim 10, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or importing

the Ford Accused Products, knowing them to be especially made or especially adapted for 

practicing the inventions of the ʼ800 patent and not a staple article or commodity of commerce 

suitable for substantial non-infringing use. This is evidenced by, among other things, the design, 

configuration, and functionality of the Ford Accused Products, which are especially made or 

especially adapted for use in infringement of the ʼ800 patent when used for their normal and 

intended purpose. This is also evidenced by, among other things, Ford’s informational and 

promotional materials described above, which describe the normal use and intended purpose of 

the Ford Accused Products and demonstrate that the Ford Accused Products are especially made 

or especially adapted for a use that infringes the ʼ800 patent. 

262. On information and belief, as a result of Ford’s inducement of, and/or contribution 

to, infringement, its customers and/or end users made, used, sold, offered for sale, or imported, 

and continue to make, use, sell, offer to sell, or import, Ford’s products, including the Ford 

Accused Products, in ways that directly infringe one or more claims of the ʼ800 patent, including 

claim 10. On information and belief, Ford had actual knowledge of its customers’ and/or end 

users’ direct infringement at least by virtue of their sales, instruction, and/or otherwise promotion 

of Ford’s products, including the Ford Accused Products, at least as of the dates of knowledge of 

the ʼ800 patent alleged above, and no later than the date of this Complaint.

263. On information and belief, with knowledge of the ʼ800 patent, Ford has willfully, 

deliberately, and intentionally infringed the ʼ800 patent, at least as of the dates of knowledge of 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 84 of 90 PageID #: 538 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 83 of 89 PageID #: 83
84

the ʼ800 patent alleged above, and no later than the date of this Complaint, and continues to 

willfully, deliberately, and intentionally infringe the ʼ800 patent. On information and belief, Ford 

had actual knowledge of the ʼ800 patent and Ford’s infringement of the ʼ800 patent at least as of 

the dates of knowledge of the ʼ800 patent alleged above, and no later than the date of this 

Complaint. On information and belief, after acquiring that knowledge, Ford continued to directly 

and indirectly infringe the ʼ800 patent as set forth above. On information and belief, Ford knew 

or should have known that its conduct amounted to infringement of the ʼ800 patent at least because 

Ford was aware of the ʼ800 patent and Ford’s infringement of the ʼ800 patent at least as of the 

dates of knowledge of the ʼ800 patent alleged above, and no later than the date of this Complaint. 

Ford was aware of its infringement by virtue of the ’800 patent’s fame in the semiconductor 

industry, Ford’s expertise in the subject matter of the ’800 patent, Ford’s technical competence to 

understand the scope of the ’800 patent, and Ford’s intimate familiarity with its Accused Products. 

Additionally, Ford was aware of the ʼ800 patent, and Ford’s infringement of the ʼ800 patent, at 

least as of the date of this Complaint because Plaintiff notified Ford of such.

264. On information and belief, Ford will continue to infringe the ʼ800 patent unless and 

until it is enjoined by this Court. Ford, by way of its infringing activities, has caused and continues 

to cause Plaintiff to suffer damages in an amount to be determined, and has caused and is causing 

Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against Ford’s acts of 

infringement and, unless Ford is enjoined from its infringement of the ʼ800 patent, Plaintiff will 

continue to suffer irreparable harm.

265. Plaintiff is entitled to recover from Ford damages at least in an amount adequate to 

compensate for its infringement of the ʼ800 patent, which amount has yet to be determined, 

together with interest and costs fixed by the Court.

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 85 of 90 PageID #: 539 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 84 of 89 PageID #: 84
85

266. On information and belief, Volkswagen has made, used, offered for sale, sold, 

and/or imported products, including within this Judicial District, including at least the Volkswagen 

Accused Products, that infringe, either literally or under the doctrine of equivalents, one or more 

claims of the ʼ800 patent in violation of 35 U.S.C. § 271(a), including claim 10. Comparisons of 

claim 10 of the ʼ800 patent to exemplary products of the Volkswagen Accused Products are

attached as Exhibits 24 and 30, which are incorporated herein by reference. 

267. On information and belief, with knowledge of the ʼ800 patent, Volkswagen has 

actively induced and continues to induce the direct infringement of one or more claims of the ʼ800 

patent, including claim 10, in violation of 35 U.S.C. § 271(b), by its customers and/or end users of 

its products, including at least the Volkswagen Accused Products, by selling, providing support 

for, providing instructions for use of, and/or otherwise encouraging its customers and/or end-users 

to directly infringe, either literally and/or under the doctrine of equivalents, one or more claims of 

the ʼ800 patent, including claim 10, with the intent to encourage those customers and/or end users 

to infringe the ʼ800 patent.

268. By way of example, on information and belief, Volkswagen actively induces 

infringement of the ʼ800 patent by encouraging, instructing, and aiding one or more persons in the 

United States, including but not limited to customers and/or end users who test, operate, and use 

Volkswagen’s products, including at least the Volkswagen Accused Products, to make, use, sell, 

offer to sell, and/or import Volkswagen’s products, including at least the Volkswagen Accused 

Products, in a manner that infringes at least one claim of the ʼ800 patent, including claim 10. For 

example, as described above, Volkswagen actively markets, advertises, offers for sale, and/or 

otherwise promotes the Volkswagen Accused Products by publishing and distributing data sheets, 

manuals, and guides for the Volkswagen Accused Products. Therein, on information and belief, 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 86 of 90 PageID #: 540 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 85 of 89 PageID #: 85
86

Volkswagen describes and touts the use of the subject matter claimed in the ʼ800 patent. 

269. On information and belief, with knowledge of the ʼ800 patent, Volkswagen also 

contributed to, and continues to contribute to, the infringement of one or more claims of the ʼ800 

patent, including claim 10, in violation of 35 U.S.C. § 271(c), by offering to sell, selling, and/or 

importing the Volkswagen Accused Products, knowing them to be especially made or especially 

adapted for practicing the inventions of the ʼ800 patent and not a staple article or commodity of 

commerce suitable for substantial non-infringing use. This is evidenced by, among other things, 

the design, configuration, and functionality of the Volkswagen Accused Products, which are 

especially made or especially adapted for use in infringement of the ʼ800 patent when used for 

their normal and intended purpose. This is also evidenced by, among other things, Volkswagen’s 

informational and promotional materials described above, which describe the normal use and 

intended purpose of the Volkswagen Accused Products and demonstrate that the Volkswagen 

Accused Products are especially made or especially adapted for a use that infringes the ʼ800 patent. 

270. On information and belief, as a result of Volkswagen’s inducement of, and/or 

contribution to, infringement, its customers and/or end users made, used, sold, offered for sale, or 

imported, and continue to make, use, sell, offer to sell, or import, Volkswagen’s products, 

including the Volkswagen Accused Products, in ways that directly infringe one or more claims of 

the ʼ800 patent, including claim 10. On information and belief, Volkswagen had actual knowledge 

of its customers’ and/or end users’ direct infringement at least by virtue of their sales, instruction, 

and/or otherwise promotion of Volkswagen’s products, including the Volkswagen Accused 

Products, at least as of the dates of knowledge of the ʼ800 patent alleged above, and no later than 

the date of this Complaint.

271. On information and belief, with knowledge of the ʼ800 patent, Volkswagen has 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 87 of 90 PageID #: 541 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 86 of 89 PageID #: 86
87

willfully, deliberately, and intentionally infringed the ʼ800 patent, at least as of the dates of 

knowledge of the ʼ800 patent alleged above, and no later than the date of this Complaint, and 

continues to willfully, deliberately, and intentionally infringe the ʼ800 patent. On information and 

belief, Volkswagen had actual knowledge of the ʼ800 patent and Volkswagen’s infringement of 

the ʼ800 patent at least as of the dates of knowledge of the ʼ800 patent alleged above, and no later 

than the date of this Complaint. On information and belief, after acquiring that knowledge, 

Volkswagen continued to directly and indirectly infringe the ʼ800 patent as set forth above. On 

information and belief, Volkswagen knew or should have known that its conduct amounted to 

infringement of the ʼ800 patent at least because Volkswagen was aware of the ʼ800 patent and 

Volkswagen’s infringement of the ʼ800 patent at least as of the dates of knowledge of the ʼ800 

patent alleged above, and no later than the date of this Complaint. Volkswagen was aware of its 

infringement by virtue of the ’800 patent’s fame in the semiconductor industry, Volkswagen’s

expertise in the subject matter of the ’800 patent, Volkswagen’s technical competence to 

understand the scope of the ’800 patent, and Volkswagen’s intimate familiarity with its Accused 

Products. Additionally, Volkswagen was aware of the ʼ800 patent, and Volkswagen’s 

infringement of the ʼ800 patent, at least as of the date of this Complaint because Plaintiff notified 

Volkswagen of such.

272. On information and belief, Volkswagen will continue to infringe the ʼ800 patent 

unless and until it is enjoined by this Court. Volkswagen , by way of its infringing activities, has 

caused and continues to cause Plaintiff to suffer damages in an amount to be determined, and has 

caused and is causing Plaintiff irreparable harm. Plaintiff has no adequate remedy at law against 

Volkswagen’s acts of infringement and, unless Volkswagen is enjoined from its infringement of 

the ʼ800 patent, Plaintiff will continue to suffer irreparable harm.

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 88 of 90 PageID #: 542 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 87 of 89 PageID #: 87
88

273. Plaintiff is entitled to recover from Volkswagen damages at least in an amount 

adequate to compensate for its infringement of the ʼ800 patent, which amount has yet to be 

determined, together with interest and costs fixed by the Court.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff Network System Technologies, LLC requests that the Court enter 

judgment for Plaintiff and against Defendants TI, Ford, and Volkswagen and enter the following 

relief:

A. A judgment that Defendants infringe the following Asserted Patents:

U.S. Patent No. 7,366,818 (Exhibit 1, “’818 patent”)

U.S. Patent No. 7,373,449 (Exhibit 2, “’449 patent”)

U.S. Patent No. 7,594,052 (Exhibit 3, “’052 patent”)

U.S. Patent No. 7,769,893 (Exhibit 4, “’9893 patent”)

U.S. Patent No. 8,072,893 (Exhibit 5, “’2893 patent”)

U.S. Patent No. 8,086,800 (Exhibit 6, “’800 patent”)

B. A preliminary and permanent injunction restraining and enjoining Defendants, their 

officers, partners, agents, servants, employees, parents, subsidiaries, divisions, affiliate 

corporations, joint ventures, other related business entities and all other persons acting in concert, 

participation, or in privity with them, and their successors and assigns, from infringing the Asserted 

Patents; 

C. An award of damages to Plaintiff arising from Defendants’ past and continuing 

infringement up until the date Defendants are finally and permanently enjoined from further 

infringement, including compensatory damages;

D. A determination that Defendants’ infringement of the Asserted Patents has been 

willful, and an award of treble damages to Plaintiff pursuant to 35 U.S.C. § 284; 

E. A determination that this is an exceptional case and awarding Plaintiff’s attorneys’ 

fees pursuant to 35 U.S.C. § 285; 

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 89 of 90 PageID #: 543 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 88 of 89 PageID #: 88
89

F. An order awarding Plaintiff costs and expenses in this action;

G. An order awarding Plaintiff pre- and post-judgment interest on its damages; and

H. Such other and further relief in law or in equity as this Court deems just and proper.

JURY DEMAND

Plaintiff respectfully requests a jury trial on all issues so triable.

Dated: December 19, 2022 Respectfully submitted,

/s/ William E. Davis, III

William E. Davis, III

DAVIS FIRM PC

213 N. Fredonia Street, Suite 230

Longview, TX 75601

(903) 235-2588

bdavis@davisfirm.com

Daniel S. Stringfield

NIXON PEABODY LLP

70 West Madison St., Suite 5200

Chicago, IL 60602

(312) 977-4130

dstringfield@nixonpeabody.com

Erica J. Van Loon

Vincent Capati

NIXON PEABODY LLP

300 S. Grand Avenue, Suite 4100

Los Angeles, CA 90071

(213) 629-6000

evanloon@nixonpeabody.com

vcapati@nixonpeabody.com

Attorneys for Plaintiff Network System 

Technologies, LLC

Case 5:23-cv-00134-RWS-JBB Document 29-3 Filed 03/08/24 Page 90 of 90 PageID #: 544 Case 2:22-cv-00482-RWS Document 1 Filed 12/19/22 Page 89 of 89 PageID #: 89