Complaint Under Section 337 of the Tariff Act of 1930,As Amended Complainant: Respondents

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UNITED"STATES INTERNATIONAL TRADE COMMISSION Washington, DC _

Before the Honorable Administrative -LawJudge

In the Matter of

CERTAIN GRAPHICS PROCESSORS, DDR InvestigationNo.337-TA-_ MEMORY CONTROLLERS, AND PRODUCTS CONTAINING THE SAME

VERIFIED COMPLAINT UNDER SECTION 337 OF THE TARIFF ACT OF 1930,AS AMENDED COMPLAINANT: RESPONDENTS:

ZiiLabs Inc., Ltd. Advanced Micro Devices, Inc. Clarendon House One AMD Place 2 Church Street P.O. Box 3453 Hamilton, HMll Bermuda Sunnyvale, CA 94088-3453 Tel: 65-65690394 Tel: 408-749-4000

COUNSEL FOR COMPLAINANT: Lenovo Group Ltd. Shangdi Information Industry Base Goutam Patnaik No. 6 Chuang Ye Road, Haidan District Tuhin Ganguly 10085 Beijing, China David J. Shaw Tel: 86-10-5886-8888 Pepper Hamilton LLP Hamilton Square Lenovo Holding Co., Inc. 600 Fourteenth Street, N.W. 1009 Think Place Washington, DC 20005-2004 Morrisville, NC 27650 Tel: 202-220-1200 Tel: 855-253-6686 Fax: 202-220-1665 Lenovo (United States) Inc. William D. Belanger 1009 Think Place Frank D. Liu Morrisville, NC 27650 Supama Datta Tel: 855-253-6686 Ryan C. Deck Pepper Hamilton LLP LG Electronics, Inc. 19th Floor, High Street Tower LG Twin Towers 125 High Street 20, Yeouido-dong Boston, MA 02110-2736 Yeongdeungpo-gu Tel: 617-204-5100 Seoul 150-721, Korea Fax: 617-204-5150 Tel: 82-2-3777-1114

-;_ Gregory S. Bishop LG Electronics U.S.A., Inc. Pepper Hamilton LLP 1000 Sylvan Avenue 333 Twin Dolphin Drive Englewood Cliffs, NI 07632 Suite 400 Tel: 201-816-2000 Redwood City, CA 94605 Tel: 650-802-3600 LG Electronics MobileComm U.S.A., Inc Fax: 650-802-3650 10101 Old Grove Road San Diego, CA 92131 Tel: 858-635-5300

MediaTek, Inc. No. 1, Dusing Rd. 1 Hsinchu Science Park Hsinchu City 30078, Taiwan Tel: 886-3-567-0766

MediaTek USA Inc. 2860 Junction Ave. San Jose, CA 95134 Tel: 408-526-1899

Motorola Mobility LLC 600 N. U.S. Highway 45 Libertyville, IL 60048 Tel: 847-523-5000

Qualcomm Inc. 5775 Morehouse Drive San Diego, CA 92121 Tel: 858-587-1121

Sony Corporation 1-7-1 Konan Minato-ku, Tokyo 108-0075 Japan Tel: 03-6748-21111

Sony Corporation of America 25 Madison Avenue New York, NY 10022-33211 Tel: 212-833-6800

Sony Electronics Inc. 16535 Via Esprillo Building 1 San Diego, CA 97127 Tel: 858-942-240.0

-1] Sony Mobile Communications (USA) Inc 2207 Bridgepoint Parkway San Mateo, CA 94404 Tel: 650-650-5910

Sony Computer Entertainment Inc. 1-7-1 Konan Minato-ku, Tokyo 108-0075 Japan Tel: O3-6748-211 I1

Sony Interactive Entertainment LLC 2207 Bridgepoint Parkway San Mateo, CA 94404 Tel: 650-655-8000

-iii TABLE OF CONTENTS

INTRODUCTION ...... l

THE PARTIES...... A. Complainant...... B. Respondents ...... I. Advanced Micro Devices, Inc.... 2. Lenovo Group Ltd...... Lenovo Holding Co., Inc. Lenovo (United States) Inc...... LG Electronics Inc...... LG Electronics U.S.A., Inc. . LG Electronics MobileComm U.S.A., Inc...... MediaTek, Inc...... MediaTek U.S.A., Inc. . MotorolaMobilityLLC...... Qualcomm Inc...... Sony Corporation ...... Sony Corporation of America ...... 10 . Sony Electronics Inc...... 11 . Sony Mobile Communications (USA) Inc...... ll Sony Computer Entertainment“Inc...... ll Sony Interactive Entertainment LLC ...... l2

THE ASSERTED PATENTS ...... A. The ’952 Patent ...... l. ForeignCounterpartstothe ’952Patent B. The ’350 Patent ...... 14 1. ForeignCounterpartsto the ’35OPatent l5 C. The ’6l6 Patent ...... l5 l. Foreign Counterparts to the ’6l6 Patent...... 16 D. The ’659 Patent ...... l7 l. Foreign Counterparts to the ’659 Patent...... 18 E. Licensees to the Asserted Patents ...... 18

NON-TECHNICAL DESCRIPTION OF THE PATENTED TECHNOLOGY ...... 18 A. The ’952 Patent —Texture Download DMA Controller Synching Multiple Independently-Running Rasterizers ...... I8 B. The ’350 Patent —Conﬁgurable Pipe Delay with Window Overlap for DDR Receive Data ...... 19 C. The ’6l 6 Patent —Graphics Processor with Texture Memory Allocation System...... D. The ’659 Patent —Shader with Global and Instruction Caches ...... 21

UNFAIR ACTS OF THE RESPONDENTS ...... 22 A. Infringement...... 22

_iV_

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I-I-L '_.,_... 3355555 -l>k»Jt\J <:o~o~:>ooeooo\1\1c\o\u=u1ww 1. The ’952 Patent ...... 23 a. AMD 23 . Lenovo 25 . LG ...... 28 MediaTek ...... 30 . Motorola...... 32 Qualc0mm...... 34 Sony ...... 36 2. ’350Patent ...... 39 . AMD...... 39 Lenovo 41 44 MediaTek 46 . Motorola... 48 Qualcomm Sony ...... m 53 3. ’6l6 Patent...... 55 . AMD ...... 55 Lenovo ...... 57 . LG ...... 60 MediaTek 62 . Mot0r0la...... 64 Qualcomm Sony ...... % 69 4. e ’659 Patent...... 7l . AMD 7l Lenovo 73 . LG ...... 76 MediaTek ...... 78 . Motorola... 80 Qualcomm g. Sony ...... 84 B. Speciﬁc Instance of Sale and Importation 87 l. AMD ...... 87 . Lenovo ...... LG ...... 88 . MediaTek 88 . Motorola ...... 89 Qualcomm ...... 89 Sony ...... 90

VI. HARMONIZED TARIFF SCHEDULE INFORMATION ...... 91

VII. RELATED LITIGATION ...... 93

VIII. DOMESTIC INDUSTRY RELATING TO THE ASSERTED PATENTS ...... 93

-V

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f-*>¢‘bQ_OO‘N>—](IQ_"'1(PQ.OC'$5=>%(IQ_*‘11(DD.f>O‘N>-] q<=~=~sl¢=@' . . :_. . . 5. . . 5 A. Intel’s Purchase of ZiiLabs’ U.K. Subsidiary and Licensing of ZiiLabs’ Patents ...... 93 B. A Domestic Industry Relating to the Asserted Patents Exists Due to Intel’s U.S. Activities ...... 93 1. Intel’sGraphicsProcessors...... 93 2. Intel’s Foundry Services ...... 94 . Intel’s Current 14nm Platforms ...... 95 . Intel’s Domestic Industry ...... 98 a. Intel’s Signiﬁcant Investment in Plant and Equipment 98 b. Intel’s Signiﬁcant Employment of Labor and Capital ...... 103 c. Intel’s Substantial Investment in the Exploitation of the Asserted Patents ...... 106 C. Intel’s Practice of the Asserted Patents ...... I07

IX. RELIEF ...... I07

-vi_

-BU-> EXHIBIT LIST

Exhibit 1 U.S. Patent No. 6,677,952 Exhibit 2 U.S. Patent No. 6,950,350 Exhibit 3 U.S. Patent No. 7,518,616 Exhibit 4 U.S. Patent No. 8,643,659 Exhibit 5 Assignment Record for U.S. Patent No. 6,677,952 Exhibit 6 Assignment Record for U.S. Patent No. 6,950,350. Exhibit 7 Assignment Record for U.S. Patent No. 7,518,616 Exhibit 8 Assignment Record for U.S. Patent No. 8,643,659 Exhibit 9 Claim Chart Comparing ’952 Patent to Lenovo Yoga Tab 3 Product Exhibit 10 Claim Chart Comparing ’952 Patent to LG G5 Product Exhibit 11 Claim Chart Comparing ’952 Patent to Motorola Z 4G LTE Product Exhibit l2 Claim Chart Comparing ’952 Patent to Sony PlayStation 4 Product Exhibit 13 Claim Chart Comparing ’952 Patent to Sony Xperia XA Ultra Product Exhibit l4 Claim Chart Comparing ’350 Patent to Lenovo Yoga Tab 3 Product Exhibit 15 Claim Chart Comparing ’350 Patent to LG G5 Product Exhibit 16 Claim Chart Comparing ’350 Patent to Motorola Z 4G LTE Product Exhibit 17 Claim Chart Comparing ’350 Patent to Sony PlayStation 4 Product Exhibit 18 Claim Chart Comparing ’350 Patent to Sony Xperia XA Ultra Product Exhibit 19 Claim Chart Comparing ’6l 6 Patent to Lenovo Yoga Tab 3 Product Exhibit 20 Claim Chart Comparing ’6l6 Patent to LG G5 Product Exhibit 21 Claim Chart Comparing ’6l 6 Patent to Motorola Z 4G LTE Product Exhibit 22 Claim Chart Comparing ’6l 6 Patent to Sony PlayStation 4 Product Exhibit 23 Claim Chart Comparing ’6l 6 Patent to Sony Xperia XA Ultra Product Exhibit 24 Claim Chart Comparing ‘659 Patent to Lenovo Yoga Tab 3 Product Exhibit 25 Claim Chart Comparing ‘659 Patent to LG G5 Product Exhibit 26 Claim Chart Comparing ‘659 Patent to Motorola Z 4G LTE Product Exhibit 27 Claim Chart Comparing ‘659 Patent to Sony PlayStation 4 Product Exhibit 28 Claim Chart Comparing ‘659 Patent to Sony Xperia XA Ultra Product Exhibit 29 Photograph(s) and screenshot of Lenovo Yoga Tab 3 Product Exhibit 30 Photograph(s) and screenshot of LG G5 Product Exhibit 31 Photograph(s) and screenshot of Motorola Z 4G LTE Product Exhibit 32 Photograph(s) of Sony PlayStation 4 Product and https://www.pIaystation.com/en-gb/explore/ps4/tech-specs/ Exhibit 33 Photograph(s) and screenshot of Sony Xperia XA Ultra Product Exhibit 34 Receipt for Lenovo Yoga Tab 3 Product Exhibit 35 Receipt for LG G5 Product and Sony PlayStation 4 Product Exhibit 36 Receipt for Motorola Z 4G LTE Product Exhibit 37 Receipt for Sony Xperia XA Ultra Product Exhibit 38 (Confidential) August 7, 2013 Letter from ZiiLabs to AMD Exhibit 39 (Confidential) August 7, 2013 Letter from ZiiLabs to Qualcomm Exhibit 40 (Confidential) License Rights in the Asserted Patents Exhibit 41 (Confidential) December 1999 Patent License Agreement Between 3DLabs Inc , Ltd. and Intel Corporation Exhibit 42 (Confidential) November 2012 Patent License Agreement by and among Intel Corporation and ZiiLabs lnc., Ltd.

-vii Exhibit 43 Claim Chart Comparing ’952 Patent to Intel Domestic lndustry Product Exhibit 44 Claim Chart Comparing ’350 Patent to Intel Domestic Industry Product Exhibit 45 Claim Chart Comparing ’616 Patent to Intel Domestic Industry Product Exhibit 46 Claim Chart Comparing ’659 Patent to Intel Domestic Industry Product Exhibit 47 2015 SEC Form 10-K for Intel Corporation Exhibit 48 https://en.wikipedia.org/wiki/Intel_HD_and_Iris_Graphics Exhibit 49 http://Www.intel.com/content/www/us/en/architecture-and-techno|ogy/visual technology/graphics-overview.html Exhibit 50 https://en.wikipedia.0rg/Wiki/List_0f_Intel_graphics_processing_units Exhibit 51 http://www.bl00mbergcom/news/atticles/201 6-()6-09/how-intel-makes-a-chip Exhibit 52 http://vvww.intel.com/content/www/us/en/architecture-and-technology/global manufac-turinghtml Exhibit 53 http ://www.inte1.com/content/wWw/us/en/silicon-innovations/ intel- 14nm technologyhtml Exhibit 54 http ://ark.inte1.com Exhibit 55 http://wwwtomshardware.co.uk/intel-fab42-14nm-cpu-factorgnews-37599.html Exhibit 56 https://en.wikipedia.org/wiki/List_0f_Intel_manufacturing_sites 6 Exhibit 57 http://Www.intel.com/pressroom/kits/manufacturing/Fab3 2/index.htm Exhibit 58 https://advance.lexis.com/api/permalink/2def7590-b134-46a2-993d d030b9d74e8c/?context=1 000516 Exhibit 59 https1//nwlaborpressorg/2010/1 105/11-5-10Intel.html Exhibit 60 http://www.compute1world.com/article/2561162/computer-hardware/inside-intel s-d1d-fab----through-the-looking;glass.html Exhibit 61 http://wwW.oregonlive.com/silicon- ' forest/index.ssf/2015/04/deal4for_new4lithographyétoolshtml Exhibit 62 List of 14nm Intel Desktop Platforms Launched as of September 2016 Exhibit 63 List of 14nm Intel Embedded Platforms Launched as of September 2016 Exhibit 64 List of l4nm Intel Mobile Platfonns Launched as of September 2016 Exhibit 65 List of 14nm Intel Server Platforms Launched as of September 2016 Exhibit 66 List of All Intel Desktop Platforms Launched as of September 2016 Exhibit 67 List of All Intel Embedded Platforms Launched as of September 2016 Exhibit 68 List of All Intel Mobile Platforms Launched as of September 2016 Exhibit 69 List of All Intel Server Platforms Launched as of September 2016 Exhibit 70 Comparison of Launched Intel 2"” Generation Core i3 Desktop Processors Exhibit 71 Summary of Intel 2'“ Generation Core i3 Desktop Processors Exhibit 72 Comparison of Launched Intel 2'“ Generation Core i5 Desktop Processors Exhibit 73 Summary of Intel 2ndGeneration Core i5 Desktop Processors Exhibit 74 Comparison of Launched Intel 2“dGeneration Core i7 Desktop Processors Exhibit 75 Summary of Intel 2ndGeneration Core i7 Desktop Processors Exhibit 76 Comparison of Launched Intel 3"]Generation Core i3 Desktop Processors Exhibit 77 Summary of Intel 3“!Generation Core i3 Desktop Processors Exhibit 78 Comparison of Launched Intel 3'd Generation Core i5 Desktop Processors Exhibit 79 Summary of Intel 3'd Generation Core i5 Desktop Processors Exhibit 80 Comparison of Launched Intel 3“ Generation Core i7 Desktop Processors Exhibit 81 Summary of Intel 3'd Generation Core i7 Desktop Processors Exhibit 82 Comparison of Launched Intel 4thGeneration Core i3 Desktop Processors

-viii Exhibit 83 Summary of Intel 4"‘Generation Core i3 Desktop Processors Exhibit 84 Comparison of Launched Intel 4"‘Generation Core i5 Desktop Processors Exhibit 85 Summary of Intel 4‘hGeneration Core i5 Desktop Processors Exhibit 86 Comparison of Launched Intel 4thGeneration Core i7 Desktop Processors Exhibit 87 Summary of Intel 4thGeneration Core i7 Desktop Processors Exhibit 88 Comparison of Launched Intel SmGeneration Core i5 Desktop Processors Exhibit 89 Summary of Intel 5thGeneration Core i5 Desktop Processors Exhibit 90 Comparison of Launched Intel 5"‘Generation Core i7 Desktop Processors Exhibit 91 Summary of Intel 5thGeneration Core i7 Desktop Processors Exhibit 92 Comparison of Launched Intel 6* Generation Core i3 Desktop Processors Exhibit 93 Summary of Intel 6”‘Generation Core i3 Desktop Processors Exhibit 94 Comparison of Launched Intel 6"‘Generation Core i5 Desktop Processors Exhibit 95 Summary of Intel 6'“ Generation Core i5 Desktop Processors Exhibit 96 Comparison of Launched Intel 6'“ Generation Core i7 Desktop Processors Exhibit 97 Summary of Intel 6*‘Generation Core i7 Desktop Processors Exhibit 98 Comparison of Launched Intel Atom Desktop Processors Exhibit 99 Summary of Intel Atom Desktop Processors Exhibit 100 Comparison of Launched Intel Celeron Desktop Processors Exhibit 101 Summary of Intel Celeron Desktop Processors Exhibit 102 Comparison of Launched Intel High End Desktop Processors Exhibit 103 Summary of Intel High End Desktop Processors Exhibit 104 Comparison of Launched Intel Pentium Desktop Processors Exhibit 105 Summary of Intel Pentium Desktop Processors Exhibit 106 Comparison of Launched Intel Legacy Celeron Desktop Processors Exhibit 107 Summary of Intel Legacy Celeron Desktop Processors Exhibit 108 Comparison of Launched Intel Legacy Core 2 Desktop Processors Exhibit 109 Summary of Intel Legacy Core 2 Desktop Processors Exhibit 110 Comparison of Launched Intel Legacy Pentium Desktop Processors Exhibit 111 Summary of Intel Legacy Pentium Desktop Processors Exhibit 112 Comparison of Launched Intel Previous Generation Core i3 Desktop Processors Exhibit 113 Summary of Intel Previous Generation Core i3 Desktop Processors Exhibit 114 Comparison of Launched Intel Previous Generation Core i5 Desktop Processors Exhibit 115 Summary of Intel Previous Generation Core i5 Desktop Processors Exhibit 116 Summary of Intel Previous Generation Core i7 Extreme Desktop Processors Exhibit 117 Comparison of Launched Intel Previous Generation Core i7 Desktop Processors Exhibit 118 Summary of Intel Previous Generation Core i7 Desktop Processors Exhibit 119 Comparison of Launched Intel 2ndGeneration Core i3 Embedded Processors Exhibit 120 Summary of Intel 2"dGeneration Core i3 Embedded Processors Exhibit I21 Comparison of Launched Intel 2ndGeneration Core i5 Embedded Processors Exhibit 122 Summary of Intel 2"dGeneration Core i5 Embedded Processors Exhibit 123 Comparison of Launched Intel 2ndGeneration Core i7 Embedded Processors Exhibit 124 Summary of Intel 2"dGeneration Core i7 Embedded Processors I _ Exhibit 125 Comparison of Launched Intel 3rdGeneration Core i3 Embedded Processors Exhibit 126 Summary of Intel 3'4 Generation Core i3 Embedded Processors Exhibit 127 Comparison of Launched Intel 3"‘Generation Core i5 Embedded Processors Exhibit 128 Summary of Intel 3'd Generation Core i5 Embedded Processors

-iX_ Exhibit 129 Comparison of Launched Intel 3“ Generation Core i7 Embedded Processors Exhibit 130 Summary of Intel 3'd Generation Core i7 Embedded Processors Exhibit l3l Comparison of Launched Intel 4"‘Generation Core i3 Embedded Processors Exhibit 132 Summary of Intel 4thGeneration Core i3 Embedded Processors Exhibit 133 Comparison of Launched Intel 4"‘Generation Core i5 Embedded Processors Exhibit 134 Summary of Intel 4‘hGeneration Core i5 Embedded Processors Exhibit I35 Comparison of Launched Intel 4"‘Generation Core i7 Embedded Processors Exhibit 136 Summary of Intel 4"‘Generation Core i7 Embedded Processors Exhibit 137 Comparison of Launched Intel 5mGeneration Core i3 Embedded Processors Exhibit 138 Summary of Intel 5"‘Generation Core i3 Embedded Processors Exhibit 139 Comparison of Launched Intel 5”‘Generation Core i5 Embedded Processors Exhibit 140 Summary of Intel 5'“ Generation Core i5 Embedded Processors Exhibit 141 Comparison of Launched Intel 5"‘Generation Core i7 Embedded Processors Exhibit 142 Summary of Intel 5"‘Generation Core i7 Embedded Processors Exhibit I43 Comparison of Launched Intel 6'h Generation Core i3 Embedded Processors Exhibit 144 Summary of Intel 6* Generation Core i3 Embedded Processors Exhibit 145 Comparison of Launched Intel 6'h Generation Core i5 Embedded Processors Exhibit 146 Summary of Intel 6mGeneration Core i5 Embedded Processors Exhibit 147 Comparison of Launched Intel 6thGeneration Core i7 Embedded Processors Exhibit I48 Summary of Intel 6‘hGeneration Core i7 Embedded Processors Exhibit 149 Comparison of Launched Intel 7thGeneration Core i3 Embedded Processors Exhibit 150 Summary of Intel 7mGeneration Core i3 Embedded Processors Exhibit 151 Comparison of Launched Intel Xeon E5 Embedded Processors Exhibit 152 Summary of Intel Xeon E5 Embedded Processors Exhibit I53 Comparison of Launched Intel Atom for Communications Embedded Processors Exhibit 154 Summary of Intel Atom for Communications Embedded Processors Exhibit 155 Comparison of Launched Intel Atom for Smartphone and Tablet Embedded Processors Exhibit 156 Summary of Intel Atom for Smartphone and Tablet Embedded Processors Exhibit 157 COInpariSOnof Launched Intel Atom for Storage Embedded Processors Exhibit 158 Summary of Intel Atom for Storage Embedded Processors Exhibit I59 Comparison of Launched Intel Atom Embedded Processors Exhibit 160 Summary of Intel Atom Embedded Processors Exhibit I61 Comparison of Launched Intel Celeron Embedded Processors Exhibit 162 Summary of Intel Celeron Embedded Processors Exhibit 163 Comparison of Launched Intel Pentium Embedded Processors Exhibit 164 Summary of Intel Pentium Embedded Processors Exhibit 165 Comparison of Launched Intel Quark SoC Embedded Processors Exhibit 166 Summary of Intel Quark SoC Embedded Processors Exhibit 167 Comparison of Launched Intel Xeon 3000 Embedded Processors Exhibit I68 Summary of Intel Xeon 3000 Embedded Processors Exhibit I69 Comparison of Launched Intel Xeon 5000 Embedded Processors Exhibit 170 Summary of Intel Xeon 5000 Embedded Processors Exhibit 171 Comparison of Launched Intel Xeon D Embedded Processors Exhibit 172 Summary of Intel Xeon D Embedded"Processors Exhibit 173 Comparison of Launched Intel Xeon E3 Embedded Processors

-X Exhibit 174 Summary of Intel Xeon E3 Embedded Processors Exhibit 175 Comparison of Launched Intel Xeon E3 v2 Embedded Processors Exhibit 176 Summary of Intel Xeon E3 v2 Embedded Processors Exhibit 177 Comparison of Launched Intel Xeon E3 v3 Embedded Processors Exhibit 178 Summary of Intel Xeon E3 v3 Embedded Processors Exhibit 179 Comparison of Launched Intel Xeon E3 v4 Embedded Processors Exhibit 180 Summary of Intel Xeon E3 v4 Embedded Processors Exhibit 181 Comparison of Launched Intel Xeon E3 v5 Embedded Processors Exhibit 182 Summary of Intel Xeon E3 v5 Embedded Processors Exhibit 183 Comparison of Launched Intel Xeon E5 v2 Embedded Processors Exhibit 184 Summary of Intel Xeon E5 v2 Embedded Processors Exhibit 185 Comparison of Launched Intel Xeon E5 v3 Embedded Processors Exhibit 186 Summary of Intel Xeon E5 v3 Embedded Processors Exhibit 187 Comparison of Launched Intel Xeon E5 v4 Embedded Processors Exhibit 188 Summary of Intel Xeon E5 v4 Embedded Processors Exhibit 189 Comparison of Launched Intel Legacy Celeron Embedded Processors Exhibit 190 Summary of Intel Legacy Celeron Embedded Processors Exhibit 191 Comparison of Launched Intel Legacy Core 2 Embedded Processors Exhibit 192 Summary of Intel Legacy Core 2 Embedded Processors Exhibit 193 Comparison of Launched Intel Legacy Core Embedded Processors Exhibit 194 Summary of Intel Legacy Core Embedded Processors Exhibit 195 Comparison of Launched Intel Legacy Pentium Embedded Processors Exhibit 196 Summary of Intel Legacy Pentium Embedded Processors Exhibit 197 Comparison of Launched Intel Legacy Xeon Embedded Processors Exhibit 198 Summary of Intel Legacy Xeon Embedded Processors Exhibit 199 Comparison of Launched Intel Previous Generation Core i3 Embedded Processors Exhibit 200 Summary of Intel Previous Generation Core i3 Embedded Processors Exhibit 201 Comparison of Launched Intel Previous Generation Core i5 Embedded Processors Exhibit 202 Summary of Intel Previous Generation Core i5 Embedded Processors Exhibit 203 Comparison of Launched Intel Previous Generation Core i7 Embedded Processors Exhibit 204 Summary of Intel Previous Generation Core i7 Embedded Processors Exhibit 205 Comparison of Launched Intel Storage Embedded Processors Exhibit 206 Summary of Intel Storage Embedded Processors Exhibit 207 Comparison of Launched Intel 2“ Generation Core i3 Mobile Processors Exhibit 208 Summary of Intel 2"dGeneration Core i3 Mobile Processors Exhibit 209 Comparison of Launched Intel 2"“ Generation Core i5 Mobile Processors Exhibit 210 Summary of Intel 2"“ Generation Core i5 Mobile Processors Exhibit 211 Comparison of Launched Intel 2“dGeneration Core i7 Extreme Mobile Processors Exhibit 212 Summary of Intel 2ndGeneration Core i7 Extreme Mobile Processors Exhibit 213 Comparison of Launched Intel 2ndGeneration Core i7 Mobile Processors Exhibit 214 Summary of Intel 2"dGeneration Core i7 Mobile Processors Exhibit 215 Comparison of Launched Intel 31dGeneration Core i3 Mobile Processors _ Exhibit 216 Summary of Intel 3"‘ Generation Core i3 Mobile Processors Exhibit 217 Comparison of Launched Intel 3rdGeneration Core i5 Mobile Processors Exhibit 218 Summary of Intel 3'd Generation Core i5 Mobile Processors Exhibit 219 Comparison of Launched Intel 3'dGeneration Core i7 Extreme Mobile Processors

-Xi_ Exhibit 220 Summary of Intel 3'd Generation Core i7 Mobile Extreme Processors Exhibit 221 Comparison of Launched Intel 3rdGeneration Core i7 Mobile Processors Exhibit 222 Summary of Intel 3'd Generation Core i7 Mobile Processors Exhibit 223 Comparison of Launched Intel 4"‘Generation Core i3 Mobile Processors Exhibit 224 Summary of Intel 4thGeneration Core i3 Mobile Processors Exhibit 225 Comparison of Launched Intel 4"‘Generation Core i5 Mobile Processors Exhibit 226 Summary of Intel 4thGeneration Core i5 Mobile Processors Exhibit 227 Comparison of Launched Intel 4"’Generation Core i7 Extreme Mobile Processors Exhibit 228 Summary of Intel 4thGeneration Core i7 Extreme Mobile Processors Exhibit 229 Comparison of Launched Intel 4thGeneration Core i7 Mobile Processors Exhibit 230 Summary of Intel 4mGeneration Core i7 Mobile Processors Exhibit 231 Comparison of Launched Intel SlhGeneration Core i3 Mobile Processors Exhibit 232 Summary of Intel 5mGeneration Core i3 Mobile Processors Exhibit 233 Comparison of Launched Intel SmGeneration Core i5 Mobile Processors Exhibit 234 Summary of Intel SmGeneration Core i5 Mobile Processors Exhibit 235 Comparison of Launched Intel 5"‘Generation Core i7 Mobile Processors Exhibit 236 Summary of Intel 5*“Generation Core i7 Mobile Processors Exhibit 237 Comparison of Launched Intel 5"“Generation Core M Mobile Processors Exhibit 238 Summary of Intel 5thGeneration Core M Mobile Processors Exhibit 239 Comparison of Launched Intel 6thGeneration Core i3 Mobile Processors Exhibit 240 Summary of Intel 6*“Generation Core i3 Mobile Processors Exhibit 241 Comparison of Launched Intel 6"‘Generation Core i5 Mobile Processors Exhibit 242 Summary of Intel 6”’Generation Core i5 Mobile Processors Exhibit 243 Comparison of Launched Intel 6"‘Generation Core i7 Mobile Processors Exhibit 244 Summary of Intel 6thGeneration Core i7 Mobile Processors Exhibit 245 Comparison of Launched Intel 6thGeneration Core m3 Mobile Processors Exhibit 246 Summary of Intel 6thGeneration Core m3 Mobile Processors Exhibit 247 Comparison of Launched Intel 6mGeneration Core m5 Mobile Processors Exhibit 248 Summary of Intel 6thGeneration Core m5 Mobile Processors Exhibit 249 Comparison of Launched Intel 6"‘Generation Core m7 Mobile Processors Exhibit 250 Summary of Intel 6thGeneration Core m7 Mobile Processors Exhibit 251 Comparison of Launched Intel 7mGeneration Core i3 Mobile Processors Exhibit 252 Summary of Intel 7'“ Generation Core i3 Mobile Processors Exhibit 253 Comparison of Launched Intel 7"‘Generation Core i5 Mobile Processors Exhibit 254 Summary of Intel 7"‘Generation Core i5 Mobile Processors Exhibit 255 Comparison of Launched Intel 7"‘Generation Core i7 Mobile Processors Exhibit 256 Summary of Intel 7mGeneration Core i7 Mobile Processors Exhibit 257 Comparison of Launched Intel 7"‘Generation Core m3 Mobile Processors Exhibit 258 Summary of Intel 7thGeneration Core m3 Mobile Processors Exhibit 259 Comparison of Launched Intel Atom for Smaitphone and Tablet Mobile Processors Exhibit 260 Summary of Intel Atom for Smartphone and Tablet Mobile Processors Exhibit 261 Comparison of Launched Intel Atom Mobile Processors Exhibit 262 Summary of [ntel Atom Mobile Processors Exhibit 263 Comparison of Launched Intel Celeron Mobile Processors Exhibit 264 Summary of Intel Celeron Mobile Processors

-xii- ' Exhibit 265 Comparison of Launched Intel Pentium Mobile Processors Exhibit 266 Summary of Intel Pentium Mobile Processors Exhibit 267 Comparison of Launched Intel Xeon E3 v5 Mobile Processors Exhibit 268 Summary of Intel Xeon E3 v5 Mobile Processors Exhibit 269 Comparison of Launched Intel Legacy Celeron Mobile Processors Exhibit 270 Summary of Intel Legacy Celeron Mobile Processors Exhibit 271 Comparison of Launched Intel Legacy Core Mobile Processors Exhibit 272 Summary of Intel Legacy Core Mobile Processors Exhibit 273 Comparison of Launched Intel Legacy Core 2 Mobile Processors Exhibit 274 Summary of Intel Legacy Core 2 Mobile Processors Exhibit 275 Comparison of Launched Intel Legacy Pentium Mobile Processors Exhibit 276 Summary of Intel Legacy Pentium Mobile Processors Exhibit 277 Comparison of Launched Intel Previous Generation Core i3 Mobile Processors Exhibit 278 Summary of Intel Previous Generation Core i3 Mobile Processors Exhibit 279 Comparison of Launched Intel Previous Generation Core i7 Extreme Mobile Processors Exhibit 280 Summary of Intel Previous Generation Core i7 Extreme Mobile Processors Exhibit 281 Comparison of Launched Intel Previous Generation Core i7 Mobile Processors Exhibit 282 Summary of Intel Previous Generation Core i7 Mobile Processors Exhibit 283 Comparison of Launched Intel Atom for Server Processors Exhibit 284 Summary of Intel Atom for Server Processors Exhibit 285 Comparison of Launched Intel Atom for Storage Server Processors Exhibit 286 Summary of Intel Atom for Server Storage Processors Exhibit 287 Comparison of Launched Intel Itanium Server Processors Exhibit 288 Summary of Intel Itanium Server Processors Exhibit 289 Comparison of Launched Intel Pentium Server Processors Exhibit 290 Summary of Intel Pentium Server Processors Exhibit 291 Comparison of Launched Intel Xeon Phi Coprocessor x100 Server Processors Exhibit 292 Summary of Intel Xeon Phi Coprocessor xl 00 Server Processors Exhibit 293 Comparison of Launched Intel Xeon Phi x200 Server Processors Exhibit 294 Summary of Intel Xeon Phi x200 Server Processors Exhibit 295 Comparison of Launched Intel Xeon 3000 Server Processors Exhibit 296 Summary of Intel Xeon 3000 Server Processors Exhibit 297 Comparison of Launched Intel Xeon 5000 Server Processors Exhibit 298 Summary of Intel Xeon 5000 Server Processors Exhibit 299 Summary of Intel Xeon 6000 Server Processors Exhibit 300 Summary of Intel Xeon 7000 Server Processors Exhibit 301 Comparison of Launched Intel Xeon D Server Processors Exhibit 302 Summary of Intel Xeon D Server Processors Exhibit 303 Summary of Intel Xeon E3 Server Processors Exhibit 304 Comparison of Launched Intel Xeon E3 v2 Server Processors Exhibit 305 Summary of Intel Xeon E3 v2 Server Processors _ Exhibit 306 Comparison of Launched Intel Xeon E3 v3 Server Processors Exhibit 307 Summary of Intel Xeon E3 v3 Server Processors Exhibit 308 Comparison of Launched Intel Xeon E3 v4 Server Processors Exhibit 309 Summary of Intel Xeon E3 v4 Server Processors

-Xlll Exhibit 310 Comparison of Launched Intel Xeon E3 v5 Server Processors Exhibit 31 1 Summary oflntel Xeon E3 v5 Sewer Processors Exhibit 312 Comparison of Launched Intel Xeon E5 Sewer Processors Exhibit 313 Summary of Intel Xeon E5 Server Processors Exhibit 314 Comparison of Launched Intel Xeon E5 v2 Server Processors Exhibit 315 Summary of Intel Xeon E5 v2 Server Processors Exhibit 316 Comparison of Launched Intel Xeon E5 v3 Sewer Processors Exhibit 317 Summary of Intel Xeon E5 v3 Server Processors Exhibit 318 Comparison of Launched Intel Xeon E5 v4 Sewer Processors Exhibit 319 Summary of Intel Xeon E5 v4 Server Processors Exhibit 320 Summary of Intel Xeon E7 Server Processors Exhibit 321 Comparison of Launched Intel Xeon E7 v2 Server Processors Exhibit 322 Summary of Intel Xeon E7 v2 Server Processors Exhibit 323 Comparison of Launched Intel Xeon E7 v3 Server Processors Exhibit 324 Summary of Intel Xeon E7 v3 Server Processors Exhibit 325 Comparison of Launched Intel Xeon E7 v4 Server Processors Exhibit 326 Summary of Intel Xeon E7 v4 Server Processors Exhibit 327 Summary of Intel Legacy Pentium Sewer Processors Exhibit 328 Comparison of Launched Intel Legacy Xeon Server Processors Exhibit 329 Summary of Intel Legacy Xeon Sewer Processors Exhibit 330 (Confidential) August 5, 2016 Letters from ZiiLabs to Lenovo Exhibit 331 (Confidential) August 5, 2016 Letters from ZiiLabs to LG Exhibit 332 (Confidential) August 18, 2016 Letters from ZiiLabs to MediaTek Exhibit 333 (Confidential) August 5, 2016 Letters from ZiiLabs to Sony Exhibit 334 (Confidential) August 7, 2013 Letter from ZiiLabs to Google Exhibit 335 (Confidential) August 8, 2016 Letter from ZiiLabs to Motorola

-xiv APPENDICES

Appendix A Patent No. 6,677,952 Prosecution History Appendix B Patent No. 6,677,952 Technical References Appendix C Patent N0. 6,950,350 Prosecution History Appendix D Patent No. 6,950,350 Technical References Appendix E Patent N0. 7,518,616 Prosecution History Appendix F Patent N0. 7,518,616 Technical References Appendix G Patent N0. 8,643,659 Prosecution History Appendix H Patent No. 8,643,659 Technical References

_XV_ I. INTRODUCTION

l. Complainant ZiiLabs Inc., Ltd. (“ZiiLabs”) ﬁles this complaint pursuant to

Section 337 of the Tariff Act of 1930, as amended, 19 U.S.C. § 1337 (“Section 337”). ZiiLabs respectfully requests that the United States Intemational Trade Commission (the “Commission”) institute an investigation relating to the unlawful importation into the United‘States, the sale for importation into the United States, and/or the sale within the United States after importation, of certain graphics processors, DDR memory controllers, and products containing the same.

2. The respondents are Advanced Micro Devices, Inc. (“AMD”), Lenovo Group

Ltd., Lenovo Holding Co., Inc., and Lenovo (United States) Inc. (collectively “Lenovo”), LG

Electronics, Inc., LG Electronics U.S.A., Inc., and LG Electronics MobileCornm U.S.A., lnc.

(collectively “LG”), MediaTek, Inc. and MediaTek USA Inc. (collectively “MediaTek”),

Motorola Mobility LLC (“Motorola”), Qualcomm Inc. (“Qualcomm”), and Sony Corporation,

Sony Corporation of America, Sony Electronics Inc., Sony Mobile Communications (USA) Inc.,

Sony Computer Entertainment Inc., and Sony Interactive Entertairmient LLC (collectively

“Sony”) (all collectively, “Respondents”).

3. Respondents have violated and continue to violate Section 337 through the importation, sale for importation, and/or the sale within the United States aﬁer importation of certain graphics processors, DDR memory controllers, and products containing the same that directly infringe, literally or under the doctrine of equivalents, ZiiLabs’ United States Patent No.

6,677,952 (the “’952 Patent”), United States Patent N0. 6,950,350 (the ‘"350 Patent”), United

States Patent No. 7,518,616 (the ‘"616 Patent”), and United States Patent No. 8,643,659 (the

‘"659 Patent”) (collectively, the “Asserted Patents”) to the detriment ofthe industry that exists in the United States relating to the Asserted Patents. ' 4. In addition to their direct infringement, Respondents have also violated and continue to violate Section 337 through the importation, sale for importation, and/or the sale within the United States after importation of certain graphics processors, DDR memory controllers, and products containing the same that indirectly infringe, literally or under the doctrine of equivalents, by induced or contributory infringement, ZiiLabs’ Asserted Patents to the detriment of the industry that exists in the United States relating to the Asserted Patents.

Respondents have knowledge of the Asserted Patents and ZiiLabs’ infringement allegations at least as of the filing of this Complaint and the related district court complaints, and in most cases earlier based on notice letters from ZiiLabs, and have continued to provide their graphics processors, DDR memory controllers, and products containing the same to the marketplace in a manner that indirectly infringes ZiiLabs’ Asserted Patents. ZiiLabs will also serve a public copy of this Complaint on each proposed Respondent the day it is filed. 5.* ZiiLabs asserts that each Respondent infringes the following claims: ~a::;.ef;1a~ ffifi _’952 1-8

’350 1—1 6 ’6l6 l-8

’659 1-20

6. To remedy Respondents’ continuing and unlawful violation of Section 337,

ZiiLabs seeks as permanent relief a limited exclusion order, pursuant to 19 U.S.C. § 1337(d), barring from entry into the United States all Respondents’ graphics processors, DDR memory controllers, and products containing the same that infringe one or more of the claims of the

Asserted Patents. ZiiLabs also seeks cease and desist orders pursuant to l9 U.S.C. § l337(f) prohibiting each domestic Respondent from engaging in the importation into the United States

-2 and/or the sale within the United States after importation of graphics processors, DDR memory controllers, and products containing the same that infringe one or more claims of the Asserted

Patents. Further, ZiiLabs requests that the Commission impose a bond upon Respondents’

importation of infringing graphics processors, DDR memory controllers, and products containing the same during the 60-day Presidential review period, pursuant to 19 U.S.C. § l337(j), to prevent further injury to the domestic industry relating to the Asserted Patents. ll. THE PARTIES

A. Complainant

7. Complainant ZiiLabs is a Bermuda corporation with its registered office at

Clarendon House, 2 Church Street, Hamilton, HM11 Bermuda. ZiiLabs is a wholly-owned subsidiary of Creative Technology Asia Limited (“CTA”), a Hong Kong company. CTA is a wholly-owned subsidiary of Creative Technology Ltd. (“Creative”), a publicly traded Singapore company.

8. ZiiLabs traces its roots to a company called benchMark Technologies (BMT), founded in 1983. In 1988, BMT was sold to DuPont, which renamed BMT as Dupont Pixel. In

1994, one of the founders of BMT led a management buyout of DuPont Pixel, and formed

3DLabs Inc. Ltd. (“3DLabs”).

9. At the time of its formation, 3DLabs focused on the creation of a 3D graphics chip for personal computers (“PCs”) and was an early pioneer in the graphics processing

industry. 3DLabs was a leading supplier of high-performance integrated hardware and software graphics accelerator solutions for 2D and 3D professional graphics applications. It was a pioneer in bringing 3D graphics to personal computers and its products were used in professional ' graphics applications for PCs and Windows NT-based PC workstations.

_3_ l0. 3DLabs introduced the GLINT 300SX, the world’s ﬁrst merchant OpenGL‘ graphics processing unit (“GPU”), in 1995.

11. In 1996 3DLabs launched the Permedia GPU, a full featured, lower cost 3D graphics processor designed to provide high performance interactive 3D graphics for mainstream consumer PCs using the Windows 95 operating system.

12. 3DLabs’ GPUs were designed into board and system level designs by companies such as Accel Graphics, Inc., Creative, Diamond Multimedia Systems Inc., ELSA, Inc., Fujitsu

Ltd., Leadtek, and NEC Corp., and boards incorporating 3DLabs’ GPUs were designed into PCs by such heavyweights as Compaq Computer Corporation, Dell Computer Corporation, Gateway

2000, Hewlett-Packard Company, Micron Electronics, Inc., NEC, and Samsung Electronics Co.,

Ltd.

13. From its inception, 3DLabs marketed and sold its 3D graphics technology through merchant processor sales primarily to PC and graphics board original equipment manufacturers

(“OEMs”) and licensed its embeddable graphics processor cores to technology partners in exchange for royalties. In July of 1998, 3DLabs acquired Dynamic Pictures Inc., then a leading supplier of 2D/3D graphics boards for high-end PC graphics applications in the Windows NT based PC workstation market, as part of 3DLabs’ strategic decision to enter the vertically integrated board business for the PC workstations market.

‘“OpenGL is the premier environment for developing portable, interactive 2D and 3D graphics applications. Since its introduction in 1992, OpenGL has become the industry’s most widely used and supported 2D and 3D graphics application programming interface (AP1), bringing thousands of applications to a wide variety of computer platfonns.” (See https://wwwopengl.org[about/.) 3DLabs was a founding member of the Khronos Group, which drives the OpenGL standard, and initiated the OpenGL ES 1.0 standard, which was ratiﬁed in 2003.

_4_ 14. In December 1999, 3DLabs and Intel Corporation (“Intel”) entered into a Patent

License Agreement, pursuant to which Intel acquired license rights to some of the Asserted

Patents.

l5. In 2000, 3DLabs acquired the assets of Intergraph Corporation (“Intergraph”), including the application that matured into the asserted ’6l6 Patent.

16. In 2002, 3DLabs was acquired by Creative, one of 3DLabs’ original investors.

17. In January of 2009, 3DLabs was rebranded as ZiiLabs, in part to signify a broadened focus on mobile processors, platforms, and software. Accordingly, ZiiLabs is the owner of the Asserted Patents. ZiiLabs began providing media processors, including those based on ZiiLabs’ StemCell architecture, for use in portable consumer electronics products.

I8. In November of 2012, Intel acquired certain engineering resources and assets related to the U.K. subsidiary of ZiiLabs. In a related transaction, Intel and ZiiLabs also entered into a Patent'License Agreement pursuant to which Intel acquired, inter alia, license rights to the remaining Asserted Patents.

19. ZiiLabs currently operates as a subsidiary of Creative and owns over 100 issued

U.S. patents related to graphics, processor, and 3D technology, and is the assignee and owner of the Asserted Patents. ZiiLabs’ continued success depends, in part, on its ability to establish, maintain, and protect its proprietary technology through enforcement of its patent rights.

B. Respondents

20. With regard to Respondents, ZiiLabs alleges the following upon information and belief:

"r " 1. ' Advanced Micro Devices, Inc.

21. Advanced Micro Devices Inc. is a corporation organized and existing under the laws of the state of Delaware, with its principal place of business located at Qne AMD Place,

_5_ P.O. Box 3453, Sunnyvale, CA 94088-3453. Advanced Micro Devices Inc. is in the business of designing, developing, manufacturing, making, marketing, offering for sale, selling, importing, and supporting graphics processors, DDR memory controllers, and products containing the same including GPUs, central processing units (“CPUs”), Accelerated Processing Units (“APUs”) — chips that combine the functionality of CPUs and GPUs, and graphics cards, in the United States, that are manufactured outside of the United States. AMD~’sproducts are utilized and sold in products including laptop and desktop PCs, game consoles, and cloud servers.

2. Lenovo Group Ltd.

22. Lenovo Group Ltd. is a foreign corporation organized and existing under the laws of China, with its principal place of business located at Shangdi Infonnation Industry Base, No. 6

Chuang Ye Road, Haidan District, 100085 Beijing, China. Lenovo Group Ltd. is in the business of designing, developing, manufacturing, making, marketing, offering for sale, selling, importing, and supporting products containing graphics processors and/or DDR memory controllers including servers, workstations, desktops, notebooks, laptops, all-in-ones,

Chromebooks, and tablets, that are manufactured outside of the United States. Lenovo Group

Ltd. is the parent corporation of Respondent Lenovo Holding Co., Inc.

3. Lenovo Holding Co., Inc.

23. Lenovo Holding Co., Inc. is a corporation organized and existing under the laws of the state of Delaware, with its principal place of business located at I009 Think Place,

Morrisville, North Carolina 27650. Respondent Lenovo Holding Co., Inc. is a subsidiary of or otherwise controlled by Respondent Lenovo Group Ltd. Lenovo Holding Co., Inc. is in the business of designing, developing, manufacturing, making, marketing, offering for sale, selling, importing, and supporting products containing graphics processors and/or DDR memory controllers including sewers, workstations, desktops, notebooks, laptops, all-in-ones,

-5 Chromebooks, and tablets in the United States, that are manufactured outside ofthe United

States. Lenovo Holding Co., Inc. is the parent corporation of Respondent Lenovo (United

States) Inc.

4. Lenovo (United States) Inc.

24. Lenovo (United States) Inc. is a corporation organized and existing under the laws of the state of Delaware, with its principal place of business located at 100i)‘ThinkPlace,

Morrisville, North Carolina 27650. Respondent Lenovo (United States) Inc. is a subsidiary of or otherwise controlled by Respondent Lenovo Holding Co., lnc. Lenovo (United States) Inc. is in the business of designing, developing, manufacturing, making, marketing, offering for sale, selling, importing, and supporting products containing graphics processors and/or DDR memory controllers including servers, workstations, desktops, notebooks, laptops, all-in-ones,

Chromebooks, and tablets in the United States, that are manufactured outside of the United

States. Lenovo Group Ltd., Lenovo Holding Co., Inc., and Lenovo (United States) Inc. are referred to collectively as “Lenovo.”

5. LG Electronics Inc.

25. LG Electronics, Inc. is a foreign corporation organized and existing under the laws of Korea, with its principal place of business located at 20, Yeouido-dong, Yeongdeungpo gu, Seoul 150-721, Korea. LG Electronics, Inc. is in the business of designing, developing, manufacturing, making, marketing, offering for sale, and selling products containing graphics processors and/or DDR memory controllers including desktops, notebooks, laptops, all-in-ones,

Chromebooks, tablets, smartphones, Wearables,televisions, and DVD and Blu-ray players in the

United States, that are manufactured outside of the United States. LG Electronics, Inc. is the parent corporation of Respondents LG Electronics U.S.A.,k1c. and LG Electronics

MobileComm U.S.A., Inc.

-7 6. LG Electronics U.S.A., Inc.

26. LG Electronics U.S.A., Inc. is a corporation organized and existing under the laws of the state of Delaware, with its principal place of business located at 1000 Sylvan Avenue,

Englewood Cliffs, New Jersey 07632. Respondent LG Electronics U.S.A., Inc. is a subsidiary of or otherwise controlled by Respondent LG Electronics, lnc. LG Electronics U.S.A., Inc. manages the North American operations,.which includes operations within the United States, of

Respondent LG Electronics MobileComm U.S.A., Inc. LG Electronics U.S.A., Inc. is in the business of marketing, offering for sale, selling, importing, and supporting products containing graphics processors and/or DDR memory controllers including desktops, notebooks, laptops, all in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players in the United States, that are manufactured outside of the United States.

7. LG Electronics MobileComm U.S.A., Inc.

27. LG Electronics MobileComm U.S.A., Inc. is a corporation organized and existing under the laws of the state of California, with its principal place of business located at 10101 Old

Grove Road, San Diego, Califomia 92131. Respondent LG Electronics MobileComm U.S.A.,

Inc. is a subsidiary of or otherwise controlled by Respondent LG Electronics, Inc., and is managed by its parent, Respondent LG Electronics U.S.A., Inc. LG Electronics MobileComm

U.S.A., lnc. is in the business of marketing, offering for sale, selling, importing, and supporting products containing graphics processors and/or DDR memory controllers including desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and

DVD and Blu-ray players in the United States, that are manufactured outside of the United

States. LG Electronics, Inc., LG Electronics U.S.A., Inc., and LG Electronics MobileComm _

U.S.A., Inc. are referred to collectively as “LG.”

8. MediaTek, Inc.

. -8 28. MediaTel

Taiwan, with its principal place of business located at No. l, Dusing Rd. l, Hsinchu Science

Park, Hsinchu City 30078, Taiwan. MediaTek Inc. is in the business of designing, developing, manufacturing, making, marketing, offering for sale, selling, importing, and supporting graphics processors, DDR memory controllers, and products containing the same including systems on a chip (“SoCs”) in the United States, that are manufactured outside of the United States.

MediaTek’s products are utilized and sold in products including tablets, smartphones, digital televisions, and consumer DVD and Blu-ray players.

9. MediaTek U.S.A., Inc.

29. MediaTek U.S.A., Inc. is a corporation organized and existing under the laws of the state of Delaware, with its principal place of business located at 2860 Junction Ave., San

Jose, CA 95134. Respondent MediaTek U.S.A., Inc. is a subsidiary of or otherwise controlled by Respondent MediaTek, Inc. MediaTek U.S.A. Inc. is in the business of designing, developing, manufacturing, making, marketing, offering for sale, selling, importing, and supporting graphics processors, DDR memory controllers, and products containing the same including systems on a chip (“SoCs”) in the United States, that are manufactured outside of the

United States. MediaTek’s products are utilized and sold in products including tablets, smartphones, digital televisions, and consumer DVD and Blu-ray players.

10. Motorola Mobility LLC

30. Motorola Mobility LLC is a corporation organized and existing under the laws of the state of Delaware, with its principal place of business located at 600 N. U.S. Highway 45,

Libertyville, IL 60048. Respondent Motorola Mobility LLC is a subsidiary of or otherwise controlled by Respondent Lenovo Group Ltd. Motorola Mobility LLC is in the business of designing, developing, manufacturing, making, marketing, offering for sale, selling, importing,

. _9_ and supporting products containing graphics processors and/or DDR memory controllers including smartphones and wearables in the United States, that are manufactured outside of the

United States.

ll. Qualcomm Inc. » >

31. Qualcomm Inc. is a corporation organized and existing under the laws of the state of Delaware, with its principal place of business located at 5775 Morehouse Drive, San Diego,

CA 92121. Qualcomm Inc. is in the business of designing, developing, manufacturing, making, marketing, offering for sale, selling, importing, and supporting graphics processors, DDR memory controllers, and products containing the same including all-in-one processors, SoCs, and baseband processors, in the United States, that are manufactured outside of the United States.

Qualcomm’s products are utilized and sold in products including laptops, tablets, and smartphones.

12. Sony Corporation

32. Sony Corporation is a foreign corporation organized and existing under the laws of Japan, with its principal place of business located at l-7-l Konan, Minato-ku, Tokyo l08

OO75Japan. Sony Corporation is in the business of designing, developing, manufacturing, making, marketing, offering for sale, selling, importing, and supporting products containing graphics processors and/or DDR memory controllers including tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems in the United States, that are manufactured outside of the United States.

13. Sony Corporation of America

33. Sony Corporation of America is a corporation organized and existing under the laws of the state of New York, with its principal place of business located at 25 Madison

Avenue, New York, NY 10022-33211. Respondent Sony Corporation of America is a subsidiary

-19 of or otherwise controlled by Respondent Sony Corporation. Sony Corporation of America is in the business of designing, developing, manufacturing, making, marketing, offering for sale, selling, importing, and supporting products containing graphics processors and/or DDR memory controllers including tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems in the United States, that are manufactured outside of the United States.

14. Sony Electronics Inc.

34. Sony Electronics Inc. is a corporation organized and existing under the laws of the state of Delaware, with its principal place of business located at 16535 Via Esprillo Building 1,

San Diego, CA 97127. Respondent Sony Electronics Inc. is a subsidiary of or otherwise controlled by Respondent Sony Corporation. Sony Electronics Inc. is in the business of designing, developing, manufacturing, making, marketing, offering for sale, selling, importing, and supporting products containing graphics processors and/or DDR memory controllers including tablets, smartphones, wearables, televisions, and DVD and Blu-ray players in the

United States, that are manufactured outside of the United States. ’

" 15. Sony Mobile Communications (USA) Inc.

35. Sony Mobile Communications (USA) lnc. is a corporation organized and existing under the laws of the state of Delaware, with its principal place of business located at 2207 I

Bridgepoint Parkway, San Mateo, CA 94404. Respondent Sony Mobile Communications (USA)

Inc. is a subsidiary of or otherwise controlled by Respondent Sony Corporation. Sony Mobile

Communications (USA) Inc. is in the business of designing, developing, manufacturing, making, marketing, offering for sale, selling, importing, and supporting products containing graphics processors and/or DDR memoryicontrollers including tablets, smartphones, and wearables, in the

United States, that are manufactured outside of the United States.

16. Sony Computer Entertainment Inc.

-11 36. Sony Computer Entertainment Inc. is a foreign corporation organized and existing under the laws of Japan, with its principal place of business located at I-7~l Konan, Minato-ku,

Tokyo I08-0075 Japan. Respondent Sony Computer Entertainment Inc. is a subsidiary of or otherwise controlled by Respondent Sony Corporation. Sony Computer Entertainment Inc. is in the business of designing, developing, manufacturing, making, marketing, offering for sale, selling, importing, and supporting products containing graphics processors and/or DDR memory controllers including gaming systems in the United States, that are manufactured outside of the

United States.

17. Sony Interactive Entertainment LLC

37. Sony Interactive Entertainment LLC is a corporation organized and existing under the laws of the state of Delaware, with its principal place of business located at 2207 Bridgepoint

Parkway, San Mateo, CA 94404. Respondent Sony Interactive Entertainment LLC is a subsidiary of or otherwise controlled by Respondent Sony Corporation. Sony Interactive

Entertainment LLC is in the business of designing, developing, manufacturing, making, marketing, offering for sale, selling, importing, and supporting products containing graphics processors and/or DDR memory controllers including gaming systems in the United States, that are manufactured outside of the United States.

III. THE ASSERTED PATENTS

38. The ’952 Patent, titled “Texture Download DMA Controller Synching Multiple

Independently-Running Rasterizers,” is properly assigned to ZiiLabs, as shown in the certiﬁed copy of the assignment records, attached as Exhibit 5.

39. The ’350~Patent, titled “Conﬁgurable Pipe Delay with Window Overlap for DDR

Receive Data,” is properly assigned to ZiiLabs, as shown in the certiﬁed copy of the assignment records, attached as Exhibit 6.

-12 40. The ’6l6 Patent, titled “Graphics Processor with Texture Memory Allocation

System,” is properly assigned to ZiiLabs, as shown in the certiﬁed copy of the assignment records, attached as Exhibit 7. 1

41. The ’659 Patent, titled “Shader with Global and Instruction Caches,” is properly assigned to ZiiLabs, as shown in the certiﬁed copy of the assignment records, attached as Exhibit

A. The ’952Patent

42. Pursuant to Commission Rules 21().12(a)(9)(i)-(ii), a certiﬁed copy of the ’952

Patent and a certiﬁed copy of the assignment records for the ’952 Patent are attached hereto as

Exhibits 1 and 5, respectively. Appendix A, pursuant to Commission Rule 2l0.l2(c)(l), contains one certiﬁed copy of the U.S. Patent and Trademark Office prosecution history for the

’952 Patent plus three additional copies thereof. Appendix B, pursuant to Commission Rule

210.12(c)(2), contains four copies of each patent and the applicable pages of each technical reference mentioned in the prosecution history of the ’952 Patent.

43. The ’952 Patent was ﬁled on June 9, 2000, claiming priority to U.S. Provisional

Patent Application No. 60/138,350, which was ﬁled on June 9, 1999, U.S. Provisional Patent

Application No. 60/138,248, which was ﬁled on June 9, 1999, and U.S. Provisional Patent

Application No. 60/143,660, which was ﬁled on July 13, 1999. The ’952 Patent issued on

January 13, 2004.

44. The ’952 Patent has eight (8) claims, including three (3) independent claims

(claims 1, 4, and 6) and ﬁve (5) dependent claims. ZiiLabs is asserting claims l-8 of the ’952

Patent:

-13 tr»

AMD 1-8

Lenovo l--8 LG l-8 MediaTek l-8

Motorola l-8

Qualcomm I-8

Sony 1-8

1. Foreign Counterparts to the ’952Patent

45. ZiiLabs, pursuant to Commission Rule 210. l2(a)(9)(v), is not aware of any foreign patents and patent applications related to the asserted ’952 Patent.

46. In accordance with Commission Rule 210.12(a)(9)(v), ZiiLabs states that it is aware of no other foreign counterparts issued, ﬁled, denied, abandoned, or withdrawn, relating to the asserted ’952 Patent.

B. The ’350 Patent

47. Pursuant to Commission Rules 210.12(a)(9)(i)-(ii), a certiﬁed copy ofthe ’350

Patent and a certiﬁed copy of the assignment records for the ’350 Patent are attached’hereto as

Exhibits 2 and 6, respectively. Appendix C, pursuant to Commission Rule 210.12(c)(l), contains one certiﬁed copy of the U.S. Patent and Trademark Ofﬁce prosecution history for the ’350

Patent plus three additional copies thereof. Appendix D, pursuant to Commission Rule

2l0.l2(c)(2), contains four copies of each patent and the applicable pages of each technical reference mentioned in the prosecution history of the ’350 Patent.

-14

QQ? 48. The ’350 Patent was ﬁled on April 4, 2002, claiming priority to U.S. Provisional

Patent Application No. 60/346,518, which was ﬁled on January 8, 2002. The ’350 Patent issued on September 27, 2005.

49. The ’3S0 Patent has sixteen (16) claims, including three (3) independent claims

(claims 1, 10, and 15) and thirteen (13) dependent claims. ZiiLabs is asserting claims 1-16 of the

’350 Patent:

< 3' §a@@aasaaaaaei%v;;aaeaar saaaaarsuaet §?aa?¥% 2% T AMD 1-I6

Lenovo 1-16 LG l-16 MediaTek 1-16 Motorola l-16

Qualcomm 1-16

Sony 1-16

1. Foreign. Counterparts to the ’350 Patent .

50. ZiiLabs, pursuant to Commission Rule 210.12(a)(9)(v), is not aware of any foreign patents and patent applications related to the asserted ’350 Patent.

51. In accordance with Commission Rule 210.12(a)(9)(v), ZiiLabs states that it is aware of no other foreign counterparts issued, ﬁled, denied, abandoned, or withdrawn, relating to the asserted ’350 Patent._

C. The ’616 Patent

52. Pursuant to Commission Rules 210.12(a)(9)(i)-(ii), a certiﬁed copy of the ’616

Patent and a certiﬁed copy of the assignment records for the ’616 Patent are attached hereto as

Exhibits 3 and 7, respectively. Appendix E, pursuant to Commission Rule 210.12(c)(1), contains

_15_

“‘€@

¥@ $5

4-.» one certiﬁed copy of the U.S. Patent and Trademark Ofﬁce prosecution history for the ’6l6

Patent plus three additional copies thereof. Appendix F, pursuant to Commission Rule

2 10.12(c)(2), contains four copies of each patent and the applicable pagesof each technical reference mentioned in the prosecution history of the ’6l6 Patent.

53. The ’6l6 Patent was ﬁled on July 15, 1999, claiming priority to U.S. Provisional

Patent Application No. 60/093,159, which was ﬁled on July 17, 1998. The _‘616Patent issued on

April l4, Z009. , i

54. The ’6l6 Patent has eight (8) claims, including three (3) independent claims

(claims 1, 7, and 8) and ﬁve (5) dependent claims. ZiiLabs is asserting claims l-8 ofthe ’6l6

Patent: _

‘------"ff ».,.::::::‘...“,~r:1m, ' ;L,r;r,;-,;;1L.t.t~*'~*;Z:'*';§?;.§.,':~-lI.:fIw,M-a kw »- J-av 1 <.ewye _:\lJ 3‘ '"Res. ~ S6 ~ l»-8 Lenovo I-8

LG l -8 MediaTek 1-8 Motorola 1-8

Qualcomm 1-8

Sony 1-8

1. Foreign Counterparts to the ’6l6 Patent

55. ZiiLabs, pursuant to Commission Rule 210. 12(a)(9)(v), identiﬁes the following foreign patents and patent applications related to the asserted ’6l6 Patent:

Document Status

WOOOO4496 No ongoing national phase prosecution

-16

gt? I PCT/US99/16033 l No ongoing national phase prosecution

56. In accordance with Commission Rule 210.12(a)(9)(v), ZiiLabs states that it is aware of no other foreign counterparts issued, ﬁled, denied, abandoned, or withdrawn, relating to the asserted ’6l6 Patent.

D. The ’659 Patent

57. Pursuant to Commission Rules 2l0.12(a)(9)(i)-(ii), a certiﬁed copy of the ’659

Patent and a certiﬁed copy of the assignment records for the ’659 Patent are attached hereto as

Exhibits 4 and 8, respectively. Appendix G, pursuant to Commission Rule 21O.12(c)(1), contains one certiﬁed,copy of the U.S. Patent and Trademark Ofﬁce prosecution history for the

’659 Patent plus three additional copies thereof. Appendix H, pursuant to Commission Rule

21O.l2(c)(2), contains four copies of each patent and the applicable pages of each technical reference mentioned in the prosecution history of the ’659 Patent.

58. The ’659 Patent was ﬁled on October 5, 2004, claiming priority to U.S.

Provisional Patent Application No. 60/533,532, which was ﬁled on December 31, 2003. The

’659 Patent issued on February 4, 2014.

59. The ’659 Patent has twenty (20) claims, including eight (8) independent claims

(claims 1, 4, 6, 9, 11, 15, 17, and 19) and twelve (12) dependent claims. ZiiLabs is asserting claims 1-20 of the ’659 Patent:

..]'7_ “

aa/J‘~;s, , .3“; t'J* fl", r;=.";M;v."".E

AMD 1-20

Lenovo l‘-20

LG l -20 MediaTek l -20 Motorola l -20

Qualcomm l -20

Sony 1-20

1. Foreign Counterparts to the ’659Patent

60. ZiiLabs, pursuant to Commission Rule 210.l2(a)(9)(v), is not aware of any foreign patents and patent applications related to the asserted ’659 Patent.

61. In accordance with Commission Rule 210.12(a)(9)(v), ZiiLabs states that it is aware of no other foreign counterparts issued, ﬁled, denied, abandoned, or withdrawn, relating to the asserted ’659 Patent. l

E. Licensees to the Asserted Patents l

62. License rights in the Asserted Patents are set forth in Conﬁdential Exhibit 40.

IV. NON-TECHNICAL DESCRIPTION OF THE PATENTED TECHNOLOGY

63. ZiiLabs’ patented technology generally relates to the ﬁeld of computer and graphics processing.

A. The ’952Patent —Texture Download DMA Controller Synching Multiple Independently-Running Rasterizers

" *64. ZiiLabs’ ’952 Patent is generally directed to multiple rasterizer graphics systems.

Multiple rasterizer graphics systems enable increased graphics processing throughput by allowing graphics processing operations to be distributed across each of the rasterizers.

-13 65. When a rasterizer is performing graphics rendering operations it may request graphics data (e.g., texture data) that has not yet been loaded into memory (e.g., RAM). To complete the rendering operation, the requested data must ﬁrst be loaded into memory before that data can be accessed by the requesting rasterizer.

66. In multi-rasterizer graphics systems, there is a possibility that separate rasterizers will request the same graphics data (e.g., texture data). As a result, the requested graphics data will be downloaded multiple times, once for each requesting rasterizer. This results in multiple copies of the same data being loaded into memory, thus increasing memory usage, and decreased bandwidth because of the additional copies of data that need to be transferred to each of the rasterizers.

67. The ’952 Patent addresses this problem by broadcasting the graphics data requested by one rasterizer to each of the other rasterizers in the graphics system. This allows the requested graphics data to be downloaded only once, thereby avoiding multiple downloads of the same data by different rasterizers. Because the same graphics data is not downloaded multiple times, memory resources are preserved, thus allowing for more efficient use of the

Il'16IT1OI'y PCSOUTCCS. '

B. The ’350Patent —Conﬁgurable Pipe Delay with Window Overlap for DDR Receive Data

68. ZiiLabs’ ’350 Patent is generally directed to maximizing the setup and hold time for data being read from Double-Data-Rate Synchronous Dynamic Random Access Memory

(DDR SDRAM). Setup and hold time refer to the minimum amount of time that is required to ensure that the data is stable before being latched. If data is not stable, then the latched data may not be accurate.

- 19_ 69. Data stored in DDR SDRAM is read into data registers or memory locations with a strobe signal. In particular, the data _islatched to a location by either the rising edge or falling edge of the strobe signal. As memory clock speeds increase, the time between rising and falling edges of the strobe signal decrease, thereby shrinking the window in which valid data can be latched.

70. The ’350 Patent maximizes the setup and hold time (i.e., valid data window) by adjusting the timing of the strobe signal for the DDR memory device and converting the data a single datum from the DDR memory device into doublewide data.

C. The ’616 Patent —Graphics’Processor with Texture Memory Allocation System

71. ZiiLabs’ ’6l 6 Patent is directed to a graphics processor that stores and processes textures in an efﬁcient manner. In three-dimensional (3D) graphics systems, textures are applied to 3D graphical objects to give them a realistic appearance. This is accomplished by retrieving the texture from memory and mapping the texture to a 3D graphical object. An example of applying texture to a 3D object is illustrated in the image below:

The memory used to store textures is typically conﬁgured as linear memory. Linear memory consists of an array of memory blocks of the same size, with each memory block accessible by a unique memory address.

-20 72. Textures are typically multi-dimensional (e.g., 2D, 3D). Storing multi-_ dimensional textures in linear memory often results in an inefﬁcient allocation of memory.

Unlike ID textures, which can be readily stored within a page of memory, multi-dimensional textures will typically span across multiple pages of memory. Accessing data within a page of memory is an efficient operation, while accessing data across different pages of a memory is an expensive and inefficient operation. For example, storing each row of texels (texture elements) of a two-dimensional texture, each in a separate page of memory, would result in inefﬁcient memory access because multiple pages of memory would need to be accessed to retrieve the multiple rows of texels that form the two-dimensional texture. V

73. The ’6l 6 Patent addresses this inefﬁcient storage of textures by converting multi dimensional textures into one-dimensional texture maps by deﬁning a plurality of data blocks within the multi-dimensional texture and storing consecutive data blocks into consecutive memory locations. These multi-dimensional textures stored as one-dimensional texture maps can be accessed through texture packets that are each associated with a unique texture map. The texture packets include data relating to the location or the texture map in memory and dimensional type of the texture map.

D. The ’659 Patent —Shader with Global and Instruction Caches

74. ZiiLabs’ ’659 Patent is generally directed to graphics rendering hardware for graphics shader programs. Graphics shader programs are computer programs that produce the desired visual effects (e.g., lighting, motion blur, depth of ﬁeld) for a graphics image.

75. Typical graphics hardware designs store global data and instructions used by graphics shader programs into a ﬁxed set of registers or writable control store (WCS). These traditional designs, however, limit the size and complexity of the shader programs that can be run on the graphics hardware.

.21 76. The ’659 Patent addresses the limitations in traditional graphics hardware designs by incorporating an instruction cache and a global data cache into the graphics rendering hardware. By incorporating an instruction cache and a global data cache, the graphics processor can virtualize the storage of instructions and global data, thereby allowing larger and more complex shader programs to run on the graphics rendering hardware.

V. UNFAIR ACTS OF THE RESPONDENTS

77. Respondents are engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors, DDR memory controllers, and products containing the same including GPUs, CPUs, APUs, SoCs, all-in-one processors, baseband processors, graphics cards, servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, televisions, DVD and Blu-ray players, and gaming systems, which infringe at least one claim of each of the Asserted Patents.

A. Infringement

78. Exhibits 9-28 are claim charts demonstrating how the asserted independent claims of the Asserted Patents apply to certain representative products of each Respondent. In addition to the speciﬁc graphics processors and/or DDR memory controllers contained in these representative Respondent products, ZiiLabs also believes that Respondents incorporate graphics processors and/or DDR memory controllers from other companies into their GPUs, CPUs,

APUs, SoCs, all-in-one processors, baseband processors, graphics cards, servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems in a manner that similarly infringes the Asserted Patents. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against Respondents’ importation, sale for importation, and/or sale after importation of these products as well.

-22 79. Respondents’ subject articles include:

~=-1:,,,;,,, AMD GPUs, CPUs, APUs, graphics cards Lenovo Servers, Workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets

LG Desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, DVD and blu-ray players MediaTek SoCs

Motorola Smartphones and wearables Qualcomm All-in-one processors, baseband processors - .

Sony Tablets, smaitphones, wearables, televisions, DVD and blu-ray players, gaming systems

1. The ’952Patent

a. AMD

80. Respondent AMD is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’952

Patent.

8l. ZiiLabs has obtained products containing graphics processors that AMD imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’952 Patent.

82. Pursuant to Commission Rule 2l 0.l2(a)(9)(viii), Exhibit 12 includes a chart comparing the asserted independent claims of the ’952 Patent to a representative product containing AMD’s graphics processors. Exhibit 12 shows!that products containing AMD graphics processors and their use are covered by at least the asserted independent claims of the

’952 Patent. Additionally, pursuant to Commission Rule 2lO.l2(a)(9)(x), Exhibit 12 contains

-33

weft

(vet

Brae,

»§$3¢>‘-w Z§%?"5§'1f4 rm photographs of products containing AMD’s graphics processors. Lastly, Commission Rule

2l0.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of

Respondent AMD that violates Section 337. ZiiLabs believes that AMD’s other devices, including AMD’s other GPUS, CPUs, APUs, and graphics cards, and their uses, are covered by at least one of the Asserted Claims ofthe ’952 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent AMD.

83. Additionally, AMD has indirectly infringed at least one claim of the ’952 Patent by inducing infringement.

84. AMD has been aware of the ’952 Patent and of ZiiLabs’ allegations of infringement since at least August 7, 2013, when ZiiLabs sent AMD a notice letter.

(Conﬁdential Exhibit 38.) ZiiLabs will serve a public copy of this Complaint on “AMDthe day it is ﬁled.

85. Despite AMD’s awareness of the ’952 Patent and ZiiLabs’ allegations, AMD has knowingly and actively induced others to infringe the ’952 Patent by selling GPUs, CPUs, V

APUs, and graphics cards,ic0ntaining graphics processors which induce the direct infringement of at least one of the claims of the ’952 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’952 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of

ZiiLabs’ ’952 Patent.

86. AMD has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’952 Patent. As shown for the representative 7 product'con*ta'iﬁi-ﬁg‘Al\7lD’sgraphics processors (Exhibit 12), AMD’s products function in a manner that infringes the claims of the ’952 Patent. At least by providing users with products

-24 that necessarily infringe the ’952 Patent, AMD has induced and is actively inducing infringement

of at least one claim of ZiiLabs’ ’95Z Patent.

87. Finally, AMD has indirectly infringed at least one of the claims of the ’952 Patent

by contributing to infringement.

88. The graphics processors in AMD’s GPUS, CPUs, APUS, and graphics cards are

made solely for the purpose of operating in a manner that infringes at least one claim of the ’952

Patent. Further, these graphics processors are especially made and/or especially adapted for use

in the infringement of ZiiLabs’ ’952 Patent, are not staple commodities of commerce, and are not

suitable for substantial non-infringing use. By providing GPUs, CPUs, APUs, and graphics

cards containing these graphics processors, AMD has contributed to the infringement of the ’952

Patent by end-users —for example, customers - who use said graphics processors provided in

AMD’s GPUs, CPUs, APUs, and graphics cards.

b. Lenovo .

89. Respondent Lenovo is engaged in the importation, the sale for importation, and/or

the sale Withinthe United States after importation of certain graphics processors and products

containing the same that infringe or are used to infringe at least the Asserted Claims of the ’952

Patent.

90. ZiiLabs has obtained products containing graphics processors that Lenovo

imported, sold for importation, and/or sold within the United States aﬁer importation, and that

infringe, directly or indirectly, at least the Asserted Claims of the ’952 Patent.

91. Pursuant to Commission Rule 2l0.l2(a)(9)(viii), Exhibit 9 includes a chart

5"‘? i comparing the asserted independent claims of the ’952 Patent to a representativeLenovo

product Exhibit 9 shows that the Lenovo product and its use are covered by at least the asserted

independent claims of the ’952 Patent. Additionally, pursuant to Commission Rule

-25_ 2l0.l2(a)(9)(x), Exhibit 9 contains photographs of the Lenovo product. Lastly, Commission

Rule 2l0.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent Lenovo that violates Section 337. ZiiLabs believes that Lenovo’s other devices, including Lenovo’s other servers, workstations, desktops, notebooks, laptops, all-in-ones,

Chromebooks, and tablets, and their uses, are covered by at least one of the Asserted Claims of the ’952 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent Lenovo.

92. In addition to incorporating graphics processors in a manner that directly infringes at least one of the Asserted Claims of the ’952 Patent, as does its use, as shown in Exhibit 9,

ZiiLabs also believes that Lenovo incorporates graphics processors from other companies into its other servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets in a manner that similarly infringes the Asserted Claims of the ’952 Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against

Lenovo’s importation, sale for importation, and/or sale aﬁer importation of these products as well. c

93. Additionally, Lenovo has indirectly infringed at least one claim of the ’952 Patent by inducing infringement.

94. Lenovo has been aware of the ’952 Patent and of ZiiLabs’ allegations of infringement since at least August 5, 2016, when ZiiLabs sent Lenovo notice letters.

(Conﬁdential Exhibit 330.) ZiiLabs will serve a public copy of this Complaint on Lenovo the . day it is ﬁled.

.. - 95. . Despite Lenovo’s awareness of the ’952 Patent and ZiiLabs’ allegations, Lenovo has knowingly and actively induced others to infringe the ’952 Patent by selling servers,

_26_ workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets containing graphics processors which induce the direct infringement of at least one of the claims of the ’952

Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’952 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’952 Patent.

96. Lenovo has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’952 Patent. As shown for the representative

Lenovo product (Exhibit 9), Lenovo’s products function in a manner that infringes the claims of the ’952 Patent. At least by providing users with products that necessarily infringe the ’952

Patent, Lenovo has induced and is actively inducing infringement of at least one claim of

ZiiLabs’ ’952 Patent.

97. Finally, Lenovo has indirectly infringed at least one of the claims of the ’952

Patent by contributing to infringement.

98. The graphics processors in Lenovo’s servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets are made solely for the purpose of operating in a manner that infringes at least one claim of the ’952 Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’952 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use.

By providing sewers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets containing these graphics processors, Lenovo has contributed to the infringement of the

’952 Patent by end-users —for example, customers -—whouse said graphics processors provided in Lenovo’s servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets.

-27 c. LG

99. Respondent LG is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least ﬁre Asserted Claims of the ’952

Patent.

100. ZiiLabs has obtained products containing graphics processors that LG imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’952 Patent.

101. Pursuant to Commission Rule 2lO.l2(a)(9)(viii), Exhibit 10 includes a chart comparing the asserted independent claims of the ’952 Patent to a representative LG product.

Exhibit l0 shows that the LG product and its use are covered by at least the asserted independent claims of the ’952 Patent. Additionally, pursuant to Commission Rule 2l().l2(a)(9)(x), Exhibit

10 contains photographsof the LG product. Lastly, Commission Rule 2l0.l2(a)(9)‘(viii) requires that Complainant chart only “a representative involved article” of Respondent LG that violates

Section 337. ZiiLabs believes that LG’s other devices, including LG’s other desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and

DVD and Blu-ray players, and their uses, are covered by at least one of the Asserted Claims of the ’952 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent LG.

102. In addition to incorporating graphics processors in a manner that directly infringes at least one of the Asserted Claims of the ’952 Patent, as does its use, as shown in Exhibit 10,

ZiiLabs also believes that LG incorporates graphics processors from other companies into its other desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players in a manner that similarly infringes the Asserted

_28_ Claims of the ’952 Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against LG’s importation, sale for importation, and/or sale after importation of these products as well.

I103. Additionally, LG has indirectly infringed at least one claim of the ’952 Patent by inducing infringement.

104. LG has been aware of the ’952 Patent and of ZiiLabs’ allegations of infringement since at least August 5, 2016, when ZiiLabs sent LG»notice letters. (Conﬁdential Exhibit 331.)

ZiiLabs will serve a public copy of this Complaint on LG the day it is ﬁled.

105. Despite LG’s awareness of the ’952 Patent and ZiiLabs’ allegations, LG has knowingly and actively induced others to infringe the ’952 Patent by selling desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, Wearables,televisions, and

DVD and Blu-ray players containing graphics processors which induce the direct infringement of at least one of the claims of the ’952 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’952 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of

ZiiLabs’ ’952 Patent.

106. LG has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’952 Patent. As shown for the representative LG product

(Exhibit 10), LG’s products function in a manner that infringes the claims of the ’952 Patent. At least by providing users with products that necessarily infringe the ’952 Patent, LG has induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’952 Patent.

107. Finally, LG has indirectly infringed at least one of the claims of the ’952 Patent by contributing to infringement.

-29 /

108. The graphics processors in LG’s desktops, notebooks, laptops, all-in-ones,

Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players are made solely for the purpose of operating in a manner that infringes at least one claim of the ’952

Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’952 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use. By providing desktops, notebooks, laptops, all-in ones, Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players containing these graphics processors, LG has contributed to the infringement of the ’952 Patent by end-users —for example, customers —who use said graphics processors provided in LG’s desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players. d. MediaTek

109. Respondent MediaTek is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’952 Patent. ,

110. ZiiLabs has obtained products containing graphics processors that MediaTek imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’952 Patent.

ll 1. Pursuant to Commission Rule 2l0.l2(a)(9)(viii), Exhibit 13 includes a chart comparing the asserted independent claims of the ’952 Patent to a representative product containing MediaTek’s graphics processors. Exhibit 13 shows that products containing

MediaTek graphics processors and their use are covered by at least the asserted independent claims of the ’952 Patent. Additionally, pursuant to Commission Rule 210.l2(a)(9)(x), Exhibit

-30 l3 contains photographs of the product containing MediaTek’s graphics processors. Lastly,

Commission Rule 2 10.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent MediaTek that violates Section 337. ZiiLabs believes that

MediaTek’s other devices, including MediaTek’s other SoCs, and their uses, are covered by at least one of the Asserted Claims of the ’952 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent MediaTek.

112. Additionally, l\/lediaTek has indirectly infringed at least one claim of the ’952

Patent by inducing infringement.

113. MediaTek has been aware of the ’952 Patent and of ZiiLabs’ allegations of infringement since at least August 18, 2016, when ZiiLabs sent MediaTel

(Conﬁdential Exhibit 332.) ZiiLabs will serve a public copy of this Complaint on MediaTek the day it is ﬁled.

114. Despite MediaTek’s awareness of the ’952 Patent and ZiiLabs’ allegations,

MediaTek has knowingly and actively induced others to infringe the ’952 Patent by selling SoCs containing graphics processors which induce the direct infringement of at least one of the claims of the ’952 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’952 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’952 Patent.

l 15. MediaTek has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’952 Patent. As shown for the representative product containing MediaTek’s graphics processors (Exhibit 13), MediaTek’s products function in a manner that infringes the claims of the ’952 Patent. At least by providing users with

-31- , products that necessarily infringe the ’952 Patent, MediaTek has induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’952 Patent.

ll6. Finally, MediaTek has indirectly infringed at least one of the claims of the ’952

Patent by contributing to infringement.

117. The graphics processors in MediaTek’s SoCs are made solely for the purpose of operating in a manner that infringes at least one claim of the ’952 Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’

’952 Patent, are not staple commodities of commerce, and are not suitable for substantial non infringing use. By providing SoCs containing these graphics processors, MediaTek has contributed to the infringement of the ’952 Patent by end-users —for example, customers —who use said graphics processors provided in MediaTek’s SoCs.

e. Motorola

118. Respondent Motorola is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’952 Patent.

119. ZiiLabs has obtained products containing graphics processors that Motorola imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’952 Patent.

120. Pursuant to Commission Rule 2l0.12(a)(9)(viii), Exhibit ll includes a chart comparing the asserted independent claims of the ’952 Patent to a representative Motorola product. Exhibit 1l shows that the Motorola product and its useiare covered by at least the asserted independent claims of the ’952 Patent. Additionally, pursuant to Commission Rule

2l0.l2(a)(9)(x), Exhibit ll contains photographs of the Motorola product. Lastly, Commission

-32_ Rule 210.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent Motorola that violates Section 337. ZiiLabs believes that Motorola’s other devices, including Motorola’s other smartphones and wearables, and their uses, are covered by at least one of the Asserted Claims of the ’952 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent Motorola.

121. In addition to incorporating graphics processors in a manner that directly infringes at least one of the Asserted Claims of the ’952 Patent, as does its use, as shown in Exhibit ll,

ZiiLabs also believes that Motorola incorporates graphics processors from other companies into its other smartphones and wearables in a manner that similarly infringes the Asserted Claims of the ’952 Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against Motorola’s importation, sale for importation, and/or sale after importation of these products as well.

122. Additionally, Motorola has indirectly infringed at least one claim of the ’952"

Patent by inducing infringement.

123. Motorola has been aware of the ’952 Patent and of ZiiLabs’ allegations of infringement since at least August 5, 2016, when ZiiLabs sent Lenovo, Motorola’s parent, notice letters. (Conﬁdential Exhibit 330.) ZiiLabs also sent a notice letter to Motorola’s then-parent,

Google Inc., on August 7, 2013 and one to Motorola itself on August 8, 2016. (Conﬁdential

Exhibits 334 and 335.) ZiiLabs will serve a public copy of this Complaint on Motorola the day it is ﬁled.

124. Despite Motorola’s awareness of the ’952 Patent and ZiiLabs’ allegations,

Motorola has knowingly and actively induced others to infringe the ’952 Patent by selling smartphones containing graphics processors which induce the direct infringement of at least one

-33 of the claims of the ’952 Patent by end-users —for example, customers. These devices are pre programmed to function in the manner claimed in the ’952 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’952 Patent.

125. Motorola has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’952 Patent. As shown for the representative

Motorola product (Exhibit 11), Motorola’s products function in a manner that infringes the claims of the ’952 Patent. At least by providing users with products that necessarily infringe the

’952 Patent, Motorola has induced and is actively inducing infringement of at least one claim of

ZiiLabs’ ’952 Patent. '

126. Finally, Motorola has indirectly infringed at least one of the claims of the ’952

Patent by contributing to infringement.

127. The graphics processors in Motorola’s smartphones and wearables are made solely for the purpose of operating in a manner that infringes at least one claim of the ’952

Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’952 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use. By providing smartphones and wearables containing these graphics processors, Motorola has contributed to the infringement of the ’952 Patent by end-users —for example, customers —who use said graphics processors provided in Motorola’s smartphones and wearables.

f. Qualcomm

l28. Respondent Qualcornm is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’952 Patent.

_34_ 129. ZiiLabs has obtained products containing graphics processors that Qualcomm

imported, sold for importation, and/or sold within the United States after importation, and that

infringe, directly or indirectly, at least the Asserted Claims of the ’952 Patent.

130. Pursuant to Commission Rule 2l0.12(a)(9)(viii), Exhibits 9, 10, and ll include

charts comparing the asserted independent claims of the ’952 Patent to representative products containing Qualcomm’s graphics processors. Exhibits 9, 10, and ll show that products containing Qualcomm’s graphics processors and their use are covered by at least the asserted

independent claims of the ’952 Patent. Additionally, pursuant to Commission Rule

2] 0.l2(a)(9)(x), Exhibits 9, 10, and ll contain photographs of the products containing

Qualcomm’s graphics processors. Lastly, Commission Rule 2lO.l2(a)(9)(viii) requires that

least one of the Asserted Claims of the ’952 Patent and have been imported, sold for importation, or sold within the United States aﬁer importation by Respondent Qualcomm.

131. Additionally, Qualcomm has indirectly infringed at least one claim ofthe ’952

Patent by inducing infringement.

132. Qualcomm has been aware of the ’952 Patent and of ZiiLabs’ allegations of infringement since at least August 7, 2013, when ZiiLabs sent Qualcomm a notice letter.

(Conﬁdential Exhibit 39.) ZiiLabs will serve a public copy of this Complaint on Qualcomm the day it is ﬁled.

W C133. Despite Qualcomm’s awareness of the ’95_2Patent and ZiiLabs" allegations,

Qualcomm has knowingly and actively induced others to infringe the ’952 Patent by selling all

-35 in-one processors, SoCs, and baseband processors containing graphics processors which induce the direct infringement of at least one of the claims of the ’952 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’952 Patent. Upon information and belief, at least one customer has directly infringed one or more claims ofZiiLabs’ ’952 Patent.

134. Qualcomm has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’952 Patent. As shown for the representative products containing Qualcomm’s graphics processors (Exhibits 9, 10, and ll), Qualcomm’s products function in a manner that infringes the claims of the ’952 Patent. At least by providing users with products that necessarily infringe the ’952 Patent, Qualcomm has induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’952 Patent.

135. Finally, Qualcomm has indirectly infringed at least one of the claims of the ’952

Patent by contributing to infringement.

136. The graphics processors in Qualcomm’s all-in-one processors, SoCs, and baseband processors are made solely for the purpose of operating in a manner that infringes at least one claim of the ’952 Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’952 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use. By providing all-in-one processors, SoCs, and baseband processors containing these graphics processors,

Qualcomm has contributed to the infringement of the ’952 Patent by end-users —for example, customers —who use said graphics processors provided in Qua1comm’s all-in-one processors,

SoCs, and baseband processors.

g. Sony

_36_ l37. Respondent Sony is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’952

Patent.

138. ZiiLabs has obtained products containing graphics processors that Sony imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’952 Patent.

139. Pursuant to Commission Rule 2l 0.l2(a)(9)(viii), Exhibits l2 and 13 include charts comparing the asserted independent claims of the ’952 Patent to representative Sony products. Exhibits 12 and 13 show that the Sony products and their use are covered by at least the asserted independent claims of the ’952 Patent. Additionally, pursuant to Commission Rule

21O.l2(a)(9)(x), Exhibits 12 and 13 contain photographs of the Sony products. Lastly,

Commission Rule 2l0.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent Sony that violates Section 337. ZiiLabs believes that Sony’s other devices, including Sony’s other tablets, smartphones, wearables, televisions, DVD and Blu ray players, and gaming systems, and their uses, are covered by at least one of the Asserted

Claims of the ’952 Patent and have been imported, sold for importation, or sold within the

United States after importation by Respondent Sony.

140. In addition to incorporating graphics processors in a manner that directly infringes at least one of the Asserted Claims of the ’952 Patent, as does its use, as shown in Exhibits 12 and 13, ZiiLabs also believes that Sony incorporates graphics processors fron1_other_c0_mpanies into its other tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems in a manner that similarly infringes the Asserted Claims of the ’952 Patent. ZiiLabs

_37_ intends to and does accuse such products of infringement and seeks remedial orders and a bond against Sony’s importation, sale for importation, and/or sale after importation of these products as Well.

141. Additionally, Sony has indirectly infringed at least one claim of the ’952 Patent by inducing infringement.

l42. Sony has been aware of the ’952 Patent and of ZiiLabs’ allegations of infringement since at least August 5, 2016, when ZiiLabs sent Sony notice letters. (Conﬁdential

Exhibit 333.) ZiiLabs will serve a public copy ofthis Complaint on Sony the day it is ﬁled.

143. Despite S0ny’s awareness of the ’952 Patent and ZiiLabs’ allegations, Sony has knowingly and actively induced others to infringe the ’952 Patent by selling tablets, smaitphones, Wearables, televisions, DVD and Blu-ray players, and gaming systems containing graphics processors which induce the direct infringement of at least one of the claims of the ’952

144. Sony has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’952 Patent. As shown for the representative Sony products (Exhibits l2 and l3), Sony’s products function in a manner that infringes the claims of the ’952 Patent. At least by providing users with products that necessarily infringe the ’952

Patent, Sony has induced and is actively inducing infringement of at least one claim of ZiiLabs’

’952 Patent.

145. Finally, Sony has indirectly infringed at least one of the claims of the ’952 Patent by contributing to infringement.

-33 146. The graphics processors in Sony’s tablets, smartphones, wearables, televisions,

DVD and Blu-ray players, and gaming systems are made solely for the purpose of operating in a manner that infringes at least one claim of the ’952 Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’952 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use.

By providing tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems containing these graphics processors, Sony has contributed to the infringement of the

’952 Patent by end-users —for example, customers —who use said graphics processors provided in Sony’s tablets, smartphones, Wearables,televisions, DVD and Blu-ray players, and gaming . systems.

2. The ’350Patent

a. AMD

147. Respondent AMD is engaged in the importation, the sale for importation, and/or the sale within the’United States after importation of certain DDR memory controllers and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’350 Patent.

148. ZiiLabs has obtained products containing DDR memory controllers that AMD imported, sold for importation, and/or sold Within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’350 Patent.

I49. Pursuant to Commission Rule 210.l2(a)(9)(viii), Exhibit 17 includes a chart comparing the asserted independent claims of the ’350 Patent to a representative product containing AMD’s DDR memory controllers. Exhibit 17 shows that products containing AMD

DDR memory controllers and their use are covered by at least the asserted independent claims of the ’350 Patent. Additionally, pursuant to Commission Rule 2l().l2(a)'(9)(x), Exhibit 17 contains

-39 photographs of products containing AMD’s DDR memory controllers. Lastly, Commission Rule

2l0.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of

Respondent AMD that violates Section 337. ZiiLabs believes that AMD’s other devices, including AMD’s other GPUs, CPUs, APUs, and graphics cards, and their uses, are covered by at least one of the Asserted Claims of the ’350 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent AMD.

l5(). Additionally, AMD has indirectly infringed at least one claim of the ’350 Patent by inducing infringement.

151. AMD has been aware of the ’35OPatent and of ZiiLabs’ allegations of infringement since at least August 7, 2013, when ZiiLabs sent AMD a notice letter.

(Conﬁdential Exhibit 38.) ZiiLabs will serve a public copy of this Complaint on AMD the day it is ﬁled.

152. Despite AMD’s awareness of the ’350 Patent and ZiiLabs’ allegations, AMD has knowingly and actively induced others to infringe the ’350 Patent by selling GPUs, CPUs,

APUs, and graphics cards containing DDR memory controllers which induce the direct infringement of at least one of the claims of the ’350 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’35()

Patent. Upon information and belief, at least one customer has directly infringed one or more claims ofZiiLabs’ ’350 Patent.

l53. AMD has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’350 Patent. As shown for the representative product containing AMD’s DDR memory controllers (Exhibit 17), AMD’s products function in a manner that infringes the claims of the ’35OPatent. At least by providing users with products

-40 that necessarily infringe the ’35OPatent, AMD has induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’350 Patent.

I54. Finally, AMD has indirectly infringed at least one of the claims of the ’35OPatent by contributing to infringement.

155. The DDR memory controllers in AMD’s GPUs, CPUs, APUs, and graphics cards, are made solely for the purpose of operating in a manner that infringes at least one claim of the

’350 Patent. Further, these DDR memory controllers are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’350 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use. By providing GPUs, CPUs,

APUs, and graphics cards containing these DDR memory controllers, AMD has contributed to the infringement of the ’350 Patent by end-users —for example, customers —who use said DDR memory controllers provided in AMD’s GPUs, CPUs, APUs, and graphics cards.

b. Lenovo

156. Respondent Lenovo is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain DDR memory controllers and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’350 Patent.

157. ZiiLabs has obtained products containing DDR memory controllers that Lenovo imported, sold for importation, and/or sold within the United States aﬁer importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’350 Patent.

158. Pursuant to CommissioniRule 2] f).l2(a)(9)§viii), Exhibit l4 includes a chart __ comparing the asserted independent claims of the ’350 Patent to a representative Lenovo product. Exhibit 14 shows that the Lenovo product and its use are covered by at least the asserted independent claims of the ’350 Patent. Additionally, pursuant to Commission Rule

-41 2l0.l2(a)(9)(x), Exhibit l4 contains photographs of the Lenovo product. Lastly, Commission

Rule 2lO.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent Lenovo that violates Section 337. ZiiLabs believes that Lenovo’s other devices, including Lenovo’s other sewers, workstations, desktops, notebooks, laptops, all-in-ones,

Chromebooks, and tablets, and their uses, are covered by at least one of the Asserted Claims of the ’350 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent Lenovo.

159. in addition to incorporating DDR memory controllers in a manner that directly infringes at least one of the Asserted Claims of the ’35OPatent, as does its use, as shown in

Exhibit 14, ZiiLabs also believes that Lenovo incorporates DDR memory controllers from other companies into its other servers, workstations, desktops, notebooks, laptops, all-in-ones,

Chromebooks, and tablets in a manner that similarly infringes the Asserted Claims of the ’350

Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against Lenovo’s importation, sale for importation, and/or sale after importation of these products as well.

160. Additionally, Lenovo has indirectly infringed at least one claim of the ’350 Patent by inducing infringement.

161. Lenovo has been aware of the ’350 Patent and of ZiiLabs’ allegations of infiingement since at least August 5, 2016, when ZiiLabs sent Lenovo notice letters.

(Conﬁdential Exhibit 330.) ZiiLabs will serve a public copy of this Complaint on Lenovo the day it is ﬁled.

162. Despite Lenovo’s awareness of the ’350 Patent and ZiiLabs’ allegations, Lenovo has knowingly and actively induced others to infringe the ’35OPatent by selling servers,

-42 workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets containing

DDR memory controllers which induce the direct infringement of at least one of the claims of the ’350 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’35OPatent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’350 Patent.

163. Lenovo has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’35OPatent. As shown for the representative

Lenovo product (Exhibit l4), Lenovo’s products function in a manner that infringes the claims of the ’350 Patent. At least by providing users with products that necessarily infringe the ’350

Patent, Lenovo has induced and is actively inducing infringement of at least one claim of

ZiiLabs’ ’350 Patent.

164. Finally, Lenovo has indirectly infringed at least one of the claims of the ’350

Patent by contributing to infringement. ,

165. The DDR memory controllers in Lenovo’s servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets are made solely for the purpose of operating in a manner that infringes at least one claim of the ’350 Patent. Further, these DDR memory controllers are especially made and/or especially adapted for use in the infringement of

ZiiLabs’ ’35OPatent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use. By providing servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets containing these DDR memory controllers, Lenovo has contributed to the infringement of the ’35()Patent by end-users ~ for example, customers —who use said DDR memory controllers provided in Lenovo’s servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets.

_43_ c. LG

166. Respondent LG is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain DDR memory controllers and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’350

Patent.

167. ZiiLabs has obtained products containing DDR memory controllers that LG imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’350 Patent.

168. Pursuant to Commission Rule 210.l2(a)(9)(viii), Exhibit I5 includes a chart comparing.the asserted independent claims of the ’35OPatent to a representative LG product.

Exhibit 15 shows that the LG product and its use are covered by at least the asserted independent claims of the ’350 Patent. Additionally, pursuant to Commission Rule 21O.l2(a)(9)(x), Exhibit l5 contains photographs of the LG product. Lastly, Commission Rule 21O.12(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent LG that violates

Section 337. ZiiLabs believes that LG’s other devices, including LG’s other desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and

DVD and Blu-ray players, and their uses, are covered by at least one of the Asserted Claims of the ’350 Patent and have been imported, sold for importation, or sold within the United States aﬁer importation by Respondent LG. I

169. In addition to incorporating DDR memory controllers in a manner that directly infringes at least one of the Asserted Claims of the ’350 Patent, as does its use, as shown in

Exhibit 15, ZiiLabs also believes that LG incorporates DDR memory controllers from other companies into its other desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players in a manner that similarly

-44 infringes the Asserted Claims of the ’350 Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against LG’s importation, sale for importation, and/or sale after importation of these products as well.

170. Additionally, LG has indirectly infringed at least one claim of the ’350 Patent by inducing infringement.

l7l. LG has been aware of the ’350 Patent and of ZiiLabs’ allegations of infringement since at least August 5, 2016, when ZiiLabs sent LG notice letters. (Conﬁdential Exhibit 331.)

172. Despite LG’s awareness of the ’35OPatent and ZiiLabs’ allegations, LG has knowingly and actively induced others to infringe the ’350 Patent by selling desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and

DVD and Blu-ray players containing DDR memory controllers which induce the direct infringement of at least one of the claims of the ’350 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’350

Patent. Upon infonnation and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’350 Patent. .

173. LG has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’350 Patent. As shown for the representative LG product

(Exhibit 15), LG’s products function in a manner that infringes the claims of the ’350 Patent. At least by providing users with products that necessarily infringe the ’35()Patent, LG has induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’350 Patent.

174. Finally, LG has indirectly infringed at least one of the claims of the ’350 Patent by contributing to infringement.

_45_ 175. The DDR memory controllers in LG’s desktops, notebooks, laptops, all-in-ones,

Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players are made solely for the purpose of operating in a manner that infringes at least one claim of the ’35O

Patent. Further, these DDR memory controllers are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’350 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use. By providing desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players containing these DDR memory controllers, LG has contributed to the infringement of the

’35OPatent by end-users - for example, customers —who use said DDR memory controllers provided in LG’s desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players.

d. MediaTek

176. Respondent MediaTek is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain DDR memory controllers and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’35O Patent.

177. ZiiLabs has obtained products containing DDR memory controllers that

MediaTek imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’350 Patent.

178. Pursuant to Commission Rule 210.12(a)(9)(viii), Exhibit 18 includes a chart comparing the asserted independent claims of the ’350 Patent to a representative product containing MediaTek’s DDR memory controllers. Exhibit 18 shows that products containing

MediaTek’s DDR memory controllers and their use are covered by at least the asserted independent claims of the ’35OPatent. Additionally, pursuant to Commission Rule

_46_ 2I0.l2(a)(9)(x), Exhibit 18 contains photographs of products containing MediaTek’s DDR memory controllers. Lastly, Commission Rule 2l0.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent MediaTek that violates Section 337.

ZiiLabs believes that MediaTek’s other devices, including MediaTek’s other SoCs, and their uses, are covered by at least one of the Asserted Claims of the ’350 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent MediaTek.

179. Additionally, MediaTek has indirectly infringed at least one claim of the ’350

Patent by inducing infringement. c

180. MediaTek has been aware of the ’350 Patent and of ZiiLabs’ allegations of infringement since at least August 18, 2016, when ZiiLabs sent MediaTek notice letters.

(Conﬁdential Exhibit 332.) ZiiLabs will serve a public copy of this Complaint on MediaTek the day it is ﬁled. '

181. Despite MediaTek’s awareness of the ’350 Patent and ZiiLabs’ allegations,

MediaTek has knowingly and actively induced others to infringe the ’350 Patent by selling SOCs containing DDR memory controllers which induce the direct infringement of at least one of the claims of the ’350 Patent by end-users —for example, customers. These devices are pre programmed to function in the manner claimed in the ’350 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’350 Patent.

182. MediaTek has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’350 Patent. As shown for the representative product containing MediaTek’s DDR memory controllers (Exhibit 18), MediaTek’s products function in a manner that infringes the claims of the ’350 Patent. At least by providing users

-47 with products that necessarily infringe the ’350 Patent, MediaTek has induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’35()Patent.

I83. Finally, MediaTek has indirectly infringed at least one of the claims of the ’350

Patent by contributing to infringement.

184. The DDR memory controllers in MediaTek’s SoCs are made solely for the purpose of operating in a manner that infringes at least one claim of the ’35OPatent. Further, these DDR memory controllers are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’350 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use. By providing SoCs containing these DDR memory controllers, MediaTek has contributed to the infringement of the ’35OPatent by end-users —for example, customers —who use said DDR memory controllers provided in MediaTek’s SoCs. e. Motorola

185. Respondent Motorola is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain DDR memory controllers and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’350 Patent.

186. ZiiLabs has obtained products containing DDR memory controllers that Motorola imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’350 Patent.

187. Pursuant to Commission Rule 210. l2(a)(9)(viii), Exhibit l6 includes a chart comparing the asserted independent claims of the ’350 Patent to a representative Motorola product. Exhibit 16 shows that the Motorola product and its use are covered by at least the asserted independent claims of the ’350 Patent. Additionally, pursuant to Commission Rule

2l0.l2(a)(9)(x), Exhibit 16 contains photographs of the Motorola product. Lastly, Commission

_48_ Rule 210.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent Motorola that violates Section 337. ZiiLabs believes that Motorola’s other devices, including Motorola’s other Smartphones and wearables, and their uses, are covered by at least one of the Asserted Claims of the ’350 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent Motorola. 188. In addition to incorporating DDR memory controllers in a manner that directly infringes at least one of the Asserted Claims of the ’350 Patent, as does its use, as shown in

Exhibit 16, ZiiLabs also believes that Motorola incorporates DDR memory controllers from other companies into its other smartphones and wearables in a manner that similarly infringes the

Asseited Claims of the ’350 Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against Motorola’s importation, sale for importation, and/or sale after importation of these products as well.

189. Additionally, Motorola has indirectly infringed at least one claim of the ’350

Patent by inducing infringement.

190. Motorola has been aware of the ’350 Patent and of ZiiLabs’ allegations of infringement since at least Augmst5, 2016, when ZiiLabs sent Lenovo, Motorola’s parent, notice letters. (Conﬁdential Exhibit 330.) ZiiLabs also sent a notice letter to Motorola’s then-parent,

Google Inc., on August 7, 2013 and one to Motorola itself on August 8, 2016. (Conﬁdential

Exhibits 334 and 335.) ZiiLabs will serve a public copy of this Complaint on Motorola the day it is ﬁled.

, 191 Despite Motorola’s awareness of the ’350 Patent and ZiiLabs’ allegations,

Motorola has knowingly and actively induced others to infringe the ’350 Patent by selling smartphones and wearables containing DDR memory controllers which induce the direct

-49 infringement of at least one of the claims of the ’350 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’350

Patent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’35()Patent.

192. Motorola has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’350 Patent. As shown for the representative

Motorola product (Exhibit 16), Motorola’s products function in a manner that infringes the claims of the ’35OPatent. At least by providing users with products that necessarily infringe the

’35()Patent, Motorola has induced and is actively inducing infringement of at least one claim of

ZiiLabs’ ’350 Patent.

193. Finally, Motorola has indirectly infringed at least one of the claims of the ’35O

Patent by contributing to infringement.

194. The DDR memory controllers in Motorola’s smartphones and wearables are made solely for the purpose of operating in a manner that infringes at least one claim of the ’35O

Patent. Further, these DDR memory controllers are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’350 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use. By providing smartphones and wearables containing these DDR memory controllers, Motorola has contributed to the infringement of the

’350 Patent by end-users —for example, customers —who use said DDR memory controllers provided in Motorola’s smartphones and wearables.

f. Qualcomm

195. Respondent Qualcomm is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain DDR memory controllers and

-50 products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’35OPatent.

196. ZiiLabs has obtained products containing DDR memory controllers that

Qualcomm imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’35()Patent.

197. Pursuant to Commission Rule 2l0.l2(a)(9)(viii), Exhibits 14, 15, and 16 include charts comparing the asserted independent claims of the ’35OPatent to representative products containing Qualcomm’s DDR memory controllers. Exhibits 14, 15, and 16 show that products containing Qualcomm’s DDR memory controllers and their use are covered by at least the asserted independent claims of the ’350 Patent. Additionally, pursuant to Commission Rule

210.l2(a)(9)(x), Exhibits 14, 15, and 16 contain photographsof the products containing

Qualcomm’s DDR memory controllers. Lastly, Commission Rule 210.12(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent Qualcomm that violates Section 337. ZiiLabs believes that Qualcomm’s other devices, including Qualcomm’s other all-in-one processors, SoCs, and baseband processors, and their uses, are covered by at least one of the Asserted Claims of the ’350 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent Qualcomm.

198. Additionally, Qualcomm has indirectly infringed at least one claim of the ’350

Patent by inducing infringement. '

199. Qualcomm has been aware of the ’350 Patent and of ZiiLabs’ allegations of infringement since at least August 7, 2013, when ZiiLabs sent Qualcomm a notice letter.

(Conﬁdential Exhibit 39.) ZiiLabs will serve a public copy of this Complaint on Qualcomm the _ day it is ﬁled.

-51 200. Despite Qualcomm’s awareness of the ’350 Patent and ZiiLabs’ allegations,

Qualcomm has knowingly and actively induced others to infringe the ’35OPatent by selling all

in-one processors, SoCs, and baseband processors containing DDR memory controllers which

induce the direct infringement of at least one of the claims of the ’35()Patent by end-users ~ for

example, customers. These devices are pre-programmed to function in the manner claimed in

the ’350 Patent. Upon information and belief, at least one customer has directly infringed one or

more claims of ZiiLabs’ ’35()Patent.

201. Qualcomm has provided and continues to provide products that cannot and do not

operate except in a manner that infringes the ’350 Patent. As shown for the representative

products containing Qualcomm’s DDR memory controllers (Exhibits l4, 15, and 16),

Qualcomm’s products function in a manner that infringes the claims of the ’350 Patent. At least

by providing users with products that necessarily infringe the ’350 Patent, Qualcomm has

induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’350 Patent.

202. Finally, Qualcomm has indirectly infringed at least one of the claims of the ’350

Patent by contributing to infringement.

203. The DDR memory controllers in Qualcomm’s all-in-one processors, SoCs, and

baseband processors are made solely for the purpose of operating in a manner that infringes at

least one claim of the ’35OPatent. Further, these DDR memory controllers are especially made

and/or especially adapted for use in the infringement of ZiiLabs’ ’350 Patent, are not staple

commodities of commerce, and are not suitable for substantial non-infringing use. By providing

_ __ all-in-one processors, SoCs, and baseband processors containing these DDR memory controllers, 7*’ ~

Qualcomm has contributed to the infringement of the ’350 Patent by end-users —for example,

-52 customers —who use said DDR memory controllers provided in Qualc0mm’s all-in-one processors, SoCs, and baseband processors.

g. Sony

204. Respondent Sony is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain DDR memory controllers and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’350 Patent.

205. ZiiLabs has obtained products containing DDR memory controllers that Sony imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’3S0 Patent.

206. Pursuant to Commission Rule 2l0.l2(a)(9)(viii), Exhibits 17 and 18 include charts comparing the asserted independent claims of the ’350 Patent to representative Sony products. Exhibits 17 and 18 show that the Sony products and their use are covered by at least the asserted independent claims of the ’350 Patent. Additionally, pursuant to Commission Rule

21O.l2(a)(9)(x), Exhibits 17 and 18 contain photographs of the Sony products. Lastly,

Commission Rule 21O.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent Sony that violates Section 337. ZiiLabs believes that Sony’s other devices, including Sony’s other tablets, smartphones, wearables, televisions, DVD and Blu ray players, and gaming systems, and their uses, are covered by at least one of the Asserted

Claims of the ’35OPatent and have been imported, sold for importation, or sold within the

United States after importation by Respondent Sony. I

207. In addition to incorporating DDR memory controllers in a manner that directly infringes at least one of the Asserted Claims of the ’350 Patent, as does its use, as shown in

Exhibits 17 and I8, ZiiLabs also believes that Sony incorporates DDR memory controllers from

_53_ other companies into its other tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems in a manner that similarly infringes the Asserted Claims of the ’350

Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against Sony’s importation, sale for importation, and/or sale after importation of these products as well.

208. Additionally, Sony has indirectly infringed at least one claim of the ’350 Patent by inducing infringement.

209. Sony has been aware of the ’350 Patent and of ZiiLabs’ allegations of infringement since at least August 5, 2016, when ZiiLabs sent Sony notice letters. (Conﬁdential

Exhibit 333.) ZiiLabs will serve a public copy of this Complaint on Sony the day it is ﬁled.

210. Despite Sony’s awareness of the ’350 Patent and ZiiLabs’ allegations, Sony has knowingly and actively induced others to infringe the ’350 Patent by selling tablets,

Smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems containing

DDR memory controllers which induce the direct infringement of at least one of the claims of the ’350 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’350 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’3S0 Patent.

211. Sony has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’350 Patent. As shown for the representative Sony products (Exhibits l7 and 18), Sony’s products function in a manner that infringes the claims of the ’350 Patent. At least by providing users with products that necessarily infringe the ’350 , . .

Patent, Sony has induced and is actively inducing infringement of at least one claim of ZiiLabs’

’350 Patent.

-54 212. Finally, Sony has indirectly infringed at least one of the claims of the ’35OPatent by contributing to infringement.

213. The DDR memory controllers in Sony’s tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems are made solely for the purpose of operating in a manner that infringes at least one claim of the ’35OPatent. Further, these DDR memory controllers are especially made and/or especially adapted for use in the infringement of

ZiiLabs’ ’35()Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use. By providing tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems containing these DDR memory controllers, Sony has contributed to the infringement of the ’350 Patent by end-users —for example, customers —who use said DDR memory controllers provided in Sony’s tablets, smaitphones, wearables, televisions, DVD and Blu-ray players, and gaming systems.

3. The ’616 Patent

a. AMD

214. Respondent Al\/TDis engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’6l6

Patent. i

215. ZiiLabs has obtained products containing graphics processors that AMD imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Assorted Claims of the ’616 Patent. __ _ _

216. Pursuant to Commission Rule 2l0.l2(a)(9)(viii), Exhibit 22 includes a chart comparing the asserted independent claims of the ’6l6 Patent to representative products containing AMD’s graphics processors. Exhibit 22 shows that products containing AMD’s

-55 graphics processors and their use are covered by at least the asserted independent claims of the

’6l6 Patent. Additionally, pursuant to Commission Rule 2lO.l2(a)(9)(x), Exhibit 22 contains photographs of the products containing AMD’s graphics processors. Lastly, Commission Rule

210.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of

Respondent AMD that violates Section 337. ZiiLabs believes that AMD’s other devices, including AMD’s otherlGPUs, CPUs, APUs, and graphics cards, and their uses, are covered by at least one of the Asserted Claims of the ’6l6 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent AMD.

217. Additionally, AMD has indirectly infringed at least one claim of the ’6l6 Patent by inducing infringement.

218. AMD has been aware of the ’6l6 Patent and of ZiiLabs’ allegations of infringement since at least August 7, 2013, when ZiiLabs sent AMD a notice letter.

(Conﬁdential Exhibit 38.) ZiiLabs will serve a public copy of this Complaint on AMD the day it is ﬁled.

219. Despite AMD’s awareness of the ’6l6 Patent and ZiiLabs’ allegations, AMD has knowingly and actively induced others to infringe the ’6l6 Patent by selling GPUs, CPUs,

APUs, and graphics cards containing graphics processors which induce»the direct infringement of at least one of the claims of the ’6l6 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’6l6 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of

ZiiLabs’ ’6l6 Patent. 7 7 W W _ t ______

220. AMD has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’6l6 Patent. As shown for the representative

_56_ product containing AMD’s graphics processors (Exhibit 22), AMD’s products function in a manner that infringes the claims of the ’6l6 Patent. At least by providing users with products that necessarily infringe the ’6l6 Patent, AMD has induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’6l6 Patent.

22l. Finally, AMD has indirectly infringed at least one of the claims of the ’6l6 Patent by contributing to infringement.

222. The graphics processors in AMD’s GPUs, CPUs, APUs, and graphics cards are made solely for the purpose of operating in a manner that infringes at least one claim of the ’6l6

Patent by end-users —for example, customers —who use said graphics processors provided in

AMD’s GPUs, CPUs, APUs, and graphics cards.

b. Lenovo

223. Respondent Lenovo is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’6l6

Patent. ' i

224. ZiiLabs has obtained products containing graphics processors that Lenovo imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’6l6 Patent.

225. Pursuant to Commission Rule 210. l2(a)(9)(viii), Exhibit 19 includes a chart comparing the asserted independent claims of the ’6l6 Patent to a representative Lenovo

' -57 product. Exhibit 19 shows that the Lenovo product and its use are covered by at least the asserted independent claims of the ’6l6 Patent. Additionally, pursuant to Commission Rule

2l0.I2(a)(9)(x), Exhibit 19 contains photographs of the Lenovo product. Lastly, Commission

Rule 2lO.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent Lenovo that violates Section 337. ZiiLabs believes that Lenovo’s other devices, including Lenovo’s other servers, workstations, desktops, notebooks, laptops, all-in-ones,

Chromebooks, and tablets, and their uses, are covered by at least one of the Asserted Claims of the ’6l6 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent Lenovo.

226. ln addition to incorporating graphics processors in a manner that directly infringes at least one of the Asserted Claims of the ’6l6 Patent, as does its use, as shown in Exhibit 19,

ZiiLabs also believes that Lenovo incorporates graphics processors from other companies into its other sewers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets in a manner that similarly infringes the Asserted Claims of the ’6l6 Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against

Lenovo’s importation, sale for importation, and/or sale after importation of these products as well.

227. Additionally, Lenovo has indirectly infringed at least one claim of the ’6l6 Patent by inducing infringement.

228. Lenovo has been aware of the ’6l6 Patent and of ZiiLabs’ allegations of infringement since at least August 5,2016, when ZiiLabs sent Lenovo notice letters. 7 V ~—

(Conﬁdential Exhibit 330.) ZiiLabs will serve a public copy of this Complaint on Lenovo the day it is ﬁled.

-53 229. Despite Lenovo’s awareness of the ’6l 6 Patent and ZiiLabs’ allegations, Lcnovo has knowingly and actively induced others to infringe the ’6l6 Patent by selling servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets containing graphics processors which induce the direct infringement of at least one of the claims of the ’6I6

Patent by end-users —for example, customers. These devices are pre-programmed to function in‘ the manner claimed in the ’616 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’6l 6 Patent.

230. Lenovo has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’6l6 Patent. As shown for the representative

Lenovo product (Exhibit 19), Lenovo’s products function in a manner that infringes the claims of the ’6l6 Patent. At least by providing users with products that necessarily infringe the ’6l6

Patent, Lenovo has induced and is actively inducing infringement of at least one claim of

ZiiLabs’ ’6I6 Patent.

231. Finally, Lenovo has indirectly infringed at least one of the claims of the ’6l6

Patent by contributing to infringement.

232. The graphics processors in Lenovo’s servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets are made solely for the purpose of operating in a manner that infringes at least one claim of the ’6l6 Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’6l6 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use.

By providing servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets containing these graphics processors, Lenovo has contributed to the infringement of the

’6l6 Patent by end-users —for example, customers —who use said graphics processors provided

-59 in Lenovo’s servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets.

c. LG

233. Respondent LG is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’616

Patent.

234. ZiiLabs has obtained products containing graphics processors that LG imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’6l6 Patent.

235. Pursuant to Commission Rule Zl O.l2(a)(9)(viii), Exhibit 20 includes a chart comparing the asserted independent claims of the ’6l6 Patent to a representative LG product.

Exhibit 20 shows that the LG product and its use are covered by at least the asserted independent claims of the ’616 Patent. Additionally, pursuant to Commission Rule 2l0.l2(a)(9)(x), Exhibit

20 contains photographs of the LG product. Lastly, Commission Rule 2l0.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent LG that violates

Section 337. ZiiLabs believes that LG’s other devices, including LG’s other desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and

DVD and Blu-ray players, and their uses, are covered by at least one of the Asserted Claims of the ’6l6 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent LG.

236. In addition to incorporating graphics processors in a manner that directly infringes at least one of the Asserted Claims of the ’6l6 Patent, as does its use, as shown in Exhibit 20,

ZiiLabs also believes that LG incorporates graphics processors from other companies into its

-50 other desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players in a manner that similarly infringes the Asserted

Claims of the ’6l 6 Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against LG’s importation, sale for importation, and/or sale after importation of these products as well.

237. Additionally, LG has indirectly infringed at least one claim of the ’6l6 Patent by inducing infringement.

238. LG has been aware of the ’6l6 Patent and of ZiiLabs’ allegations of infringement since at least August 5, 2016, when ZiiLabs sent LG notice letters. (Conﬁdential Exhibit 331.)

-ZiiLabswill serve a public copy of this Complaint on LG the day it is ﬁled.

239. Despite LG’s awareness of the ’6l6 Patent and ZiiLabs’ allegations, LG has knowingly and actively induced others to infringe the ’6l6 Patent by selling desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and

DVD and Blu-ray players containing graphics processors which induce the direct infringement of at least one of the claims of the ’6l6 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’6l6 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of

ZiiLabs’ ’6l6 Patent.

240. LG has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’6l6 Patent. As shown for the representative LG product

(Exhibit 20), LG’s products function in a manner that infringes the claims of the ’6l6 Patent. At least by providing users with products that necessarily infringe the ’6l6 Patent, LG has induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’6l6 Patent.

_61_ 241. Finally, LG has indirectly infringed at least one of the claims of the ’6l6 Patent by contributing to infringement.

' 242. The graphics processors in LG’s desktops, notebooks, laptops, all-in-ones,

Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players are made solely for the purpose of operating in a manner that infringes at least one claim of the ’6l 6

Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’6l6 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use. By providing desktops, notebooks, laptops, all-in ones, Chromebooks, tablets, smartphones, wearables, .televisions, and DVD and Blu-ray players containing these graphics processors, LG has contributed to the infringement of the ’6l 6 Patent by end-users —for example, customers —who use said graphics processors provided in LG’s desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players.

d. MediaTek

243. Respondent MediaTek is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’6l6 Patent. "

244. ZiiLabs has obtained products containing graphics processors that MediaTek imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’6l6 Patent.

245. Pursuant to Commission Rule 2l0.l2(a)(9)(viii), Exhibit 23 includes a chart comparing the asserted independent claims of the ’6l6 Patent to a representative product containing MediaTek’s graphics processors. Exhibit 23 shows that products containing

-62 MediaTek’s graphics processors and their use are covered by at least the asserted independent claims ofthe ’6l6 Patent. Additionally, pursuant to Commission Rule 2 lO.l2(a)(9)(x), Exhibit

23 contains photographs of the product containing MediaTek’s graphics processors. Lastly,

Commission Rule 2l0.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent MediaTek that violates Section 337. ZiiLabs believes that

MediaTek’s other devices, including MediaTek’s other SoCs, and their uses, are covered by at least one of the Asserted Claims of the ’6l6 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent MediaTek.

246. Additionally, MediaTek has indirectly infringed at least one claim of the ’6l6

Patent by inducing infringement.

247. MediaTek has been aware of the ’6l6 Patent and of ZiiLabs’ allegations of infringement since at least August 18, 2016, when ZiiLabs sent MediaTek notice letters.

(Conﬁdential Exhibit 332.) ZiiLabs will serve a public copy of this Complaint on MediaTek the day it is ﬁled. '

248. Despite MediaTek’s awareness of the ’6l6 Patent and ZiiLabs’ allegations,

MediaTek has knowingly and actively induced others to infringe the ’6l6 Patent by selling SoCs containing graphics processors which induce the direct infringement of at least one of the claims of the ’6l6 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’6l6 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’6l6 Patent.

249. MediaTek has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’6l6 Patent. As shown for the representative. product containing MediaTek’s graphics processors (Exhibit 23), MediaTek’s products function

-53 in a manner that infringes the claims of the ’6l6 Patent. At least by providing users with products that necessarily infringe the ’6l6 Patent, MediaTek has induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’6l6 Patent.

250. Finally, MediaTek has indirectly infringed at least one of the claims of the ’6l6

Patent by contributing to infringement. _

251. The graphics processors in MediaTek’s SoCs are made solely for the purpose of operating in a manner that infringes at least one claim of the ’6l6 Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’

’6l6 Patent, are not staple commodities of commerce, and are not suitable for substantial non infringing use. By providing SoCs containing these graphics processors, MediaTek has contributed to the infringement of the ’6l6 Patent by end-users —for example, customers —who use said graphics processors provided in MediaTek’s SoCs.

e. Motorola

252. Respondent Motorola is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe atleast the Asserted Claims of the ’6l6 Patent.

253. ZiiLabs has obtained products containing graphics processors that Motorola imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’6l6 Patent.

- "- 254. Pursuant to Commission Rule 210.l2(a)(9)(viii)», Exhibit 21 includes a chart comparing the asserted independent claims of the ’6l6 Patent to a representative Motorola product. Exhibit 21 shows that the Motorola product and its use are covered by at least the asserted independent claims of the ’6l6 Patent. Additionally, pursuant to Commission Rule

-64 2lO.l2(a)(9)(x), Exhibit 21 contains photographs of the Motorola product. Lastly, Commission

Rule 2l0. l 2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent Motorola that violates Section 337. ZiiLabs believes that Motorola’s other devices, including Motorola’s other smartphones and wearables, and their uses, are covered by at least one of the Asserted Claims of the ’6l6 Patent and have been imported, sold for importation, or sold within the United States alter importation by Respondent Motorola.

255. In addition to incorporating graphics processors in a manner that directly infringes at least one of the Asserted Claims of the ’6l6 Patent, as does its use, as shown in Exhibit 21,

ZiiLabs also believes that Motorola incorporates graphics processors from other companies into its other smartphones and wearables in a manner that similarly infringes the Asserted Claims of the ’6l6 Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against Motorola’s importation, sale for importation, and/or‘sale after importation of these products as well.

256. Additionally, Motorola has indirectly infringed at least one claim of the ’6l6

Patent by inducing infringement.

257. Motorola has been aware of the ’6l6 Patent and of ZiiLabs’ allegations of infringement since at least August 5, 2016, when ZiiLabs sent Lenovo, Motorola’s parent, notice letters. (Conﬁdential Exhibit 330.) ZiiLabs also sent a notice letter to Motorola’s then-parent,

Google Inc., on August 7, 2013 and one to Motorola itself on August 8, 2016. (Confidential

Exhibits 334 and 335.) ZiiLabs will serve a public copy ofthis Complaint on Motorola the day it is ﬁled.

258. Despite Motorola’s awareness of the ’6l6 Patent and ZiiLabs’ allegations,

Motorola has knowingly and actively induced others to infringe the ’6l6 Patent by selling

_65_ smartphones and wearables containing graphics processors which induce the direct infringement of at least one of the claims of the ’6l6 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’6l6 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of

ZiiLabs’ ’6l6 Patent.

259. Motorola has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’6l 6 Patent. As shown for the representative

Motorola product (Exhibit 21), Motorola’s products function in a manner that infringes the claims of the ’6l6 Patent. At least by providing users with products that necessarily infringe the

’6l6 Patent, Motorola has induced and is actively inducing infringement of at least one claim of

ZiiLabs’ ’6l6 Patent.

260. Finally, Motorola has indirectly infringed at least one of the claims of the ’6l6

Patent by contributing to infringement._

261. The graphics processors in Motorola’s smartphones and wearables are made solely for the purpose of operating in a manner that infringes at least one claim of the ’6l6

Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’6l6 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use. By providing smartphones and wearables containing these graphics processors, Motorola has contributed to the infringement of the ’6l6 Patent by end-users j for example, customers —who use said graphics processors provided in Motorola’s smartphones and wearables.

f. Qualcomm

262. Respondent Qualcomm is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and

- -66 products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’6l 6 Patent. i

263. ZiiLabs has obtained products containing graphics processors that Qualcomm imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’6l6 Patent.

264. Pursuant to Commission Rule 210.12(a)(9)(viii), Exhibits 19, 20, and 21 include charts comparing the asserted independent claims of the ’6l6 Patent to representative products containing Qualcomm’s graphics processors. Exhibits I9, 20, and 21 show that the products containing Qualcomm’s graphics processors and their use are covered by at least the asserted independent claims ofthe ’6l6 Patent. Additionally, pursuant to Commission Rule

210.12(a)(9)(x), Exhibits l9, 20, and 21 contain photographs of the products containing

Qualcomm’s graphics processors. Lastly, Commission Rule 2l0.12(a)(9)(viii) requires that

Complainant chart only “a representative involved article” of Respondent Qualcomm that violates Section 337. ZiiLabs believes that Qualcomm’s other devices, including Qualcomm’s other all-in-one processors, SoCs, and baseband processors, and their uses, are covered by at least one of the Asserted Claims of the ’6l6 Patent and have been imported, sold for importation, or sold within the United States aﬁer importation by Respondent Qualcomm.

265. Additionally, Qualcomm has indirectly infringed at least one claim of the ’6l6

Patent by inducing infringement.

266. Qualcomm has been aware of the ’6l6 Patent and of ZiiLabs’ allegations of infringement since at least August 7, 2013, when ZiiLabs sent Qualcomm a notice letter.

(Conﬁdential Exhibit 39.) ZiiLabs will serve a public copy of this Complaint on Qualcomm the day it is ﬁled.

-67 267. Despite Qualcomm’s awareness of the ’6l6 Patent and ZiiLabs’ allegations,

Qualcomm has knowingly and actively induced others to infringe the ’6l6 Patent by selling all in-one processors, SoCs, and baseband processors containing graphics processors which induce the direct infringement of at least one of the claims of the ’6l 6 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’6l6 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’6l6 Patent.

268. Qualcomm has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’6l6 Patent. As shown for the representative products containing Qualcomm’s graphics processors (Exhibits 19, 20, and 21), Qualcomm’s products function in a manner that infringes the claims of the ’6l6 Patent. At least by providing users with products that necessarily infringe the ’6l6 Patent, Qualcomm has induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’6l6 Patent.

269. Finally, Qualcomm has indirectly infringed at least one ofthe claims ofthe ’6l6

Patent by contributing to infringement.

270. The graphics processors in Qualcomm’s all-in-one processors, SoCs, and baseband processors are made solely for the purpose of operating in a manner that infringes at least one claim of the ’6l6 Patent. Further, these graphics ‘processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’6l6 Patent, are not staple ' commodities of commerce, and are not suitable for substantial non-infringing use. By providing all-in-one processors, SoCs, and baseband processors containing these graphicsprocessors, ' '*'

Qualcomm has contributed to the infringement of the ’6l6 Patent by end—users—for example,

_6g_ customers —who use said graphics processors provided in Qualcomm‘s all-in-one processors,

SoCs, and baseband processors.

g. Sony

271. Respondent Sony is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’6l6

Patent. V

272. ZiiLabs has obtained products containing graphics processors that Sony imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’6l6 Patent.

273. Pursuant to Commission Rule 210.l2(a)(9)(viii), Exhibits 22 and 23 include charts comparing the asserted independent claims of the ’6l6 Patent to representative Sony products. Exhibits 22 and 23 show that the Sony products and their use are covered by at least the asserted independent claims of the ’6l6 Patent. Additionally, pursuant to Commission Rule

2l0.l2(a)(9)(x), Exhibits 22 and 23 contain photographs of the Sony products. Lastly,

Commission Rule 2l0.12(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent Sony that violates Section 337. ZiiLabs believes that Sony’s other devices, including Sony’s other tablets, smartphones, wearables, televisions, DVD and Blu ray players, and gaming systems, and their uses, are covered by at least one of the Asserted

Claims of the ’6l6 Patent and have been imported, sold for importation, or sold within the

United States after importation by Respondent Sony.

’ 7" 274. In addition to incorporating graphics processors in a manner that directlyirifringes at least one of the Asserted Claims of the ’6l6 Patent, as does its use, as shown in Exhibits 22 and 23, ZiiLabs also believes that Sony incorporates graphics processors from other companies

-69- ' into its other tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems in a manner that similarly infringes the Asserted Claims of the ’6l6 Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against Sony’s importation, sale for importation, and/or sale after importation of these products as well.

275. Additionally, Sony has indirectly infringed at least one claim of the ’6l6 Patent by inducing infringement.

276. Sony has been aware ofthe ’6l6 Patent and of ZiiLabs’ allegations of infringement since at least August 5, 2016, when ZiiLabs sent Sony notice letters. (Conﬁdential

Exhibit 333.) ZiiLabs will serve a public copy of this Complaint on Sony the day it is ﬁled.

277. Despite Sony’s awareness of the ’6l6 Patent and ZiiLabs’ allegations, Sony has knowingly and actively induced others to infringe the ’6l6 Patent by selling tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems containing graphics processors which induce the direct infringement of at least one of the claims of the ’6l6

Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’6l6 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’6l6 Patent.

278. t Sony has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’6l6 Patent. As shown for the representative Sony products (Exhibits 22 and 23), Sony’s products function in a manner that infringes the claims of the ’6l6 Patent. At least by providing users with products that necessarily infringe the ’6l6

Patent, Sony has induced and is actively inducing infringement of at least one claim of ZiiLabs’

’6l6 Patent.

_70 279. Finally, Sony has indirectly infringed at least one of the claims of the ’6l6 Patent by contributing to infringement.

280. ' The graphics processors in Sony’s tablets, smartphones, wearables, televisions,

DVD and Blu-ray players, and gaming systems are made solely for the purpose of operating in a manner that infringes at least one claim of the ’6l6 Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’6l6 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use.

By providing tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems containing these graphics processors, Sony has contributed to the infringement of the

’6l6 Patent by end-users —for example, customers - who use said graphics processors provided in Sony’s tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems.

4. The ’659 Patent

a. AlV[D

281. Respondent AMD is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’6_59

Patent.

282. ZiiLabs has obtained products containing graphics processors that AMD imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’659 Patent.

l 2283. Piiisuaniio Commission Rule 2lO.l2(a)(9)(viii), Eiiiiibii 27'iiicli.ide'sa chart ' comparing the asserted independent claims of the ’659 Patent to a representative product containing AMD’s graphics processors. Exhibit 27 shows that products containing AlVlD’s

-71 graphics processors and their use are covered by at least the asserted independent claims of the

’659 Patent. Additionally, pursuant to Commission Rule 2l().l2(a)(9)(x), Exhibit 27 contains _ photographs of the products containing AMD’s graphics processors. Lastly, Commission Rule

2l0.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of

Respondent AMD that violates Section 337. ZiiLabs believes that AMD’s other devices, including AMD’s other GPUs, CPUs, APUs, and graphics cards, and their uses, are covered by at least one of the Asserted Claims of the ’659 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent AMD.

284. Additionally, AMD has indirectly infringed at least one claim of the ’659 Patent by inducing infringement.

285. AMD has been aware of the ’659 Patent and of ZiiLabs’ allegations of infringement since at least the ﬁling of this Complaint. ZiiLabs will serve a public copy of this

Complaint on AMD the day it is ﬁled.

286. Despite AMD’s awareness of the ’659 Patent and ZiiLabs’ allegations, AMD has knowingly and actively induced others to infringe the ’659 Patent by selling GPUs, CPUs,

APUs, and graphics cards containing graphics processors which induce the direct infringement of at least one of the claims of the ’659 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’659 Patent. Upon infonnation and belief, at least one customer has directly infringed one or more claims of

ZiiLabs’ ’659 Patent. .

‘ " " 287. AMD has provided and continues to provide products that cannot and do'not' " ' operate except in a manner that infringes the ’659 Patent. As shown for the representative product containing AMD’s graphics processors (Exhibit 27), AMD’s products function in a

-72 manner that infringes the claims of the ’659 Patent. At least by providing users with products that necessarily infringe the ’659 Patent, AMD has induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’659 Patent.

288. Finally, AMD has indirectly infringed at least one of the claims of the ’659 Patent by contributing to infringement.

289. The graphics processors in AMD’s GPUs, CPUs, APUs, and graphics cards are made solely for the purpose of operating in a manner that infringes at least one claim of the ’659

Patent by end-users —for example, customers —who use said graphics processors provided in

AMD’s GPUs, CPUs, APUs, and graphics cards.

b. Lenovo

290. Respondent Lenovo is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’659

Patent. _ 291. ZiiLabs has obtained products containing graphics processors that Lenovo imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’659 Patent.

292. Pursuant to Commission Rule 2lO.l2(a)(9)(viii), Exhibit 24 includes a chart comparing the asserted independent claims of the ’659 Patent to a representative Lenovo product. Exhibit 24 shows that the Lenovo product and its use are covered by at least the

-73 asserted independent claims of the ’659 Patent. Additionally, pursuant to Commission Rule

210. l2(a)(9~)(x),Exhibit 24 contains photographs of the Lenovo product. Lastly, Commission

Rule 2l 0.12(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent Lenovo that violates Section 337. ZiiLabs believes that Lenov0’s other devices, including Lenovo’s other servers, workstations, desktops, notebooks, laptops, all-in-ones,

Chromebooks, and tablets, and their uses, are covered by at least one of the Asserted Claims of the ’659 Patent and have been imported, sold for importation, or sold within the United States after impoitation by Respondent Lenovo.

293. In addition to incorporating graphics processors in a manner that directly infringes at.least one of the Asserted Claims of the ’659 Patent, as does its use, as shown in Exhibit 24,

ZiiLabs also believes that Lenovo incorporates graphics processors from other companies into its other servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets in a manner that similarly infringes the Asserted Claims of the ’659 Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against

Lenovo’s importation, sale for importation, and/or sale after importation of these products as well.

294. Additionally, Lenovo has indirectly infringed at least one claim of the ’659 Patent by inducing infringement.

295. Lenovo has been aware of the ’659 Patent and of ZiiLabs’ allegations of infringement since at least August 5, 2016, when ZiiLabs sent Lenovo notice letters.

(Conﬁdential Exhibit 330.) ZiiLabs will serve a public copy of this Complaint on Lenovo the day it is ﬁled.

_74_ 296. Despite Lenovo’s awareness of the ’659 Patent and ZiiLabs’ allegations, Lenovo has knowingly and actively induced others to infringe the ’659 Patent by selling sewers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets containing graphics processors which induce the direct infringement of at least one of the claims of the ’659

Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’659 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’659 Patent.

297. Lenovo has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’659 Patent. As shown for the representative

Lenovo product (Exhibit 24), Lenovo’s products function in a manner that infringes the claims of the ’659 Patent. At least by providing users with products that necessarily infringe the ’659

Patent, Lenovo has induced and is actively inducing infringement of at least one claim of

ZiiLabs’ ’659 Patent.

298. Finally, Lenovo has indirectly infringed at least one of the claims of the ’659

Patent by contributing tolinfringement.

299. The graphics processors in Lenovo’s servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets are made solely for the purpose of operating in a manner that infringes at least one claim of the ’659 Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’659 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use.

By providing servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets containing these graphics processors, Lenovo has contributed to the infringement of the

’659 Patent by end-users —for example, customers —who use said graphics processors provided

-75 in Lenovo’s servers, workstations, desktops, notebooks, laptops, all-in-ones, Chromebooks, and tablets.

_c. LG

300. Respondent LG is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’659

Patent.

301. ZiiLabs has obtained products containing graphics processors that LG imported, sold for importation, and/or sold Withinthe United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’659 Patent.

302. Pursuant to Commission Rule 210. 12(a)(9)(viii), Exhibit 25 includes a chart comparing the asserted independent claims of the ’65~9Patent to a representative LG product.

Exhibit 25 shows that the LG product and its use are covered by at least the asserted independent claims of the ’659 Patent. Additionally, pursuant to Commission Rule 210.l2(a)(9)(x), Exhibit

25 contains photographs of the LG product. Lastly, Commission Rule 2l0.l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent LG that violates

Section 337. ZiiLabs believes that LG’s other devices, including LG’s other desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and

DVD and Blu-ray players, and their uses, are covered by at least one of the Asserted Claims of the ’659 Patent and have been imported, sold for importation, or sold within the United=States after importation by Respondent LG.

303. ln addition to incorporating graphics processors in a manner that directly infringes at least one of the Asserted Claims of the ’659 Patent, as does its use, as shown in Exhibit 25,

ZiiLabs also believes that LG incorporates graphics processors from other companies into its

_76_ other desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players in a manner that similarly infringes the Asserted

Claims of the ’659 Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against LG’s importation, sale for importation, and/or sale after importation of these products as well.

304. Additionally, LG has indirectly infringed at least one claim of the ’659 Patent by inducing infringement.

305. LG has been aware of the ’659 Patent and of ZiiLabs’ allegations of infringement since at least August 5, 2016, when ZiiLabs sent LG notice letters. (Conﬁdential Exhibit 331.)

ZiiLabs will serve a public copy ofthis Complaint on LG the day it is ﬁled.

306. Despite LG’s awareness of the ’659 Patent and ZiiLabs’ allegations, LG has knowingly and actively induced others to infringe the ’659 Patent by selling desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and

DVD and Blu-ray players containing graphics processors which induce the direct infringement of at least one of the claims of the ’659 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’659 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of

ZiiLabs’ ’659 Patent.

307. LG has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’659 Patent. As shown for the representative LG product

(Exhibit 25); LG’s products function in a manner"that infringes the claims of the "659 Patent? At " least by providing users with products that necessarily infringe the ’659 Patent, LG has induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’659 Patent.

-77_ 308. Finally, LG has indirectly infringed at least one of the claims of the ’659 Patent by contributing to infringement.

309. The graphics processors in LG’s desktops, notebooks, laptops, all-in-ones,

Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players are made solely for the purpose of operating in a manner that infringes at least one claim of the ’659

Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’659 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use. By providing desktops, notebooks, laptops, all-in ones, Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players containing these graphics processors, LG has contributed to the infringement of the ’659 Patent by end-users —for example, customers —who use said graphics processors provided in LG’s desktops, notebooks, laptops, all-in-ones, Chromebooks, tablets, smartphones, wearables, televisions, and DVD and Blu-ray players.

d. MediaTek

310. Respondent MediaTek is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’659 Patent.

311. ZiiLabs has obtained products containing graphics processors that MediaTek imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’659 Patent; -- W — _

312. Pursuant to Commission Rule 2l0.l2(a)(9)(viii), Exhibit 28 includes a chart comparing the asserted independent claims of the ’659 Patent to a representative product containing MediaTek’s graphics processors. Exhibit 28 shows that products containing

-73 \

MediaTek’s graphics processors and their use are covered by at least the asserted independent claims of the ’659 Patent. Additionally, pursuant to Commission Rule 210.12(a)(9)(x), Exhibit

28 contains photographs of the product containing MediaTel<’sgraphics processors. Lastly,

Commission Rule 210. l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent MediaTek that violates Section 337. ZiiLabs believes that

MediaTek’s other devices, including MediaTek’s other SoCs, and their uses, are covered by at least one of the Asserted Claims of the ’659 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent MediaTek. .

313. Additionally, MediaTek has indirectly infringed at least one claim of the ’659

Patent by inducing infringement.

314. MediaTek has been aware of the ’659 Patent and of ZiiLabs’ allegations of infringement since at least August 18, 2016, when ZiiLabs sent MediaTek notice letters.

(Conﬁdential Exhibit 332.) ZiiLabs will serve a public copy of this Complaint on MediaTek the day it is ﬁled.

315. Despite MediaTel<’sawareness of the ’659 Patent and ZiiLabs’ allegations,

MediaTek has knowingly and actively induced others to infringe the ’659 Patent by selling SoCs containing graphics processors which induce the direct infringement of at least one of the claims of the ’659 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’659 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’659 Patent.

316. _MediaTek has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’659 Patent. As shown for the representative product containing MediaTel<’sgraphics processors (Exhibit 28), MediaTek’s products function

-79 in a manner that infringes the claims of the ’659 Patent. At least by providing users with products that necessarily infringe the ’659 Patent, MediaTek has induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’659 Patent.

317. Finally, MediaTek has indirectly infringed at least one of the claims of the ’659

Patent by contributing to infringement.

318. The graphics processors in MediaTek’s SoCs are made solely for the purpose of operating in a manner that infringes at least one claim of the ’659 Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’

’659 Patent, are not staple commodities of commerce, and are not suitable for substantial non infringing use. By providing SoCs containing these graphics processors, MediaTek has contributed to the infringement of the ’659 Patent by end-users -—forexample, customers —who use said graphics processors provided in MediaTek’s SoCs.

e. Motorola

319. Respondent Motorola is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’659 Patent.

320. ZiiLabs has obtained products containing graphics processors that Motorola imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asseited Claims of the ’659 Patent.’

321. Pursuant to Commission Rule 210. l2(a)(9)(viii), Exhibit 26 includes a chart comparing the asserted independent claims of the ’659 Patent to a representative Motorola product. Exhibit 26 shows that the Motorola product and its use are covered by at least the asserted independent claims of the ’659 Patent. Additionally, pursuant to Commission Rule

_g0_ 210.12(a)(9)(x), Exhibit 26 contains photographs of the Motorola product. Lastly, Commission

Rule 2l().l2(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent Motorola that violates Section 337. ZiiLabs believes that Motorola’s other devices, including Motorola’s other smartphones and wearables, and their uses, are covered by at least one of the Asserted Claims of the ’659 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent Motorola.

322. In addition to incorporating graphics processors in a manner that directly infringes at least one of the Asserted Claims of the ’659 Patent, as does its use, as shown in Exhibit 26,

ZiiLabs also believes that Motorola incorporates graphics processors from other companies into its other smartphones and wearables in a manner that similarly infringes the Asserted Claims of the ’659 Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond against Motorola’s importation, sale for importation, and/or sale after importation of these products as Well.

323. Additionally, Motorola has indirectly infringed at least one claim of the ’659

Patent by inducing infringement.

324. Motorola has been aware of the ’659 Patent and of ZiiLabs’ allegations of infringement since at least August 5, 2016, when ZiiLabs sent Lenovo, Motorola’s parent, notice letters. (Conﬁdential Exhibit 330.) ZiiLabs will serve a public copy of this Complaint on

Motorola the day it is filed. h

325. Despite Motorola’s awareness of the ’659 Patent and ZiiLabs’ allegations,

Motorola has knowingly and actively induced others to infringe the ’659 Patent by selling smartphones containing graphics processors which induce the direct infringement of at least one of the claims of the ’659 Patent by end-users —for example, customers. These devices are pre

.8] programmed to function in the manner claimed in the ’659 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’659 Patent. I

326. Motorola has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’659 Patent. As shown for the representative

Motorola product (Exhibit 26), Motorola’s products function in a manner that infringes the claims of the ’659 Patent. At least by providing users with products that necessarily infringe the

’659 Patent, Motorola has induced and is actively inducing infringement of at least one claim of

ZiiLabs’ ’659 Patent.

327. Finally, Motorola has indirectly infringed at least one of the claims of the ’659

Patent by contributing to infringement.

328. The graphics processors in Motorola’s smartphones and wearables are made solely for the purpose of operating in a manner that infringes at least one claim of the ’659

Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’659 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use. By providing smartphones and wearables containing these graphics processors, Motorola has contributed to the infringement of the ’659 Patent by end-users —for example, customers —who use said graphics processors provided in Motor0la’s smaitphones and wearables.

f. Qualcomm

329. Respondent Qualcomm is engaged in the importation, the sale for importation, and/or the sale within the United States after importation of certain graphics processors and i products containing the same that infringe or are used to infringe at least the Asserted Claims of the ’659 Patent.

_g2 330. ZiiLabs has obtained products containing graphics processors that Qualcomm imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’659 Patent.

331. Pursuant to Commission Rule 2l0.l2(a)(9)(viii), Exhibits 24, 25, and 26 include charts comparing theiasserted independent claims of the ’659 Patent to representative products containing Qualcomm’s graphics processors. Exhibits 24, 25, and 26 show that products containing Qualcomm’s graphics processors and their use are covered by at least the asserted independent claims of the ’659 Patent. Additionally, pursuant to Commission Rule

~2l0.lZ(a)(9)(x), Exhibits 24, 25, and 26 contain photographs of the products containing

Qualcomm’s graphics processors. Lastly, Commission Rule 2lO.l2(a)(9)(viii) requires that

Complainant chart only “a representative involved article” of Respondent Qualcomm that violates Section 337. ZiiLabs believes that Qualcomm’s other devices, including Qualcomm’s other all-in-one processors, SoCs, and baseband processors, and their uses, are covered by at least one of the Asserted Claims of the ’659 Patent and have been imported, sold for importation, or sold within the United States after importation by Respondent Qualcomm.

332. Additionally, Qualcomm has indirectly infringed at least one claim of the ’659

Patent by inducing infringement.

333. Qualcomm has been aware of the ’659 Patent and of ZiiLabs’ allegations of infringement since at least the ﬁling of this Complaint. ZiiLabs will serve a public copy of this

Complaint on Qualcomm the day it is ﬁled.

' ""3341 Despite Qualcomm’s‘ awarenessof the ’65’9Patent and ZiiLabs’ allegations,- -- -

Qualcomm has knowingly and actively induced others to infringe the ’659 Patent by selling all in-one processors, SoCs, and baseband processors containing graphics processors which induce

-33 the direct infringement of at least one of the claims of the ’659 Patent by end-users —for example, customers. These devices are pre-programmed to function in the manner claimed in the ’659 Patent. Upon information and belief, at least one customer has directly infringed one or more claims of ZiiLabs’ ’659 Patent.

335. Qualcomm has provided and continues to provide products that cannot and do not operate except in tamanner that infringes the ’659 Patent. As shown for the representative products containing Qualcomm’s graphics processors (Exhibits 24, 25, and 26), Qualcomm’s products function in a manner that infringes the claims of the ’659 Patent. At least by providing users with products that necessarily infringe the ’659 Patent, Qualcomm has induced and is actively inducing infringement of at least one claim of ZiiLabs’ ’659 Patent.

336. Finally, Qualcomm has indirectly infringed at least one of the claims of the ’659

Patent by contributing to infringement. i

337. The graphics processors in Qualcomm’s all-in-one processors, SoCs, and baseband processors are made solely for the purpose of operating in a manner that infringes at least one “claimof the ’659 Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’659 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use. By providing all-in-one processors, SoCs, and baseband processors containing these graphics processors,

Qualcomm has contributed to the infringement of the ’659 Patent by end-users —for example, customers —who use said graphics processors provided in Qualcomm’s all-in-one processors,

SoCs, and baseband processors.

g. Sony '

338. Respondent Sony is engaged in the importation, the sale for importation, and/or the sale within the United States alter importation of certain graphics processors and products

-34 containing the same that infringe or are used to infringe at least the Asserted Claims ofthe ’659

Patent.

339. ZiiLabs has obtained products containing graphics processors that Sony imported, sold for importation, and/or sold within the United States after importation, and that infringe, directly or indirectly, at least the Asserted Claims of the ’659 Patent.

340. Pursuant to Commission Rule 2l0.l2(a)(9)(viii), Exhibits 27 and 28 include charts comparing the asserted independent claims of the ’659 Patent to representative Sony products. Exhibits 27 and 28 show that the Sony products and their use are covered by at least the asserted independent claims of the ’659 Patent. Additionally, pursuant to Commission Rule

2I0.I2(a)(9)(x), Exhibits 27 and 28 contain photographs of the Sony products. Lastly,

Commission Rule 2l0.12(a)(9)(viii) requires that Complainant chart only “a representative involved article” of Respondent Sony that violates Section 337. ZiiLabs believes that S0ny’s other devices, including Sony’s other tablets, smartphones, wearables, televisions, DVD and Blu ray players, and gaming systems, and their uses, are covered by at least one of the Asserted

Claims of the ’659 Patent and have been imported, sold for importation, or sold within the

United States after importation by Respondent Sony. g

341. In addition to incorporating graphics processors in a manner that directly infringes at least one of the Asserted Claims of the ’659 Patent, as does its use, as shown in Exhibits 27 and 28, ZiiLabs also believes that Sony incorporates graphics processors from other companies into its other tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems in a manner that similarly infringes the Asserted Claims of the ’659 Patent. ZiiLabs intends to and does accuse such products of infringement and seeks remedial orders and a bond

-35 against Sony’s importation, sale for importation, and/or sale after importation of these products as well.

342. ‘Additionally, Sony has indirectly infringed at least one claim of the ’659 Patent by inducing infringement.

343. Sony has been aware of the ’659 Patent and of ZiiLabs’ allegations of infringement since at least August 5, 2016, when ZiiLabs sent Sony notice letters. (Conﬁdential

Exhibit 333.) ZiiLabs will serve a public copy of this Complaint on Sony the day it is ﬁled. l

344. Despite S0ny’s awareness of the ’659 Patent and ZiiLabs’ allegations, Sony has knowingly and actively induced others to infringe the ’659 Patent by selling tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems containing graphics processors which induce the direct infringement of at least one of the claims of the ’659

345. Sony has provided and continues to provide products that cannot and do not operate except in a manner that infringes the ’659 Patent. As shown for the representative Sony products (Exhibits 27 and 28), Sony’s products function in a manner that infringes the claims of the ’659 Patent. At least by providing users with products that necessarily infringe the ’659

Patent, Sony has induced and is actively inducing infringement of at least one claim of ZiiLabs’

’659 Patent.

A 346’. Finally, Sony has indirectly infringed at least one of the claims of the ’659 Patent by contributing to infringement.

-36 347. The graphics processors in Sony’s tablets, smartphones, wearables, televisions,

DVD and Blu-ray players, and gaming systems are made solely for the purpose of operating in a manner that infringes at least one claim of the ’659"Patent. Further, these graphics processors are especially made and/or especially adapted for use in the infringement of ZiiLabs’ ’659 Patent, are not staple commodities of commerce, and are not suitable for substantial non-infringing use.

By providing tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems containing these graphics processors, Sony has contributed to the infringement of the

’659"Patent by end-users —for example, customers —who use said graphics processors provided in Sony’s tablets, smartphones, wearables, televisions, DVD and Blu-ray players, and gaming systems.

B. Speciﬁc Instance of Sale and Importation

1. AMD

1 348. Respondent AMD imports, sells for importation, and/or sells within the United

States after importation the representative AMD Jaguar low power x86-64 8 core CPU with

AMD Radeon Graphics Core Next engine product in the product depicted in Exhibit 32.

Pursuant to Commission Rule 210. l2(a)(3), Exhibit 35 is a copy of a receipt from Best Buy showing a sale of the product containing the representative AMD product within the United

States. As shown in the photographs and PlayStation 4 technical speciﬁcations contained in

Exhibit 32, the product containing the representative AMD product is marked as “Made in

China.” Thus, AMD is violating Section 337 of the Tariff Act of 1930 by importing, selling for importation, and/or selling within the United States after importation into the United States the representative product and other similar products and devices, which directly or indirectly, either literally or under the doctrine of equivalents, infringe the ’952 Patent, the ’35OPatent, the ’6l6

Patent, and the ’659 Patent.

_g7_ 2. Lenovo

349. Respondent Lenovo imports, sells for importation, and/or sells within the United

States after importation the representative Lenovo Yoga Tab 3 product depicted in Exhibit 29.

Pursuant to Commission Rule 210.l2(a)(3), Exhibit 34 is a copy of a receipt from Micro Center showing a sale of the representative Lenovo product within the United States. As shown in the photographs contained in Exhibit 29, the Lenovo product is marked as “Made in China.” Thus,

Lenovo is violating Section 337 of the Tariff Act of 1930 by importing, selling for importation, and/or selling Withinthe United States aﬁer importation into the United States the representative product and other similar products and devices, which directly or indirectly, either literally or under the doctrine of equivalents, infringe the ’952 Patent, the ’350 Patent, the ’616 Patent, and the ’659 Patent.

3. LG

350. Respondent LG imports, sells for importation, and/or sells within the United

States aﬁer importation the representative LG G5 product depicted in Exhibit 30. Pursuant to

Commission Rule 210.l2(a)(3), Exhibit 35 is a copy of a receipt from Best Buy showing a sale of the representative LG product within the United States. As shown in the photographs contained in Exhibit 30, the LG product is marked as “Made in Korea.” Thus, LG is violating

Section 337 of the Tariff Act of 1930 by importing, selling for importation, and/or selling within the United States after importation into the United States the representative product and other similar products and devices, which directly or indirectly, either literally or under the doctrine of equivalents, infringe the ’952 Patent, the ’350 Patent, the ’6l6 Patent, and the ’659 Patent.

4. MediaTek

351. Respondent MediaTek imports, sells for importation, and/or sells within the

United States aﬂer importation the representative MediaTek Helio P10 (MT6755) product in the

-33 product depicted in Exhibit 33. Pursuant to Commission Rule 2l0.12(a)(3), Exhibit 37 is a copy

of a receipt from Best Buy showing a sale of a product containing the representative MediaTek

product within the United States. As shown in the photographs and screenshot contained in

Exhibit 33, the packaging of the product containing the representative MediaTek product is

marked as “Made in China.” Thus, MediaTek is violating Section 337 of the Tariff Act of l93O

by importing, selling for importation, and/or selling within the United States after importation

into the United States the representative product and other similar products and devices, which

directly or indirectly, either literally or under the doctrine of equivalents, infringe the ’952

Patent, the ’350 Patent, the ’6l6 Patent, and the ’659 Patent.

5. Motorola 1

352. Respondent Motorola imports, sells for importation, and/or sells within the United

States after importation the representative Motorola Z 4G LTE product depicted in Exhibit 31.

Pursuant to Commission Rule 2l0.l2(a)(3),’ Exhibit 36 is a copy of a receipt from Best Buy

showing a sale of the representative Motorola product within the United States. As shown in the

photographs contained in Exhibit 31, the Motorola product’s packaging is marked as “Phone

Made in China.” Thus, Motorola is violating Section 337 of the Tariff Act of 1930 by importing,

selling for importation, and/or selling within the United States after importation into the United

States the representative product and other similar products and devices, which directly or

indirectly, either literally or under the doctrine of equivalents, infringe the ’952 Patent, the ’35O

,1 . Patent, the ’616 Patent, iand the ’659 Patent.

_ _ 6. Qualcomm , _, _ ,_ _E.,_ t . .. . -;

353. Respondent Qualcomm imports, sells for importation, and/or sells within the

United States after importation the representative Qualcomm APQ8009 processor with Adreno

304 GPU and Snapdragon 820 processor with Adreno 530 GPU products in the products

-39 depicted in Exhibits 29, 30, and 3l. Pursuant to Commission Rule 2lO.l2(a)(3), Exhibits 34, 35 and 36 are copies of receipts from Micro Center and Best Buy showing sales of products containing the representative Qualcomm products within the United States. As shown in the photographs and screenshots contained in Exhibits 29, 30, and 31, the products containing the representative Qualcomm products are marked as “Made in China,” “Made in Korea” and

“Phone Made in China.” Thus, Qualcomm is violating Section 337 of the Tariff Act of 1930 by importing, selling for importation, and/or selling within the United States after importation into the United States the representative products and other similar products and devices, which directly or indirectly, either literally or under the doctrine of equivalents, infringe the ’952

Patent, the ’350 Patent, the ’6l6 Patent, and the ’659 Patent.

7. Sony

354. Respondent Sony imports, sells for importation, and/or sells within the United

States after importation the representative Sony PlayStation 4 and Xperia XA Ultra products depicted in Exhibits 32 and 33. Pursuant to Commission Rule 2l.O.l2(a)(3), Exhibits 35 and 37 are copies of receipts from Best Buy showing sales of the representative Sony products within the United States. As shown in the photographs contained in Exhibits 32 and 33, the Sony

PlayStation product is marked as “Made in China” and the Sony Xperia XA Ultra product’s packaging is marked as “Made in China.” Thus, Sony is violating Section 337 of the Tariff Act of 1930 by importing, selling for importation, and/or selling witl1inthe United States after importation into the United States the representative product and other similar products and devices, which directly or indirectly, either literally or under the doctrine of equivalents, infringe the ’952 Patent, the ’35()Patent, the ’6l6 Patent, and the ’659 Patent.

_9()_ VI. HARMONIZED TARIFF SCHEDULE INFORMATION

355. ‘The articles subject to this complaint are classiﬁable under at least the following headings and subheadings of the Harmonized Tariff Schedule (“HTS”) of the United States:

1 lg: 8542.31.00(ElectronicIntegratedCircuits: Processorsand controllers,

whether or not combined with memories, converters, logic circuits, ampliﬁers,

clock and timing circuits, or other circuits); 8542.39.00 (Electronic integrated

Circuits: Other);

0 Gaming systems: 9504.50.00 (Video game consoles and machines, articles for

arcade, table or parlor games, including pinball machines, bagatelle, billiards and

special tables for casino games; automatic bowling alley equipment; parts and

accessories thereof: Video game consoles and machines, other than those of

subheading 9504.30, and parts and accessories thereof);

I Personal computers. tablets. servers. and workstations: 8471.30.01 (Portable

automatic data processing machines, weighing not more than 10 kg, consisting of

at least a central processing unit, a keyboard, and a display), 8471.49.00 (Other

[Automatic data processing machines and units thereof; magnetic or optical

readers, machines for transcribing data onto data media in coded fonn and

machines for processing such data, not elsewhere speciﬁed or included], entered

in the form of systems), 8471.50.01 (Processing units other than those of

subheading 8471.41 or 8471.49, whether or not containing in the same housing

7 **one or two of the following types of unit: storage units, input units, output units); KWe

1 ' Smagtphones: 8517.12.00 (Telephones for cellular networks or for other wireless

networks), 8517.18.00 (Other apparatus for transmission or reception of voice,

_91_

\ images, or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network)), 8517.62.00 (Machines for the reception, conversion, and transmission or regeneration of voice, images or other data, including switching and routing apparatus);

Televisions: 8528.72.64 (Monitors and projectors, not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording or reproducing apparatus: Reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording or reproducing apparatus: Other, color: Other), 8528.72.72 (Monitors and projectors, not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording or reproducing apparatus: Reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording or reproducing apparatus: Other, color: Other), 8528.72.80 (Monitors and projectors, not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording or reproducing apparatus: Reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording or reproducing apparatus: Other, color: Other); and

:** 8471.41.01(Otherautomaticdataprocessingmachinescomprising""** in the same housing at least a central processing unit and an input and output unit,

Whether or not combined); 8471.50.0l (Processing units other than those of

-92. subheading 8471.41 or 8471.49, whether or not containing in the same housing

one or two of the following types of unit: storage units, input units, output units)

0 related subheadings of the HTS.

356. These HTS numbers are illustrative only and are not intended to restrict the scope of this investigation.

VII. RELATED LITIGATION

357. Contemporaneously with the ﬁling of this complaint, ZiiLabs also intends to ﬁle suits alleging infringement of the Asserted ’952 Patent, ’350 Patent, ’6l6 Patent, and ‘6S9 Patent against AMD, Lenovo, LG, MediaTek, Motorola, Qualcomm, and Sony in the United States

District Court for the Eastern District of Texas.

VIII. DOMESTIC INDUSTRY RELATING TO THE ASSERTED PATENTS

A. Intel’s Purchase of ZiiLabs’ U.K. Subsidiary and Licensing of ZiiLabs’ Patents

358. In December 1999, 3DLabs and Intel entered into a Patent License Agreement, pursuant to which Intel acquired license rights to some of the Asserted Patents. (Exhibit 41.)

359. In November of 2012, Intel acquired certain engineering resources and assets related to the U.K. subsidiary of ZiiLabs. In a related transaction, Intel and ZiiLabs also entered into a Patent License Agreement pursuant to which Intel acquired, inter alia, license rights to the remaining Asserted Patents. (Exhibit 42.)

B. A Domestic Industry Relating to the Asserted Patents Exists Due to Intel’s U.S. Activities

360. ZiiLabs alleges the following upon information and belief:

1. Intel’s Graphics Processors

361. Intel is a leader in the design and manufacturing of advanced integrated digital technology platforms. (Exhibit 47 at 1.) An Intel “platform” may consist of a microprocessor

_93_ and chipset, a stand-alone SoC (“system on a chip”), or a multi-chip package, and may be enhanced by additional hardware, software, and services. (Exhibit 47 at I, 5.)

362. Intel sells its platforms primarily to OEMs, ODMs, and industrial and communications equipment manufacturers in the computing and communications industries.

(Exhibit 47 at I.)

363. Intel’s platforms are used across the computing continuum, including in notebooks (including Ultrabook devices), 2 in I systems, desktops, servers, tablets, phones, and the Internet of Things (including wearables, retail devices, and manufacturing devices). (Exhibit

47 at 1.) '

364. A microprocessor is the CPU of a computer system. (Exhibit 47 at 5.) Many of

Intel’s processor families integrate graphics functionality onto the processor die. (Exhibit 47 at

5.) This is accomplished by manufacturing an integrated graphics processor onto the same die as the CPU. (See, e.g., Exhibit 48 (https://en.wikipedia.org/wiki/InteI_HD_and_Iris_Graphicsl.)

365. Intel’s graphics technology currently, includes Intel HD Graphics processors, Intel

Iris Graphics processors, and Intel Iris Pro Graphics processors. (See, e.g., Exhibit 48

(https://en.wikipedia.org/wiki/Intel_HD_and_Iris_Graphics); Exhibit 49

(http://www.intel.com/content/www/us/en/architecture-and-technolo gy/visual technologylgraphics-overview.html); Exhibit 50

(https://en.Wikipedia.org/wiki/List_0f4Intel_graphicsA_processing_units).) ZiiLabs contends that

Intel’s products containing an Intel HD Graphics processor, an Intel Iris Graphics processor, or an Intel Iris Pro Graphics processor practice the Asserted Patents. - ' "

2. ‘Intel’s Foundry Services

366. Intel’s operations include foundry services for manufacturing its processors.

(Exhibit 47 at 8, I2-I3.)

-94 367. The process of designing and manufacturing a microprocessor is a technically complex, time intensive process. (See, e.g., Exhibit 51

(http://www.bloomberg.com/news/articles/20 l6-O6-09/hoW-intel-makes-a-chip).)

368. Intel’s public ﬁlings conﬁrm that lntel manufactures its platforms in the United

States. As of December 26, 2015 —the end of lntel’s ﬁscal 2015 —55% of Intel’s wafer fabrication was conducted within the United States. (Exhibit 47 at 12; see also Exhibit 52

(http://www.intel.com/content/www/us/en/architecture-and-technology/globah manufacmringhtml (map of Intel wafer fabrication sites)).)

369'. Intel’s current, most recent product generations are manufactured using 14 nanometer (nm) transistors - i.e., manufactured using Intel’s l4nm process technology? (See, e.g., Exhibit 47 at l2 (“Our products utilizing our l4nm process technology are in the market and we are continuing to work on the development of our next-generation l0nm process technology.”); Exhibit 53 (http://www.intel.com/content/www/us/en/silicon-innovations/ intel l4nm-technology.html).) . 3. Intel’s Current 14nm Platforms

370. During its ﬁscal 20l 5, Intel offered a range of platforms based on nine different microprocessors —Atom, Celeron, Core i, Core m, ltanium, Pentium, Quark, Xeon, and Xeon

Phi. (Exhibit 47 at 7; see also https://www.intel.com/content/www/us/en/homepage.html at

“Products” tab, click “Processors.”)

371. On its website, Intel provides product speciﬁcations for its platforms. (See

Exhibit 54 (http://ark.intel.com).) These speciﬁcations indicate whether each individual _ processor is current (i.e., “Launched”), future, (i.e., “Announced”), no longer sold (i.e., “End of

2Such microprocessors may also be referred to herein as “l4nm platforms” or “l4nm processors ”

-95 Life”), or no longer supported (i.e., “End of Interactive Support”). These speciﬁcations also include much other information, including which process technology, or “lithography” (i.e., l4nm) is used to fabricate each processor and ‘whichprocessor graphics (i.e., Intel HD Graphics,

Intel Iris Graphics, Intel IrisPro Graphics), if any, is included in each processor.

372. ZiiLabs used these speciﬁcations to determine that 62.5% (187/299) of lntel’s current (i.e., “Launched”) l4nm processors include Intel HD Graphics, Intel Iris Graphics, or

Intel IrisPro Graphics, and therefore qualify as domestic industry products, as of September

2016. V

373. First, ZiiLabs reviewed the feature summary for each platform family to discern which processors are currently “Launched.” (See generally Exhibits 70-329.) Then, ZiiLabs used a tool on the Intel product speciﬁcations website to compare speciﬁcations for the currently launched processors and determine which of those processors were fabricated with l4nm process technology and which of those processors contain Intel HD Graphics, Intel Iris Graphics,‘or Intel

IrisPro Graphics. (Seegenerally Exhibits 70-329.) For ease of reference, ZiiLabs compiled this information into simpliﬁed charts. (See Exhibits 62-65.) As shown in those charts, 39/43 of

Intel’s launched l4nm processors for desktop applications use graphics processing, 44/73 of lntel’s launched l4nm processors for embedded applications use graphics processing, 94/94 of lntel’s launched l4nm processors for mobile applications use graphics processing, and 10/89 of lntel’s launched l4nm processors for server applications use graphics processing.

374. Similarly, ZiiLabs used these speciﬁcations to create similar charts and determine that 47.8% (635/ 1,329) of all of lntel’s current (1'.e.,“Launched”) processors include er —

Intel HD Graphics, Intel Iris Graphics, or Intel IrisPro Graphics, and therefore qualify as

-95 domestic industry products, as of September 2016. (See Exhibits 66-69; see also generally

Exhibits 70-329.)

375. While Intel’s “Launched” processors as of September 2016 include products from a number of product generations made on a number of different manufacturing process nodes, the Intel speciﬁcations attached hereto show that later (more recent) generations of Intel products incorporate Intel HD Graphics, Intel Iris Graphics, or Intel IrisPro Graphics in a greater proportion of individual models. (See generally Exhibits 70-329.) These speciﬁcations also show that a greater proportion of individual models incorporate Intel HD Graphics, Intel Iris

Graphics, or Intel IrisPro Graphics as Intel’s manufacturing process node has shrunk to 14nm

.fromprevious, larger sizes. (See generally Exhibits 70-329.) Thus, if anything, the allocations herein are likely understated since Intel’s current chips are much more likely to utilize Intel HD

Graphics, Intel Iris Graphics, or Intel IrisPro Graphics than older generation chips that are still

“Launched.” Similarly, the proportion of Intel’s facilities, equipment, labor, capital, and engineering, research, and development currently dedicated to Intel HD Graphics, Intel Iris

Graphics, or Intel IrisPro Graphics is likely higher than the proportions utilized herein, which give equal weight to all “Launched” products, whether they are older generation products likely being phased out and not made in high volumes or current-generation products in volume production.

376. For example, public information indicates that “[i]n the fourth quarter of 201.3,

Intel integrated graphics represented, in units, 65% of all PC graphics processor shipments.”

(Exhibit 48.) Although this information is 3 years old, it is still greater than ZiiLabs’ allocation for Intel’s current l4nm platforms (62.5%) and all current Intel platforms (47.8%).

_97_ 377. ZiiLabs believes that non-public evidence provided by Intel in discovery will establish that Intel’s facilities, equipment, labor, capital, and engineering, research, and development with respect to even just one of its ﬁve l4nm wafer fabrication facilities (“fabs”) in the U.S. are signiﬁcant and substantial.

4. Intel s Domestic Industry

378. A domestic industry for the purposes of I9 U.S.C. § l337(a)(2), as deﬁned in

U.S.C. § 1337(a)(3)(A), (B), and (C), exists with respect to Intel’s signiﬁcant and continuous investment in plant and equipment, signiﬁcant and continuous employment of labor or capital, and substantial and ongoing investment in engineering, research, and development in Intel’s Intel

HD Graphics processors, Intel Iris Graphics processors, and Intel Iris Pro Graphics processors.

a. Intel’s Signiﬁcant Investment in Plant and Equipment

379. A domestic industry as deﬁned by l9 U.S.C. § l337(a)(3)(A) exists in the United

States with respect to the articles protected by the Asserted Patents by reason of Intel’s signiﬁcant investment in plant and equipment.

(1) Intel’s 14nm Platforms

380. These most cutting-edge Intel microprocessors, made using l4nm process technology, are manufactured at Intel’s wafer fabrication facilities in Arizona, Oregon, and

Ireland. (Exhibit 47 at I2; see also Exhibit 55 (http://www.tomshardware.co.uk/intel-fab42

l.4nin-cpu-factor)/.news-37599.html); Exhibit 56

(https://en.wikipedia.org/wiki/List_of_Intel_manufacturing_sites (Intel’s Fab 32 and Fab 42 in

Chandler, Arizona, DIC, DID, and D1X fabs in Hillsboro, Oregon, and Fab 24 in Leixlip,

Ireland are l4nm fabs; all except Fab 42 are currently online and making l4nm platforms).)

381. Intel’s U.S. fabs where Intel manufactures l4nm platforms are large, expensive, state-of-the-art facilities.

-93 382. 1ntel’s Fab 32, in Chandler, Arizona, comprises one million (1,000,000) square feet. (See, e.g., Ex. 57 (http://www.intel.com/pressroom/kits/manufacturing/Fab32/index.htm).)

383. 1ntel’sFab 42, in Chandler, Arizona, also comprises approximately one million

(1,000,000) square feet and cost approximately ten billion dollars ($10,000,000,000). (See, e.g.,

Ex. 58 (https://advance.lexis.com/api/permalink/2def7590-b134-46a2-993d dO30b9d74e8c/?context=l000516) (discussing Intel’s construction plans in Oregon —“lt appears to be roughly 1 million square feet, the same size as the $10 billion Fab 42 in Arizona”).)

384. Intel’s D1C Fab, in Hillsboro, Oregon, comprises approximately two-hundred eighty thousand (280,000) square feet, of which one-hundred thousand (100,000) square feet are clean room. (See, e.g., Ex. 59 (https://nwlaborpressorg/2010/1105/11-5-l0Intel.html).)

385. Intel’s DID Fab, in Hillsboro, Oregon, comprises approximately eight-hundred thousand (800,000) square feet, of which one-hundred ninety thousand (190,000) square feet are clean room, and cost approximately two billion dollars ($2,000,000,000). (See, e.g., Ex. 59

(https://nwlaborpress.org/2010/1 105/l l-5—l0lntel.html); see also, e.g., Ex. 60

(http://www.computerworld.com/article/256l 162/computer-hardware/inside-intel-s-d1d-fab--- through-the-looking-g|ass.html1(“DlD...covers a little less than 1 million square feet” and some of the chip making tools in DID “cost more than $10 million each”).)

386. Intel’s DIX Fab, in Hillsboro, Oregon, comprises a total of two million, two hundred thousand (2,200,000) square feet —“two adjoining factories of 1.1 million square feet apiece.” (See Ex. 61 (http://www.oregonlive.com/silicon forest/index.ssf/2015/04/deal;for_,new_Iithography_tools.html).) DIX cost approximately three billion dollars ($3,000,000,000) to build. (See, e.g,, Ex. 61 (http://vwvw.0regonlive.com/silicon forest/index.ssf/2015/04/deal_for_new_lithography_tools.html).)

-99 387. Even without publicly available information on the cost of Fab 32 and the DlC

Fab, and discounting the one million (1,000,000) square feet and ten-billion dollar

($l0,000,000,000) cost of Fab 42, Intel’s currently-online} l4nm fabs in the U.S. comprise

approximately four million, two-hundred and eighty thousand (4,280,000) square feet and cost

five billion dollars ($5,000,000,000).

388. The following table compiles the aforementioned statistics with respect to the size

and cost of lntel’s four online l4nm fabs in the United States, plus cost estimates for Fab 32 and

the DIC Fab as described below:

FAB l SIZE (FIZZ) l COST (estimate as described below) Fab 32 —Chandler, AZ 1,000,000 I $1,666,666,667 DlC —Hillsboro, OR 280,000 l $466,666,667 Dl D —Hillsboro, OR 800,000 I $2,000,000,000

DIXTotal —Hillsboro, OR4,280,000 2,200,000 I $7$3,000,000,0009 133 9 333 9 334

Table 1 —Cost and size of Intel’s currently-online 14nm U.S. fabs

389. In order to estimate the cost of Fab 32 and the DlC Fab, ZiiLabs used publicly i

available information about Intel’s other currently-online 14nm fabs - DlD and DlX. As shown

in Table l above, the DID and DlX Fabs comprise approximately three million (3,000,000)

square feet and cost a total of about ﬁve billion dollars ($5,000,000,000). Therefore, the cost of

2 building these two fabs was approximately $1,666.66/ft. ZiiLabs multiplied that cost per square

foot by the square footage of Fab 32 and the DlC Fab to calculate the estimated total cost for

each of those two fabs.

_, _ -390. Therefore, discounting Fab 42 which is not currently online, Intel’s currently- - *— ri

operating l4nm fabs in the U.S. comprise approximately four million, two-hundred and eighty

3Since Fab 42 is not currently online, ZiiLabs did not consider it for these domestic industry pleadings.

-100- ' thousand (4,280,000) square feet and cost approximately seven billion, one-hundred thirty-three million, three-hundred thirty-three thousand, three-hundred and thirty-four dollars

($7,l33,333,334). I

391. Multiplying those numbers by the 62.5% of Intel’s current l4nm processors that include Intel HD Graphics, Intel Iris Graphics, or Intel IrisPro Graphics reveals that Intel currently operates at least two million, six-hundred and seventy-ﬁve thousand (2,675,000) square feet of fabs in the U.S. dedicated to manufacturing domestic industry products, and that the cost of those fabs attributable to the domestic industry products is approximately four billion, four hundred ﬁfty-eight million, three-hundred thirty-three thousand, three-hundred and thirty-four dollars ($4,458,333,334).

392. These numbers alone demonstrate that Intel’s investments in plant and equipment, just with respect to l4nm processors containing Intel HD Graphics, Intel Iris Graphics, or Intel

IrisPro Graphics, comprise a domestic industry in the U.S. with respect to ZiiLabs’ Asserted

Patents.

(2) All Intel Platforms

393. Intel owns and leases millions of additional square feet of facilities in the U.S. As ofDecember 26, 2015 —the end of Intel’s ﬁscal 2015 —Intel’s major facilities consisted of:

*squarefeet, in millions United States Other Countries Total

Owned Facilities 30.7 17.2 47.9

Leased Facilities . .

Total I 32.8 | 23.2

(Exhibit 47 at 28.) Intel’s principal executive offices and the majority of Intel’s wafer fabrication facilities are located in the United States. (Exhibit 47 at 28.)

-lOl

to ._

oo\

V1 .6‘ 9° C) ._ 394. Multiplying those U.S. numbers by the 47.8% of Intel’s current processors that include Intel HD Graphics, Intel Iris Graphics, or Intel IrisPro Graphics reveals that as of

December 26, 2015, Intel owned 14,674,600 square feet of facilities in the U.S. and leased another 1,003,800 square feet of facilities in the U.S. that are allocable to the domestic industry products practicing ZiiLabs’ Asserted Patents.

395. At the end of its ﬁscal 2015, Intel held $31,858,000,000 worldwide in property, plant and equipment as follows:

Total

United States I $22,6l 1,000,000

Ireland $5-,789,000,000

Israel $1,661,000,000

Other Countries $1,797,000,000

Total $3I,858,000,000

(Exhibit 47 at 122.) ~

396. Multiplying those U.S. numbers by the 47.8% of Intel’s current processors that include Intel HD Graphics, Intel Iris Graphics, or Intel IrisPro Graphics reveals that as of

December 26, 2015, Intel held $10,808,05 8,000 of property, plant and equipment in the U.S. that are allocable to the domestic industry products practicing ZiiLabs’ Asserted Patents.

397. Additionally, in ﬁscal 2015, Intel made additions to property, plant and equipment totaling $7,326,000,000. (Exhibit 47 at 31.)

l 398. For its ﬁscal 2016, Intel currently has $234,000,000 in payments due for operating lease obligations and $4,250,000,000 in capital purchase obligations (i.e.,

-102 “commitments for the construction or purchase of property, plant and equipment”). (Exhibit 47 at 54.)

399. Given these additional holdings of and investments in plant and equipment in the

U.S., Intel’s activities with respect to Intel HD Graphics, lntel Iris Graphics, Intel IrisPr0

Graphics, and/or processors utilizing such graphics processing comprise a domestic industry in the U.S. with respect to ZiiLabs’ Asserted Patents.

b. Intel’s Signiﬁcant Employment of Labor and Capital

400. A domestic industry as deﬁned by 19 U.S.C. § 1337(a)(3)(B) exists in the United

States with respect to the articles protected by the Asserted Patents by reason of Intel’s signiﬁcant employment of labor and/or capital.

(1) Intel’s 14nm Platforms

401. In addition to their size, Intel’s U.S. fabs where Intel manufactures l4nm platforms employ thousands of U.S.-based employees.

402. Intel’s Fab 32, in Chandler, Arizona, houses over one thousand (1,000) U.S. based employees. (See, e.g., Ex. 57

(http://www.intel.c0m/pressroom/kits/manufacturing/Fab32/index.htm).)

403. Intel’s DID Fab, in Hillsboro, Oregon, employs several hundred U.S.-based technicians. (See, e.g., Ex. 60 (http://www.computerworld.com/article/256I162/computer hardware/inside-intel-s-d1d-fab----through-the-looking-glasshtmli.)

404. Intel’s DIX Fab, in Hillsboro, Oregon, also employs as many as one thousand

(1,000) skilled manufacturing and research U7._S_.-basedemployees, (See, e.g., Ex. 59 ..

(https://nwlaborpressorg/2010/I 105/11-5-l0Intel.html).) i

-103 405. Even without publicly available information on the number of employees at the

DIC Fab, lntel’s currently-online l4nm fabs in the U.S. employ over two-thousand (2,000) U.S. based employees.

406. The following table compiles the aforementioned statistics with respect to the number of employees at lntel’s currently-online l4nm fabs in the U.S., plus employment estimates for the DIC Fab and the DID Fab as described below:

NUMBER OF EMPLOYEES (estimate as described FAB below) Fab 32 ——Chandler,AZ l,000 DIC —Hillsboro, OR DID —Hillsboro, OR DIX —Hillsboro, OR 1,000 Total 2,675

Table 2 -»Number of employees at Intel’s currently-online l4nm U.S. fabs

407. In order to estimate the number of employees at the DIC Fab and DID Fab,

ZiiLabs used publicly available information about Intel’s other currently-online l4nm fabs —Fab

32 and DIX. As shown in Tables I and 2 above, Fab 32 and the DIX Fab comprise I approximately three million two-hundred thousand (3,200,000) square feet and employ two thousand (2,000) U.S.-based employees. Therefore, these two fabs employ approximately one

(I) U.S.-based employee per one-thousand six-hundred (1,600) square feet. ZiiLabs divided the square footage of the DIC Fab and DID Fab by one-thousand six-hundred (1,600) to calculate an estimated number of U.S.-based employees for each of these two fabs.

408. Based on that calculation, Intel’s currently-operating l4nm fabs in the U.S. employ approximately two-thousand six-hundred and seventy-ﬁve (2,675) U.S.-based employees.

-l04

l\| QU1 © G 409. Multiplying that number by the 62.5% of Intel’s current 14nm processors that include Intel HD Graphics, Intel Iris Graphics, or Intel IrisPro Graphics reveals that Intel currently employs at least approximately one-thousand six-hundred and seventy-two (1,672)

U.S.-based employees at fabs in the U.S. dedicated to manufacturing 14nm domestic industry products.

410. These numbers alone demonstrate that Intel’s employment of labor and capital, just with respect to 14nm processors containing Intel HD Graphics, Intel Iris Graphics, or Intel

IrisPro Graphics, comprise a domestic industry in the U.S. with respect to ZiiLabs’ Asserted

Patents.

(2) All Intel Platforms

411. As of December 26, 2015 —the end of lnte1’s ﬁscal 2015 —Intel had 107,300 employees worldwide, with approximately 51% of these employees (i.e., approximately 55,000) located in the United States. (Exhibit 47 at l5; see also id. at 31.)

412. Multiplying those U.S. numbers by the 47.8% of Intel’s current processors that include Intel HD Graphics, Intel Iris Graphics, or Intel IrisPro Graphics reveals that as of

December 26, 2015, Intel employed approximately 26,290 people in the U.S. that are allocable to the domestic industry products practicing ZiiLabs’ Asserted Patents.

i 413. I Further, Intel added approximately 600 employees worldwide from the end of

ﬁscal 2014 through the end of ﬁscal 2015. (Exhibit 47 at 31.)

414. At the end of its ﬁscal 2015, Intel also owed $3,l38,000,000 in accrued compensation and beneﬁts. (Exhibit 47 at 63.) _ __ .. . . .

4,15. Also in its ﬁscal 2015, Intel invested $7,326,000,000 in capital expenditures.

(Exhibit 47 at 50.)

-105 416. Given this additional employment of labor and capital in the U.S., Intel’s activities with respect to Intel HD Graphics, Intel Iris Graphics, Intel IrisPro Graphics, and/or processors utilizing such graphics processing comprise a domestic industry in the U.S. with respect to ZiiLabs’ Asserted Patents. _

c. Intel’s Substantial Investment in the Exploitation of the Asserted Patents

417. A domestic industry as deﬁned by 19 U.S.C. § 1337(a)(3)(C) exists in the United

States with respect to the Asserted Patents by reason of Intel’s substantial investmentlin its engineering, research, and development directed to its products covered by ZiiLabs’ Asserted

Patents.

418. Intel’s total investment in research and development for ﬁscal 2015 was

$12,128,000,000, or 21.9% of net revenue. (Exhibit 47 at 40; see also id. at 61.) Intel’s R&D activities range from designing and developing new products and manufacturing processes to researching future technologies and products. (Exhibit 47 at 15.) These R&D activities include investment in graphics. (Id)

419. While publicly available information does not appear to disclose the exact nature of Intel’s R&D activities in the U.S. with respect to its processors or graphics, given Intel’s level expenditures on R&D including R&D of processors and graphics, discovery from Intel is expected to demonstrate that Intel’s exploitation of the Asserted Patents with respect to Intel HD

Graphics, Intel Iris Graphics, Intel IrisPro Graphics, and/or processors utilizing such graphics processing comprise a domestic industry in the U.S. with respect to ZiiLabs’ Asserted Patents.

-106 C. Intel’s Practice of the Asserted Patents

420. Intel’s Intel HD Graphics, Intel Iris Graphics, Intel IrisPro Graphics, and/or processors utilizing such graphics processing practice the following claims of each of the Asserted Patents:8 4- I ’952 I ’350 l-16 ’6l6 1-8

I ’659 1-20

421. Pursuant to Commission Rule 2lO.l2(a)(9)(ix), Exhibits 43-46 include charts that apply an exemplary claim of each Asserted Patent to a representative Intel product that practices that patent. IX. RELIEF

WHEREFORE, by reason of the foregoing, ZiiLabs requests that the Commission:

l) Institute an investigation pursuant to Section 337 of the Tariff Act of 1930, as amended, 19 U.S.C. § 1337, with respect to Respondents’ violations of Section 337 based on the importation into the United States, the sale for importation into the United States, and/or the sale within the United States after importation of articles that infringe the Asserted Patents; _

2) Schedule and conduct a hearing on permanent relief pursuant to 19"U.S.C. § l337(d) and (f) of the Tariff Act of 1930, as amended;

3) Issue a_Limited Exclusion Order speciﬁcally directed to each named Respondent, pursuant to 19 U.S.C. § l337(d), excluding from entry into the United States articles that infringe the Asserted Patents;

4) Issue a cease and desist order pursuant to 19 U.S.C. § l337(f) prohibiting each domestic Respondent from engaging in the unlawful importation and/or the sale within the United States after importation of articles that infringe the Asserted Patents; and

5) Impose a bond upon Respondents who continue to import infringing articles during the 60-day-Presidential review period per l9 U.S.C. § l337(i); and issue

-107

00 such other and further relief as the Commission deems just and proper under the law, based upon the facts determined by the investigation and the authority of the Commission.

-108 December 16, 2016 Respectfully submitted,

Goutam4/a~/5/£1-8*-'~' Patn Tuhin Ganguly David J. Shaw Pepper Hamilton LLP Hamilton Square 600 Fourteenth Street, N.W. Washington, DC 20005-2004 202.220.1200 202.220.1665 (facsimile)

William D. Belanger Frank D. Liu Supama Datta Ryan C. Deck Pepper Hamilton LLP 19th Floor, High Street Tower 125 High Street Boston, MA O2110-2736 617.204.5100 617.204.5150 (facsimile)

Gregory S. Bishop Pepper Hamilton LLP 333 Twin Dolphin Drive Suite 400 Redwood City, CA 94605 Tel: 650-802-3600 Fax: 650-802-3650

Counsel for Complainant ZiiLabs Inc. Ltd.

-109