1 Robert T. Haslam (Bar No. 71134) [email protected] 2 COVINGTON & BURLING LLP 333 Twin Dolphin Drive, Suite 700 3 Redwood Shores, California 94065 Telephone: (650) 632-4700 4 Facsimile: (650) 632-4800

5 Alan H. Blankenheimer (Bar No. 218713) [email protected] 6 Laura E. Muschamp (Bar No. 228717) [email protected] 7 Christopher K. Eppich (Bar No. 228025) [email protected] 8 Jessica G. Baldwin (Bar No. 260984) [email protected] 9 COVINGTON & BURLING LLP 9191 Towne Centre Drive, 6th Floor 10 San Diego, California 92122 Telephone: (858) 678-1800 11 Facsimile: (858) 678-1600

12 Jon Berkelhammer (Pro hac vice application pending) [email protected] 13 SMITH MOORE LEATHERWOOD LLP 300 N. Greene Street, Suite 1400 14 Greensboro, North Carolina 27420 Telephone: (336) 378-5200 15 Facsimile: (336) 378-5400

16 Attorneys for Plaintiff Peregrine Semiconductor Corporation 17 18 UNITED STATES DISTRICT COURT 19 SOUTHERN DISTRICT OF CALIFORNIA

20 PEREGRINE SEMICONDUCTOR Civil Case No.: '13CV0725 LAB KSC CORPORATION, a Delaware 21 corporation COMPLAINT FOR DAMAGES 22 Plaintiff, AND INJUNCTIVE RELIEF

23 v. (1) Patent Infringement under 35 U.S.C. §§ 271, 281, 283-85 24 RF MICRO DEVICES, INC., a North Carolina corporation, DEMAND FOR JURY TRIAL 25 Defendant. 26 27 28

COMPLAINT Civil Case No.:

1 For its complaint against Defendant RF Micro Devices, Inc. (“RFMD”), 2 Plaintiff Peregrine Semiconductor Corporation (“Peregrine”) complains and 3 alleges as follows: 4 NATURE OF ACTION 5 This is an action for patent infringement arising under the patent laws of the 6 United States, Title 35 of the United States Code, including without limitation 35 7 U.S.C. §§ 271 et seq. Plaintiffs seek damages, attorneys’ fees, costs, and 8 preliminary and/or permanent injunctive relief. 9 JURISDICTION 10 1. This Court has subject matter jurisdiction over this case pursuant to 11 28 U.S.C. §§ 1331 and 1338(a), because this action arises under the patent laws of 12 the United States, Title 35 of the United States Code. 13 2. This Court has personal jurisdiction over RFMD based upon the 14 following: (a) RFMD maintains an office in the Southern District of California; 15 (b) RFMD transacts substantial business in and maintains continuous and 16 systematic contacts with this District and the State of California; (c) RFMD has 17 committed tortious acts that RFMD knew or should have known would cause 18 injury to Peregrine in the Southern District of California; and (d) RFMD has 19 appointed an agent in the State of California to receive service of process. 20 3. Venue is proper in the United States District Court for the Southern 21 District of California under 28 U.S.C. §§ 1391(b)-(d), 1400(b). 22 PARTIES 23 4. Peregrine is a Delaware corporation with a principal place of business 24 at 9380 Carroll Park Drive, San Diego, California 92121. 25 5. Upon information and belief, RFMD is a North Carolina corporation 26 with a principal place of business at 7628 Thorndike Road, Greensboro, North 27 Carolina 27409. 28 1

COMPLAINT Civil Case No.:

1 FACTUAL ALLEGATIONS 2 6. Peregrine is an owner by assignment of all rights, title, and interest in 3 and to United States Patent No. 8,405,147 (the “‘147 Patent”) (Exhibit A). The 4 ‘147 Patent is entitled “Method and Apparatus for Use in Improving Linearity of 5 MOSFETs Using an Accumulated Charge Sink,” and issued on March 26, 2013. 6 7. The ‘147 Patent describes and claims advanced 7 technologies for use in radio frequency switches. Radio frequency switches 8 practicing the ‘147 Patent can be used in a variety of devices including, for 9 example, antenna tuning circuits, devices that use diversity or multiple-input and 10 multiple-output (MIMO) antennas, and mobile devices that use cellular 11 technologies and/or wireless local area network (WLAN) technologies. Mobile 12 wireless devices that use radio frequency switches practicing the ‘147 Patent may 13 transmit and receive wireless signals more efficiently and effectively, since the 14 ‘147 Patent reduces harmonic and intermodulation distortion and thereby 15 improves performance of radio frequency circuits. After significant investments 16 in research and development, engineering, labor, plant and equipment, 17 manufacturing and marketing, Peregrine-branded radio frequency switches that 18 practice the ‘147 Patent have been selected for use in wireless handsets by many 19 of the leading wireless handset manufacturers including Apple, LG, , 20 , and Sony Ericsson. 21 8. RFMD infringes the ‘147 Patent by engaging in acts constituting 22 infringement under 35 U.S.C. § 271, including but not limited to making, having 23 made, importing, using, offering for sale and/or selling radio frequency integrated 24 circuit switches that infringe one or more claims of the ‘147 Patent, including but 25 not limited to those with integrated circuit die markings M1D1604, M1D1293, 26 and M1D8889, which are marketed and sold by RFMD under the RF switch 27 device names RF1604, RF1293, and RF8889A. 28 2

COMPLAINT Civil Case No.:

1 9. RFMD does not have a license to any Peregrine patents or 2 technology. 3 FIRST CAUSE OF ACTION 4 (Infringement of the ‘147 Patent) 5 10. Peregrine incorporates the allegations in the preceding paragraphs as 6 if fully set forth herein. 7 11. Peregrine is the owner by assignment of all rights, title, and interest 8 in and to the ‘147 Patent. Peregrine therefore has standing to sue for infringement 9 of the ‘147 Patent. 10 12. RFMD infringes, literally and/or under the doctrine of equivalents, 11 one or more claims of the ‘147 Patent, by making, having made, importing, using, 12 offering to sell, or selling radio frequency integrated circuit switches that infringe 13 one or more claims of the ‘147 Patent, including but not limited to those with 14 integrated circuit die markings M1D1604, M1D1293, and M1D8889, which are 15 marketed and sold by RFMD under the RF switch device names RF1604, RF1293, 16 and RF8889A. 17 13. On information and belief, RFMD supplies in or from the United 18 States all or a substantial portion of the components of the invention described in 19 the ‘147 Patent, with the intent or knowledge that such components will be used 20 and/or combined in a manner that would otherwise infringe the ‘147 Patent if the 21 activity occurred in the United States, and such components not being suitable for 22 substantial noninfringing use. Those components include but are not limited to 23 those assembled to form radio frequency integrated circuit switches with the 24 integrated circuit die markings M1D1604, M1D1293, and M1D8889, which are 25 marketed and sold by RFMD under the RF switch device names RF1604, RF1293, 26 and RF8889A. 27 14. RFMD has knowledge and notice of the ‘147 patent and its 28 infringement since at least, and through, the filing and service of the Complaint. 3

COMPLAINT Civil Case No.:

1 15. As a direct and proximate result of RFMD’s infringement, Peregrine 2 has suffered, and will continue to suffer, injury. 3 16. As a result of the harm suffered as alleged herein, Peregrine is 4 entitled to all of the remedies available under the Patent Act, including damages 5 adequate to compensate it for such infringement, but in no event less than a 6 reasonable royalty, costs and attorneys’ fees. 7 PRAYER FOR RELIEF 8 WHEREFORE, Peregrine respectfully prays that the Court grant the 9 following relief: 10 A. The entry of judgment in favor of Peregrine and against RFMD; 11 B. A preliminary and/or permanent injunction prohibiting RFMD, its 12 respective officers, agents, servants, employees and/or all persons acting in 13 concert or participation with them, or any of them, from engaging in further 14 infringement of the ‘147 Patent; 15 C. An award of damages adequate to compensate Peregrine for the 16 infringement, as well as prejudgment interest from the date the infringement 17 began, but in no event less than a reasonable royalty as permitted by 35 U.S.C. 18 § 285; 19 D. A finding that, to the extent RFMD knew of its infringing activities, 20 RFMD’s infringement was willful; 21 E. An award of treble damages for the period of any willful 22 infringement pursuant to 35 U.S.C. § 284; 23 F. A finding that this case is exceptional and an award of interest, costs 24 and attorneys’ fees incurred by Peregrine in prosecuting this action as provided by 25 35 U.S.C. § 285; 26 G. For any other orders necessary to accomplish complete justice 27 between the parties; and 28 4

COMPLAINT Civil Case No.:

1 H. For such other and further relief as this Court or a jury may deem just 2 and proper. 3 JURY DEMAND 4 Peregrine demands a trial by jury on all issues triable by jury. 5

6 7 DATED: March 26, 2013 COVINGTON & BURLING LLP 8 By: /s/ Alan H. Blankenheimer Robert T. Haslam 9 COVINGTON & BURLING LLP 333 Twin Dolphin Drive, Suite 700 10 Redwood Shores, California 94065 Telephone: (650) 632-4700 11 Facsimile: (650) 632-4800

12 Alan H. Blankenheimer Laura E. Muschamp 13 Christopher K. Eppich Jessica G. Baldwin 14 COVINGTON & BURLING LLP 9191 Towne Centre Drive, 6th Floor 15 San Diego, California 92122 Telephone: (858) 678-1800 16 Facsimile: (858) 678-1600

17 Jon Berkelhammer SMITH MOORE LEATHERWOOD LLP 18 300 N. Greene Street, Suite 1400 Greensboro, North Carolina 27420 19 Telephone: (336) 378-5200 Facsimile: (336) 378-5400 20 Attorneys for Plaintiff 21 Peregrine Semiconductor Corporation 22 23 24 25 26 27 28 5

COMPLAINT Civil Case No.: