Complex Memory LLC v. Broadcom Corporation

Following a notice letter allegedly sent to Broadcom in April 2018 without response, Complex Memory LLC, an affiliate of Texas monetization firm IPValuation Partners LLC (d/b/a IPVal), has filed suit against the company in the Northern District of California (5:18-cv-07530). The complaint asserts five patents, generally pertaining to chip operation and memory access, already at issue in the campaign, with the NPE identifying certain Broadcom products “incorporating ARM Cortex-A9, A15, A57 and other ARM Cortex-A architectures” as the accused products, specifically identifying Broadcom’s “BCM5871X, BCM58712, BCM58713, BCM4707, BCM4708, BCM4709, BCM5301X, BCM11107, and BCM5862X families of products”. This new case joins suits filed in the latter half of 2018 against Renesas (in July), against Lenovo (Motorola Mobility) (in September), and STMicro (in November).

Last year’s suits winding down, Complex Memory LLC, an affiliate of Texas monetization firm IPValuation Partners LLC (d/b/a IPVal), has added another suit in 2018. The NPE accuses STMicro (1:18-cv-06255) of infringing four of the seven patents-in-campaign through the provision of mobile chipsets with certain features related to memory management. Those accused products include the STiH416 system-on-chip, targeted over its alleged inclusion of an ARM Cortex-A9 Core and its cache memory; certain STM STM32F100xx Series microcontrollers (MCUs), which allegedly include a direct memory access (DMA) controller; the Telemaco3P family of microprocessors (designed for automotive telematics), which allegedly include certain types of DDR memory; and the STiH series of systems-on-chip, targeted over certain energy conservation features of the Cortex-A9. The asserted patents, of disparate origins but all received from Intellectual Ventures LLC (IV), generally relate to chip operation and memory access.

The 2017 cases in its sole litigation campaign either stayed in light of settlement negotiations or having settled already, Complex Memory LLC has added a second 2018 suit, this one against Lenovo (Motorola Mobility) (1:18-cv-06255) in the Northern District of Illinois. Last month, the NPE, an affiliate of IPValuation Partners LLC (d/b/a IPVal), sued Renesas in the Northern District of California, while cases against SVTronics and Texas Instruments (TI) (on July 6) and Huawei (on July 26) were dismissed with prejudice in July. A November 2017 suit against ZTE has been stayed to facilitate settlement. All five cases have asserted the same five patents, broadly concerning various aspects of chip operation and memory access, with the suit against Renesas throwing in two additional such patents. At issue have principally been smartphones based around TI OMAP or ARM core architectures—in the complaint against Motorola Mobility, mobile devices “incorporating ARM Cortex-A53 and other ARM Cortex-A architectures, including Qualcomm Snapdragon, Kryo and Krait devices”.

Complex Memory LLC, an affiliate of IP Valuation Partners LLC (d/b/a IPVal), has added a third suit to the litigation campaign that it began last month, suing ZTE (3:17-cv-03196) in the Northern District of Texas over the same five patents, broadly concerning various aspects of chip operation and memory access. At issue are ZTE “mobile devices, such as smart phones, incorporating ARM Cortex-A53 and other ARM Cortex-A architectures, including Qualcomm Snapdragon, Kryo and Krait devices”. Complex Memory’s October cases were filed in the Eastern District of Texas against Huawei alone and SVTronics and Texas Instruments (TI) together; the defendants have requested extensions of the deadline to respond to the complaints against them.

Yet another affiliate of IP Valuation Partners LLC (d/b/a IPVal) has launched a litigation campaign, the sixth in October alone. Complex Memory LLC has filed complaints against Huawei (2:17-cv-00700) and SVTronics and Texas Instruments (TI) (2:17-cv-00699), each asserting five patents generally related to chip operation and memory access. The NPE accuses Huawei of infringement through the provision of smartphones and tablets that incorporate ARM Cortex-A9, Cortex-A15, Cortex-A53, Cortex-A73, and/or other ARM Cortex-A architectures, and SVTronics and TI of infringement through the provision of products incorporating ARM Cortex-A9 and/or ARM Cortex-A15 architectures. Complex Memory pleads that the latter two defendants are properly named in a single complaint because they both allegedly incorporate TI OMAP processors into the accused products, and because SVTronics purportedly integrates, “and sells products based on”, TI processor designs.