Headway Technologies, Inc. has filed a complaint (2:15-cv-07987) in the Central District of California seeking a declaratory judgment of non-infringement of a single patent (7,128,988) that NPE Lambeth Magnetic Structure, LLC’s (LMS) has previously asserted against Toshiba in the Western District of Pennsylvania (2:14-cv-01526). Headway pleads reasonable apprehension of suit based on LMS’s infringement contentions in the Pennsylvania case, which Headway alleges accuse its components, within Toshiba hard disk drives, of infringement. The ‘988 patent relates to magnetic material and magnetic devices used in data storage.