Case 1:21-cv-00052-UNA Document 1 Filed 01/18/21 Page 1 of 59 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No.
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`JURY TRIAL DEMANDED
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`Plaintiff,
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`v.
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`NIDEC CORPORATION,
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`SEAGATE TECHNOLOGY LLC, SEAGATE
`SINGAPORE INTERNATIONAL
`HEADQUARTERS PTE. LTD., and
`SEAGATE TECHNOLOGY
`(NETHERLANDS) B.V.,
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`Defendants.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff Nidec Corporation (“Nidec” or “Plaintiff”), by way of Complaint against
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`Defendants Seagate Technology LLC, Seagate Singapore International Headquarters Pte. Ltd., and
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`Seagate Technology (Netherlands) B.V. (together “Defendants”), alleges as follows:
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`THE PARTIES
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`1.
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`Nidec is a Japanese corporation with its principal place of business at 338
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`Kuzetonoshiro-cho, Minami-ku, Kyoto, Japan.
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`2.
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`On information and belief, Defendant Seagate Technology LLC is a limited liability
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`company organized and existing under the laws of the State of Delaware with its principal place
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`of business at 47488 Kato Rd., Fremont, California 94538. On information and belief, Seagate
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`Technology LLC may be served with process through its registered agent Corporation Trust
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`Company, 1209 Orange St., Wilmington, DE 19801.
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`3.
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`On
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`information and belief, Defendant Seagate Singapore
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`International
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`Headquarters Pte. Ltd. is a Singapore corporation having a principal place of business at 7000 Ang
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`Mo Kio Avenue 5, Singapore 569877. On information and belief, Defendant Seagate Singapore
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`International Headquarters Pte. Ltd. also maintains an address at Koolhovenlaan 1, 1119 NB
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`Schiphol – Rijk, The Netherlands.
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`4.
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`On information and belief, Defendant Seagate Technology (Netherlands) B.V. is a
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`Netherlands corporation having a principal place of business at Tupolevlaan 105, 1119 PA
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`Schiphol-Rijk, The Netherlands.
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`5.
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`On information and belief, Defendants develop, manufacture, import, offer for sale,
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`and/or sell certain products, including hard disk drives (“HDDs”), for consumers in the United
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`States, including in the State of Delaware.
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`JURISDICTION AND VENUE
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`6.
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`7.
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`Nidec realleges and incorporates each of preceding paragraphs 1–5.
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`This patent infringement action arises under the United States Patent Laws, Title
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`35 U.S.C. § 100 et seq., including 35 U.S.C. § 271. This Court has subject matter jurisdiction under
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`28 U.S.C. §§ 1331 and 1338(a).
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`8.
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`On information and belief, Defendant Seagate Technology LLC has purposefully
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`availed itself of the benefits of doing business in the District of Delaware by designing,
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`manufacturing, distributing, promoting, marketing, selling, offering for sale, and/or importing one
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`or more of the Seagate-branded products identified in this Complaint and deriving substantial
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`revenue from such activities by placing those products into the stream of commerce with the
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`expectation that they will be purchased by consumers within the District of Delaware. For
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`example, on information and belief, Defendant Seagate Technology LLC has designed,
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`manufactured, distributed, promoted, marketed, sold, offered for sale, and/or imported the Seagate
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`16TB IronWolf Pro ST16000NE000 and the Seagate 2TB BarraCuda ST2000LM015. The covers
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`of these products sold in the United States, and on information and belief in this District, identify
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`Defendant Seagate Technology LLC as the manufacturer:
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`9.
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`On
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`information and belief, Defendant Seagate Singapore
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`International
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`Headquarters Pte. Ltd. has purposefully availed itself of the benefits of doing business in the
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`District of Delaware by designing, manufacturing, distributing, promoting, marketing, selling,
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`offering for sale, and/or importing one or more of the Seagate-branded products identified in this
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`Complaint and deriving substantial revenue from such activities by placing those products into the
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`stream of commerce with the expectation that they will be purchased by consumers within the
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`District of Delaware. For example, on information and belief, Defendant Seagate Singapore
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`International Headquarters Pte. Ltd. has designed, manufactured, distributed, promoted, marketed,
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`sold, offered for sale, and/or imported the Seagate 2TB BarraCuda ST2000LM015. The cover of
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`this product sold in the United States, and on information and belief in this District, lists Defendant
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`Seagate Singapore International Headquarters Pte. Ltd. with an address of Koolhovenlaan 1, 1119
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`NB Schiphol – Rijk, The Netherlands:
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`10.
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`On information and belief, Defendant Seagate Technology (Netherlands) B.V. has
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`purposefully availed itself of the benefits of doing business in the District of Delaware by
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`designing, manufacturing, distributing, promoting, marketing, selling, offering for sale, and/or
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`importing one or more of the Seagate-branded products identified in this Complaint and deriving
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`substantial revenue from such activities by placing those products into the stream of commerce
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`with the expectation that they will be purchased by consumers within the District of Delaware. For
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`example, on information and belief, Defendant Seagate Technology (Netherlands) B.V. has
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`designed, manufactured, distributed, promoted, marketed, sold, offered for sale, and/or imported
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`the Seagate 16TB IronWolf Pro ST16000NE000. The cover of this product sold in the United
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`States, and on information and belief in this District, lists Defendant Seagate Technology
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`(Netherlands) B.V. with an address of Tupolevlaan 105, 1119 PA Schiphol – Rijk, The
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`Netherlands.
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`11.
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`This Court has specific personal jurisdiction over Defendants at least because, on
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`information and belief, they have worked in concert to establish distribution and sales channels in
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`the United States, including in the District of Delaware, for one or more of the Seagate-branded
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`products identified in this Complaint.
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`12.
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`This Court also has general personal jurisdiction over Defendant Seagate
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`Technology LLC because Defendant Seagate Technology LLC is a Delaware LLC, and thus
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`resides in this district.
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`13.
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`Venue is proper against Defendant Seagate Technology LLC in the District of
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`Delaware pursuant to 28 U.S.C. §§ 1391 and 1400(b) because Defendant Seagate Technology LLC
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`is a Delaware LLC, and thus resides in this district.
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`14.
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`Venue is proper against Defendants Seagate Technology (Netherlands) B.V. and
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`Singapore International Headquarters Pte. Ltd. pursuant to 28 U.S.C. § 1391(c)(3) because venue
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`is deemed proper in any district against a foreign corporation.
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`15.
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`The Defendants are properly joined because, on information and belief, they have
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`acted in concert with each other to develop, manufacture, import, market, promote, distribute, sell,
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`and/or offer for sale one or more Seagate-branded products identified in this Complaint in this
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`district and throughout the United States, such that the relief requested in this action arises out of
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`the same transaction, occurrence, or series of transactions and will require resolution of common
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`questions of law and/or fact.
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`BACKGROUND
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`16.
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`17.
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`Nidec realleges and incorporates each of preceding paragraphs 1–15.
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`Nidec was founded in 1973 and has recently been named as one of the most
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`innovative companies in the world.1 Nidec develops, manufactures, and sells a variety of products
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`used in commercial and industrial applications, machinery, electronic devices, and automotive
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`products, with annual revenues exceeding $14 billion. Nidec makes and sells all varieties of
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`electric motors and is the number one global producer of brushless DC motors.
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`18.
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`Hard disk drives, or HDDs, are data storage devices that store large amounts of data
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`either magnetically or optically on encoded disks. HDDs rely on a small precision motor called a
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`spindle motor that rotates these disks at thousands of revolutions per minute, allowing a read-write
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`1 https://www.forbes.com/companies/nidec/?sh=5c9cae85ed2b.
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`head to move over the disk and read or write data. HDDs are important components of data center
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`servers and PCs.
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`19.
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`Nidec is one of the major suppliers of HDD spindle motors in the world and
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`consistently provides leading edge innovation. In 1979, Nidec became the first company in the
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`world to successfully commercialize a direct drive spindle motor for HDDs using a brushless DC
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`motor. This innovation was one of the driving forces allowing computers to reduce in size. In the
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`1990s, Nidec pioneered the use of fluid dynamic bearings in spindle motors, leading to
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`dramatically improved performance in the spindle motor over prior spindle motors that relied on
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`ball bearings. Nidec was the first company to launch mass production of HDD spindle motors that
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`use fluid dynamic bearings in 1994. Today, Nidec remains the leading producer of HDD spindle
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`motors worldwide, with a global market share exceeding 80%.
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`20.
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`Nidec has continued to innovate in the area of HDD spindle motors. The U.S. Patent
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`and Trademark Office reviewed these technological advances and awarded Nidec numerous
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`patents, including but not limited to U.S. Patent No. 8,737,017 (“’017 patent”), U.S. Patent No.
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`9,742,239 (“’239 patent”), U.S. Patent No. 9,935,528 (“’528 patent”), U.S. Patent No. 10,407,775
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`(“’775 patent”), and U.S. Patent No. 10,460,767 (“’767 patent”), as described below.
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`21.
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`Defendants have knowledge of each of the ’017, ’239, ’528, ’775, and ’767 patents
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`at least as of the service of this Complaint.
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`NATURE OF THE ACTION
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`22.
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`23.
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`Nidec realleges and incorporates each of preceding paragraphs 1–21.
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`This is an action for patent infringement arising under the patent laws of the United
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`States, Title 35, United States Code, against Defendants for infringement of the ’017, ’239, ’528,
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`’775, and ’767 patents. This action relates to Seagate HDD products designed, manufactured,
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`imported, marketed, distributed, promoted, sold, and/or offered for sale by Defendants.
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`24.
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`On information and belief, and as discussed in greater detail below, Defendants
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`directly infringe one or more claims of the ’017 patent, including at least claim 1, by making,
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`using, selling, offering for sale, and/or importing Seagate HDD products (“’017 Accused
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`Products”). The ’017 Accused Products include but are not limited to Defendants’ BarraCuda
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`HDDs, including the Seagate 2TB BarraCuda ST2000LM015 with a spindle motor from
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`MinebeaMitsumi Inc., and all reasonably similar Seagate HDD products.
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`25.
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`On information and belief, and as discussed in greater detail below, Defendants
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`indirectly infringe the ’017 patent by inducing their customers to directly infringe one or more
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`claims of the ’017 patent, including at least claim 1. With knowledge (at least based on this
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`Complaint) that their customers directly infringe the ’017 patent when using the ’017 Accused
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`Products as intended, and by intentionally encouraging such use, Defendants are liable for induced
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`infringement under 35 U.S.C. § 271(b).
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`26.
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`On information and belief, and as discussed in greater detail below, Defendants
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`indirectly infringe the ’017 patent by contributing to the direct infringement of one or more claims
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`of the ’017 patent, including at least claim 1, by their customers. On information and belief,
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`Defendants know (at least based on this Complaint) that the ’017 Accused Products are especially
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`made or adapted for use by their customers in a manner that directly infringes the ’017 patent under
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`35 U.S.C. § 271(a). Because the ’017 Accused Products also are not staple articles of commerce
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`and are not suitable for substantial noninfringing uses, Defendants are liable for contributory
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`infringement under 35 U.S.C. § 271(c).
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`27.
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`On information and belief, and as discussed in greater detail below, Defendants
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`directly infringe one or more claims of the ’239 patent, including at least claim 1, by making,
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`using, selling, offering for sale, and/or importing Seagate HDD products (“’239 Accused
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`Products”). The ’239 Accused Products include but are not limited to Defendants’ IronWolf Pro
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`HDDs, including the Seagate 16TB IronWolf Pro ST16000NE000 with a spindle motor from
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`MinebeaMitsumi Inc., and all reasonably similar Seagate HDD products.
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`28.
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`On information and belief, and as discussed in greater detail below, Defendants
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`indirectly infringe the ’239 patent by inducing their customers to directly infringe one or more
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`claims of the ’239 patent, including at least claim 1. With knowledge (at least based on this
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`Complaint) that their customers directly infringe the ’239 patent when using the ’239 Accused
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`Products as intended, and by intentionally encouraging such use, Defendants are liable for induced
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`infringement under 35 U.S.C. § 271(b).
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`29.
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`On information and belief, and as discussed in greater detail below, Defendants
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`indirectly infringe the ’239 patent by contributing to the direct infringement of one or more claims
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`of the ’239 patent, including at least claim 1, by their customers. On information and belief,
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`Defendants know (at least based on this Complaint) that the ’239 Accused Products are especially
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`made or adapted for use by their customers in a manner that directly infringes the ’239 patent under
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`35 U.S.C. § 271(a). Because the ’239 Accused Products also are not staple articles of commerce
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`and are not suitable for substantial noninfringing uses, Defendants are liable for contributory
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`infringement under 35 U.S.C. § 271(c).
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`30.
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`On information and belief, and as discussed in greater detail below, Defendants
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`directly infringe one or more claims of the ’528 patent, including at least claim 1, by making,
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`using, selling, offering for sale, and/or importing Seagate HDD products (“’528 Accused
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`Products”). The ’528 Accused Products include but are not limited to Defendants’ IronWolf Pro
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`HDDs, including the Seagate 16TB IronWolf Pro ST16000NE000 with a spindle motor from
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`MinebeaMitsumi Inc., and all reasonably similar Seagate HDD products.
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`31.
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`On information and belief, and as discussed in greater detail below, Defendants
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`indirectly infringe the ’528 patent by inducing their customers to directly infringe one or more
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`claims of the ’528 patent, including at least claim 1. With knowledge (at least based on this
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`Complaint) that their customers directly infringe the ’528 patent when using the ’528 Accused
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`Products as intended, and by intentionally encouraging such use, Defendants are liable for induced
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`infringement under 35 U.S.C. § 271(b).
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`32.
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`On information and belief, and as discussed in greater detail below, Defendants
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`indirectly infringe the ’528 patent by contributing to the direct infringement of one or more claims
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`of the ’528 patent, including at least claim 1, by their customers. On information and belief,
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`Defendants know (at least based on this Complaint) that the ’528 Accused Products are especially
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`made or adapted for use by their customers in a manner that directly infringes the ’528 patent under
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`35 U.S.C. § 271(a). Because the ’528 Accused Products also are not staple articles of commerce
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`and are not suitable for substantial noninfringing uses, Defendants are liable for contributory
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`infringement under 35 U.S.C. § 271(c).
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`33.
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`On information and belief, and as discussed in greater detail below, Defendants
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`directly infringe one or more claims of the ’775 patent, including at least claim 9, by making,
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`using, selling, offering for sale, and/or importing Seagate HDD products (“’775 Accused
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`Products”). The ’775 Accused Products include but are not limited to Defendants’ IronWolf Pro
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`HDDs, including the Seagate 16TB IronWolf Pro ST16000NE000 with a spindle motor from
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`MinebeaMitsumi Inc., and all reasonably similar Seagate HDD products.
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`34.
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`On information and belief, and as discussed in greater detail below, Defendants
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`indirectly infringe the ’775 patent by inducing their customers to directly infringe one or more
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`claims of the ’775 patent, including at least claim 9. With knowledge (at least based on this
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`Complaint) that their customers directly infringe the ’775 patent when using the ’775 Accused
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`Products as intended, and by intentionally encouraging such use, Defendants are liable for induced
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`infringement under 35 U.S.C. § 271(b).
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`35.
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`On information and belief, and as discussed in greater detail below, Defendants
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`indirectly infringe the ’775 patent by contributing to the direct infringement of one or more claims
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`of the ’775 patent, including at least claim 9, by their customers. On information and belief,
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`Defendants know (at least based on this Complaint) that the ’775 Accused Products are especially
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`made or adapted for use by their customers in a manner that directly infringes the ’775 patent under
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`35 U.S.C. § 271(a). Because the ’775 Accused Products also are not staple articles of commerce
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`and are not suitable for substantial noninfringing uses, Defendants are liable for contributory
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`infringement under 35 U.S.C. § 271(c).
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`36.
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`On information and belief, and as discussed in greater detail below, Defendants
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`directly infringe one or more claims of the ’767 patent, including at least claim 1, by making,
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`using, selling, offering for sale, and/or importing Seagate HDD products (“’767 Accused
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`Products”). The ’767 Accused Products include but are not limited to Defendants’ IronWolf Pro
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`HDDs, including the Seagate 16TB IronWolf Pro ST16000NE000 with a spindle motor from
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`MinebeaMitsumi Inc., and all reasonably similar Seagate HDD products.
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`37.
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`On information and belief, and as discussed in greater detail below, Defendants
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`indirectly infringe the ’767 patent by inducing their customers to directly infringe one or more
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`claims of the ’767 patent, including at least claim 1. With knowledge (at least based on this
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`Complaint) that their customers directly infringe the ’767 patent when using the ’767 Accused
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`Products as intended, and by intentionally encouraging such use, Defendants are liable for induced
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`infringement under 35 U.S.C. § 271(b).
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`38.
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`On information and belief, and as discussed in greater detail below, Defendants
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`indirectly infringe the ’767 patent by contributing to the direct infringement of one or more claims
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`of the ’767 patent, including at least claim 1, by their customers. On information and belief,
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`Defendants know (at least based on this Complaint) that the ’767 Accused Products are especially
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`made or adapted for use by their customers in a manner that directly infringes the ’767 patent under
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`35 U.S.C. § 271(a). Because the ’767 Accused Products also are not staple articles of commerce
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`and are not suitable for substantial noninfringing uses, Defendants are liable for contributory
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`infringement under 35 U.S.C. § 271(c).
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`PATENTS IN SUIT
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`39.
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`Nidec realleges and incorporates each of preceding paragraphs 1–38.
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`The ’017 Patent
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`40.
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`On May 27, 2014, the U.S. Patent and Trademark Office duly and legally issued
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`the ’017 patent, titled “Spindle Motor and Disk Drive Apparatus.” A true and correct copy of the
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`’017 patent is attached as Exhibit A. The claims of the ’017 patent are valid and enforceable. The
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`entire right, title, and interest in the ’017 patent is assigned to and owned by Nidec.
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`41.
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`The ’017 patent is directed to a spindle motor for a disk drive apparatus. The
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`specification explains that there was a need to reduce the thickness of the spindle motor mounted
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`in a disk drive apparatus. The inventors recognized that reducing the thickness of the motor
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`mounted in the disk drive can cause disproportionate reductions in the torque constant Kt of torque
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`generated between the stator and the rotor magnet. A decrease in the torque constant Kt
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`corresponds to an increase in the time it takes for the motor to reach a rated speed for startup.
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`42.
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`The inventors invented, for example, a thin spindle motor for a disk drive apparatus
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`that, for example, generates sufficient torque and shortens the startup time. The thin spindle motor
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`is designed, for example, to increase the torque constant Kt and the motor constant Km in a desired
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`range. The motor constant Km is described as an optimal index that expresses a suitable motor
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`structure in a case where the motor is made thin.
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`The ’239 Patent
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`43.
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`On August 22, 2017, the U.S. Patent and Trademark Office duly and legally issued
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`the ’239 patent, titled “Spindle Motor and Disk Drive Apparatus.” A true and correct copy of the
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`’239 patent is attached as Exhibit B. The claims of the ’239 patent are valid and enforceable. The
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`entire right, title, and interest in the ’239 patent is assigned to and owned by Nidec.
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`44.
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`The ’239 patent is directed to a spindle motor for a disk drive with a metal base
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`portion comprising a base portion through hole and a lead wire that connects a coil in the spindle
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`motor and a circuit board. The specification explains that, previously, the lead wire from the coil
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`passed through the base portion through hole. The inventors recognized that, if the lead wire is
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`brought into contact with the edge of the base portion through hole, the insulation coating of the
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`lead wire may be damaged, and cause a hard disk drive malfunction. The inventors also recognized
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`that an interior space of a hard disk drive may be filed with a gas and any gap between the lead
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`wire and the base portion through hole may cause gas to enter or exit through the base portion
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`through hole. The inventors invented, for example, designs for a spindle motor that improve, for
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`example, the prevention of damage of an insulation coating of a lead wire and potential gas leak.
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`The ’528 Patent
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`45.
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`On April 3, 2018, the U.S. Patent and Trademark Office duly and legally issued the
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`’528 patent, titled “Spindle Motor and Disk Drive Apparatus.” A true and correct copy of the ’528
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`patent is attached as Exhibit C. The claims of the ’528 patent are valid and enforceable. The entire
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`right, title, and interest in the ’528 patent is assigned to and owned by Nidec.
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`46.
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`The ’528 patent is directed to a spindle motor for a disk drive with a base portion
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`comprising a base portion through hole and a lead wire that connects a coil in the spindle motor
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`and a circuit board. The specification explains that, previously, the lead wire from the coil passed
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`through the base portion through hole. The inventors recognized that, if the lead wire is brought
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`into contact with the edge of the base portion through hole, the insulation coating of the lead wire
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`may be damaged, and cause a hard disk drive malfunction. The inventors invented, for example,
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`designs for a spindle motor with an insulation sheet portion that improve, for example, the
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`prevention of damage of an insulation coating of a lead wire.
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`The ’775 Patent
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`47.
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`On September 10, 2019, the U.S. Patent and Trademark Office duly and legally
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`issued the ’775 patent, titled “Base Plate, Hard Disk Drive, and Method of Manufacturing Base
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`Plate.” A true and correct copy of the ’775 patent is attached as Exhibit D. The claims of the ’775
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`patent are valid and enforceable. The entire right, title, and interest in the ’775 patent is assigned
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`to and owned by Nidec.
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`48.
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`The ’775 patent states that a known technique to reduce windage loss in a disk drive
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`apparatus involves filling an interior space of a disk device with a gas having a density lower than
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`that of air, such as, for example, a helium gas. The ’775 patent provides, for example, a base plate,
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`a hard disk drive, and a method of manufacturing the base plate which are able to achieve an
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`{01653380;v1 }
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`Case 1:21-cv-00052-UNA Document 1 Filed 01/18/21 Page 15 of 59 PageID #: 15
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`
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`improvement in airtightness of an interior space of a housing using the base plate. It discloses a
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`base plate that is arranged to define a portion of a housing of a hard disk drive. The base plate
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`includes a base body defined by casting, an electrodeposition coating film, and an impregnant. The
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`electrodeposition coating film, which, for example, is arranged to cover a surface of the base body
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`with a relatively higher metal density, helps maintain the airtightness of the interior space of the
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`disk drive. The impregnant can be arranged to cover at least a portion of a worked surface with a
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`relatively lower metal density that is exposed from the electrodeposition coating film. Covering
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`the worked surface in the impregnant seals minute cavities in the worked surface, leading, for
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`example, to improved airtightness of the interior space of the disk drive.
`
`The ’767 Patent
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`49.
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`On October 29, 2019, the U.S. Patent and Trademark Office duly and legally issued
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`the ’767 patent, titled “Base Member Including Information Mark and Insulating Coating Layer,
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`and Disk Drive Apparatus Including the Same.” A true and correct copy of the ’767 patent is
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`attached as Exhibit E. The claims of the ’767 patent are valid and enforceable. The entire right,
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`title, and interest in the ’767 patent is assigned to and owned by Nidec.
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`50.
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`The ’767 patent is directed to a disk drive apparatus that includes a base member
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`comprising an information mark and an insulating coating layer. The specification explains that,
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`previously, the base member was manufactured by a die casting process and that there was a need
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`for an improvement to determine whether a casting process has a problem. The inventors invented,
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`for example, a new process to put an information mark on the base member to record various
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`information concerning the casting process used to produce the base member, which can be used
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`to achieve an improvement, for example, in the quality of the base member and an improved
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`product yield.
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`{01653380;v1 }
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`Case 1:21-cv-00052-UNA Document 1 Filed 01/18/21 Page 16 of 59 PageID #: 16
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`51.
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`52.
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`COUNT I FOR PATENT INFRINGEMENT
`(Infringement of the ’017 Patent)
`
`Nidec realleges and incorporates each of preceding paragraphs 1–50.
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`On information and belief, Defendants have made, used, sold, offered for sale,
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`and/or imported into the United States, and continue to do so, Seagate-branded hard drives
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`containing spindle motors, including the ’017 Accused Products like the Seagate 2TB BarraCuda
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`ST2000LM015, that practice at least one claim of the ’017 patent, including claim 1.
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`53.
`
`Claim 1 of the ’017 patent recites “[a] spindle motor of a disk drive apparatus.” The
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`Seagate 2TB BarraCuda ST2000LM015 is a disk drive apparatus that contains a spindle motor.
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`Seagate’s product specification shows that the spindle motor in the Seagate 2TB BarraCuda
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`ST2000LM015 rotates at 5,400 revolutions per minute. Ex. F (BarraCuda 2.5 HDD DATA
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`SHEET, available at https://www.seagate.com/www-content/datasheets/pdfs/barracuda-2-5-
`
`DS1907-3-2005US-en_US.pdf (last visited Jan. 15, 2021)).
`
`54.
`
`On
`
`information and belief,
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`the Seagate 2TB BarraCuda ST2000LM015
`
`incorporates a spindle motor from MinebeaMitsumi Inc.
`
`55.
`
`On information and belief, the cross section of the spindle motor incorporated into
`
`the Seagate 2TB BarraCuda ST2000LM015 is illustrated by the following image, which shows a
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`motor having the same general structure.
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`{01653380;v1 }
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`Case 1:21-cv-00052-UNA Document 1 Filed 01/18/21 Page 17 of 59 PageID #: 17
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`
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`Ex. G (MinebeaMitsumi, “FDB Motor,” available at https://www.minebeamitsumi.com/
`
`english/product/rotary/1197094_6224.html (last visited Jan. 15, 2021)).
`
`56.
`
`Claim 1 of the ’017 patent recites “a base unit.” On information and belief, the
`
`Seagate 2TB BarraCuda ST2000LM015 incorporates a spindle motor that includes a base unit.
`
`
`
`57.
`
`Claim 1 of the ’017 patent recites “a stator that includes a stator core and a plurality
`
`of coils mounted to the stator core and is disposed above the base unit.” On information and belief,
`
`the Seagate 2TB BarraCuda ST2000LM015 incorporates a spindle motor with a stator that includes
`
`a stator core and a plurality of coils mounted to the stator core. They are disposed above the base
`
`unit.
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`{01653380;v1 }
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`17
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`Case 1:21-cv-00052-UNA Document 1 Filed 01/18/21 Page 18 of 59 PageID #: 18
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`
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`58.
`
`Claim 1 of the ’017 patent recites “a covered cylindrical rotor hub that includes a
`
`cover portion positioned above the stator and a side wall portion extending downward from an
`
`outer edge of the cover portion.” On information and belief, the Seagate 2TB BarraCuda
`
`ST2000LM015 incorporates a spindle motor that includes a covered cylindrical rotor hub. The
`
`covered cylindrical rotor hub has a cover portion above the stator and a side wall portion extending
`
`downward from an outer edge of the cover portion.
`
`59.
`
`Claim 1 of the ’017 patent recites “a rotor magnet that is positioned outside the
`
`stator in a radial direction thereof and is fixed to an inner circumferential surface of the side wall
`
`portion of the rotor hub.” On information and belief, the Seagate 2TB BarraCuda ST2000LM015
`
`incorporates a spindle motor that has a rotor magnet positioned outside the stator in a radial
`
`
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`{01653380;v1 }
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`18
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`Case 1:21-cv-00052-UNA Document 1 Filed 01/18/21 Page 19 of 59 PageID #: 19
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`
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`direction thereof. The rotor magnet is fixed to an inner circumferential surface of the side wall
`
`portion of the rotor hub.
`
`
`
`60.
`
`Claim 1 of the ’017 patent recites “a bearing mechanism that supports the rotor hub
`
`and the rotor magnet to be rotatable with respect to the base unit and the stator.” On information
`
`and belief, the Seagate 2TB BarraCuda ST2000LM015 incorporates a spindle motor that has a
`
`bearing mechanism that supports the rotor hub and the rotor magnet to be rotatable with respect to
`
`the base unit and the stator.
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`{01653380;v1 }
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`Case 1:21-cv-00052-UNA Document 1 Filed 01/18/21 Page 20 of 59 PageID #: 20
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`
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`61.
`
` Claim 1 of the ’017 patent recites “a height of the stator core in an axial direction
`
`is about 50% or more and about 70% or less than a height of the stator.” On information and belief,
`
`the Seagate 2TB BarraCuda ST2000LM015 incorporates a spindle motor where a height of the
`
`stator core in an axial direction is about 63% than a height of the stator.
`
`62.
`
`Claim 1 of the ’017 patent recites “a torque constant Kt of torque generated between
`
`the stator and the rotor magnet is about 4 mNꞏm/A or more and about 6 mNꞏm/A or less.” On
`
`information and belief, the Seagate 2TB BarraCuda ST2000LM015 incorporates a spindle motor
`
`that includes a torque constant Kt of about 5.4 mNꞏm/A.
`
`63.
`
`Claim 1 of the ’017 patent recites “a motor constant Km is about 2 mNꞏm/(Aꞏ√Ω)
`
`or more and about 4 mNꞏm/(Aꞏ√Ω) or less.” On information and belief, the Seagate 2TB
`
`BarraCuda ST2000LM015 incorporates a spindle motor that includes a motor constant Km of
`
`about 2.8 mNꞏm/(Aꞏ√Ω).
`
`64.
`
`In violation of 35 U.S.C. § 271(a), Defendants have infringed, and will continue to
`