Case 2:22-cv-00134-JRG-RSP Document 1 Filed 05/05/22 Page 1 of 58 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`ADVANCED MICRO DEVICES, INC.; and
`ATI TECHNOLOGIES ULC
`
`
`
`
`
`TCL INDUSTRIES HOLDINGS CO., LTD.;
`TCL INDUSTRIES HOLDINGS (H.K.)
`LIMITED;
`TCL ELECTRONICS HOLDINGS LIMITED;
`TCL TECHNOLOGY GROUP
`CORPORATION;
`TTE CORPORATION;
`TCL HOLDINGS (BVI) LIMITED;
`TCL KING ELECTRICAL APPLIANCES
`(HUIZHOU) CO. LTD.;
`SHENZHEN TCL NEW TECHNOLOGIES
`CO., LTD.;
`TCL MOKA INTERNATIONAL LIMITED;
`TCL SMART DEVICE (VIETNAM) CO.,
`LTD;
`MANUFACTURAS AVANZADAS SA DE
`CV;
`TCL ELECTRONICS MEXICO, S DE RL DE
`CV;
`TCL OVERSEAS MARKETING LTD.; and
`REALTEK SEMICONDUCTOR CORP.
`
`
`
`
`
`
`
`
`Plaintiffs,
`
`
`
`v.
`
`
`
`Defendants.
`
`C.A. No.: 2:22-cv-00134
`
`JURY TRIAL DEMANDED
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiffs Advanced Micro Devices, Inc. and ATI Technologies ULC (collectively,
`
`“AMD” or “Plaintiffs”), bring this action for patent infringement under 35 U.S.C. § 271 against
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`Defendants TCL Industries Holdings Co. Ltd., TCL Industries Holdings (H.K.) Limited, TCL
`
`Electronics Holdings Limited, TCL Technology Group Corporation, TTE Corporation, TCL
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`Case 2:22-cv-00134-JRG-RSP Document 1 Filed 05/05/22 Page 2 of 58 PageID #: 2
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`Holdings (BVI) Limited, TCL King Electrical Appliances (Huizhou) Co. Ltd., Shenzhen TCL
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`New Technologies Co., Ltd., TCL MOKA International Limited, and TCL Smart Device
`
`(Vietnam) Co., Ltd, Manufacturas Avanzadas SA de CV, TCL Electronics Mexico, S de RL de
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`CV, and TCL Overseas Marketing Ltd. (together, “TCL”), and against Defendant Realtek
`
`Semiconductor Corp. (“Realtek”) (TCL and Realtek together, “Defendants”). Plaintiffs allege as
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`follows:
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`Plaintiffs’ Patented Technology
`
`1.
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`Plaintiff Advanced Micro Devices, Inc. is a corporation organized and existing
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`under the laws of the State of Delaware, and maintains its principal place of business at 2485
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`Augustine Drive, Santa Clara, California 95054. Plaintiff ATI Technologies ULC is incorporated
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`in Canada and has a principal place of business at 1 Commerce Valley Drive East, Markham,
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`Ontario L3T 7X6, Canada. Plaintiff ATI Technologies ULC is a wholly-owned indirect subsidiary
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`of Plaintiff Advanced Micro Devices, Inc.
`
`2.
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`Advanced Micro Devices, Inc. was founded in 1969 as a Silicon Valley start-up,
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`with a few dozen employees focused on leading-edge semiconductor products. ATI Technologies
`
`ULC began as a semiconductor technology corporation based in Markham, Ontario and with
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`locations in Silicon Valley, specializing in the development of graphics processing units and
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`chipsets. Since at least as early as 1985, ATI Technologies ULC has made substantial investments
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`to research, develop, and have manufactured high quality graphics systems. On July 24, 2006,
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`Advanced Micro Devices, Inc. and ATI Technologies ULC jointly announced that Advanced
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`Micro Devices, Inc. would acquire ATI Technologies ULC in a deal valued at $5.4 billion.
`
`3.
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`From those modest beginnings, AMD has grown into a global company, achieving
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`many important industry firsts, and today develops high-performance computing products to
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`address some of the world’s toughest challenges. As of December 25, 2021, AMD has
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`Case 2:22-cv-00134-JRG-RSP Document 1 Filed 05/05/22 Page 3 of 58 PageID #: 3
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`approximately 15,500 employees across the globe, as reported in AMD’s annual report in February
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`2022.
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`4.
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`The Asserted Patents stem from the research and design of innovative proprietary
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`technology developed by AMD. AMD has continued to make substantial investments to research,
`
`develop, and have manufactured high quality graphics systems that practice the Asserted Patents.
`
`AMD has invested substantial resources collectively researching, developing, testing, launching,
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`supporting, and maintaining groundbreaking graphics technology that practices the Asserted
`
`Patents.
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`5.
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`The Asserted Patents cover inventions relating to important aspects of AMD’s
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`graphics processing units (“GPUs”), central processing units (“CPUs”), and accelerated processing
`
`units (“APUs”).
`
`6.
`
`One of the patents asserted in this action (U.S. Patent No. 7,742,053) has been
`
`upheld as valid by the U.S. Court of Appeals for the Federal Circuit. ATI Techs. ULC v. Iancu,
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`920 F.3d 1362, 1364-65 (Fed. Cir. 2019). According to the Federal Circuit’s background
`
`description:
`
`The prior art describes that computer-graphics images are drawn on
`a screen by filling in a grid of dots called ‘pixels.’ Shapes are
`represented by a collection of simple polygons such as triangles or
`squares, called ‘primitives,’ formed by the interconnection of pixels.
`The corner of each primitive is called a ‘vertex,’ with each vertex
`defined by the spatial coordinates: x, y, and z. Color and texture are
`applied to the individual pixels that comprise the shape, based on
`the location of the pixels within the primitive and the primitive’s
`orientation relative to the generated shape. Id. To orient the
`wireframe three-dimensional model, matrix transformations applied
`to vertices Vx, Vy, and Vz of the primitives generate new vertices
`Vx’, Vy’, and Vz’, which are then translated into pixels. The
`graphics processor interconnects the primitives and applies color
`and texture to the generated shapes. The following illustration
`shows an example set of graphics displaying a three-dimensional
`object as a two-dimensional image:
`
`
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`
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`
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`Prior art processors required separate shaders to specify how and
`with what attributes a final image is drawn, in transforming
`primitives by adjusting the x, y, and z coordinates of their vertices.
`Prior art graphics processors required both a vertex shader and a
`pixel shader, because vertex operations and pixel operations have
`different processing requirements and were required to be
`performed separately and sequentially by separate shader systems.
`
`
`Id. (citing inter alia, U.S. Patent No. 6,897,871 at 1:11-60).
`
`
`7.
`
`The ’053 Patent asserted in this action, as well as others, as described more
`
`specifically below, claim novel systems that perform unified shading.
`
`The TCL Defendants and Their Product Offerings
`
`8.
`
`The TCL Defendants in this action (collectively referred to as “TCL”) are foreign-
`
`based corporations who, along with their own subsidiaries and associates, operate as agents of one
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`another, and work in concert together as a business group to make, use, offer to sell, or sell any
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`patented invention, within the United States or import into the United States infringing products,
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`including digital TVs, in the United States, including in Texas and this judicial district.
`
`9.
`
`For example, in TCL’s Annual Report 2020, TCL first defines “TCL Holdings” as
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`“TCL Industries Holdings Co. Ltd.,” which is a “joint stock limited company established under
`
`the laws of the PRC, the ultimate controlling shareholder of the Company” and “TCL Holdings
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`Group” as “TCL Holdings and its subsidiaries.” TCL Annual Report 2020 at 315 (emphasis added)
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`Case 2:22-cv-00134-JRG-RSP Document 1 Filed 05/05/22 Page 5 of 58 PageID #: 5
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`(https://doc.irasia.com/listco/hk/tclelectronics/annual/2020/ar2020.pdf) (accessed Mar. 8, 2022).
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`Second, TCL defines “T.C.L. Industries (H.K.)” as “T.C.L. Industries Holdings (H.K.)
`
`Limited,” which is “a company incorporated in Hong Kong with limited liability, the immediate
`
`controlling shareholder of the Company and a wholly-owned subsidiary of TCL Holdings.” Id.
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`Third, TCL defines the “Company” as “TCL Electronics Holdings Limited, a company
`
`incorporated in the Cayman Islands with limited liability[,]” and the “Group” as “the Company
`
`and its subsidiaries.” And fourth, TCL defines “TCL Technology” as “TCL Technology Group
`
`Corporation[,] formerly known as TCL Corporation[,] a joint stock limited company established
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`under the laws of the PRC” and defines “TCL Technology Group” as “TCL Technology and its
`
`subsidiaries.” Id. at 316. As explained by TCL “the ultimate holding company of the Company
`
`[i.e, TCL Electronics Holdings Limited] has changed to TCL Holdings [i.e, TCL Electronics
`
`Holdings Limited] following the completion of [a] restructuring” relating to TCL Technology
`
`Group Corporation. Id. at 139. However, as TCL also explains, because “the major shareholders
`
`of TCL Holdings are the key management of TCL Technology [i.e., TCL Technology Group
`
`Corporation], TCL Technology [Group Corporation] remained a related party of the Group [i.e.,
`
`the Company (TCL Electronics Holdings Limited) and its subsidiaries].” Id.
`
`10.
`
`TCL describes its various corporate relatives as operating together in “synergies”
`
`in order to establish an “eco-system enterprise based on smart TVs”:
`
`[T]he Company [i.e., TCL Electronics Holdings Limited]
`maintains good relationships with its suppliers[.] Further, the Group
`[i.e., TCL Electronics Holdings Limited and its subsidiaries] has
`been pursuing and will continue to pursue synergies with multiple
`industries of TCL Holdings Group [i.e., TCL Industries Holdings
`Co. Ltd. and its subsidiaries] and TCL Technology Group [i.e.,
`TCL Technology Group Corporation and its subsidiaries] and
`leverage the advantages from the long-term relationship with CSOT
`(which is a major panel supplier in the PRC) from integrated
`industrial chain in order to become a forerunner in capitalising [sic]
`
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`Case 2:22-cv-00134-JRG-RSP Document 1 Filed 05/05/22 Page 6 of 58 PageID #: 6
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`opportunities arising from the revolution of the industry and to
`establish an eco-system enterprise based on smart TVs.
`
`Id. at 94 (emphases added). Also, TCL’s executives overlap across TCL’s various entities,
`
`including in its Company’s “Strategy Committee.” Id. at 315. For example, Mr. Li Dongsheng is
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`“an executive Director and the chairman of the [Company’s] Strategy Committee[, . . .] is the
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`founder of the Company and has served the Group since 1999[, and he] is currently the chairman
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`and chief executive officer of TCL Technology (000100.SZ), a director of T.C.L. Industries
`
`(H.K.), TCL Holdings and certain subsidiary(ies) of the Company.” Id. at 38. Also, Mr. Wang
`
`Chen is “an executive Director, CEO and a member of the Strategy Committee[, and he] is also: .
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`. . the chief executive officer of TCL Holdings[.]” Id. at 39. Also, Mr. Hu Dien Chien is “the chief
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`financial officer of the Company, a member of the Remuneration Committee and the Nomination
`
`Committee[, and he] “became an executive Director with effect from December 2020[, and] is also
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`the chief financial officer of TCL Holdings.” Id. at 41.
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`11.
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`TCL has extensive contacts with the United States market including with Texas and
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`this district. For example, on page 2 of its own press release on 2021 annual results
`
`(https://doc.irasia.com/listco/hk/tclelectronics/annual/2021/respress.pdf)
`
`(accessed Mar. 16,
`
`2022), TCL states that:
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`[In 2021,] the market share of TCL smart screen by sales volume
`ranked No. 2 in the U.S. . . .
`
`[T]he sales revenue of TCL smart screen in the North American
`markets increased by 24.8% year-on-year [in 2021].
`
`Id. at 2 (emphases added). Further, according to TCL’s most recent annual report, TCL’s goal is
`
`to
`
`
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`constantly improve the brand power and competitiveness of the
`[TCL] Group in domestic and overseas TV markets in order to step
`towards the target of becoming No. 1 brand in the global TV
`market.
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`Case 2:22-cv-00134-JRG-RSP Document 1 Filed 05/05/22 Page 7 of 58 PageID #: 7
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` TCL
`
`Annual
`
`Report
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`2020
`
`at
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`25
`
`(emphasis
`
`added)
`
`(https://doc.irasia.com/listco/hk/tclelectronics/annual/2020/ar2020.pdf) (accessed Mar. 16, 2022).
`
`12.
`
`According to TCL, the TCL “Group” is organized into “business units based on
`
`their geographical TV segments” and other product types and has “four reportable operating
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`segments” as follows:
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`
`
`
`
`
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`(a) TV segment – manufacture and sale of TV sets in:
`– TCL TV – the PRC market; and
`– TCL TV – the overseas markets;
`
`(b) Internet business segment – advertising, value-added, video-on-
`demand and membership cards;
`
`(c) Smart mobile, connective devices and service segment –
`manufacture and sale of mobile phones, smart connective
`products and display and service; and
`
`(d) Smart commercial display, smart home and other businesses
`segment.
`
`Id. at 192. In the year 2020 alone, TCL sold $1.9 billion in the “TV and other products” segment
`
`in the North American market, an increase from $1.4 billion in 2019. Id. at 194–95. Further, in
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`the first half of 2021 alone, TCL sold $1.32 billion in the “smart screen and other products”
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`segment
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`in
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`the North American market.
`
` See TCL 2021 Interim Results at 16
`
`(https://doc.irasia.com/listco/hk/tclelectronics/interim/2021/intrep.pdf) (accessed Mar. 16, 2022).
`
`13.
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`TCL Industries Holdings Co. Ltd. is a Chinese corporation with a principal place
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`of business at 22nd Floor, TCL Technical Tower, Huifeng Third Road, Zhongkai Development
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`Zone, Huizhou, Guangdong, P.R. China 516006. On information and belief, TCL Industries
`
`Holdings Co. Ltd. is the ultimate controlling shareholder of Defendant TCL Electronics Holdings
`
`Limited, and an ultimate parent corporation of the other TCL Defendants named in this action. In
`
`addition, TCL Industries Holdings Co. Ltd. has represented in legal filings that it is one of several
`
`TCL entities who “is a manufacturer and seller of consumer electronics, including . . .
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`televisions[.]” Complaint at ¶ 2, TCL Indus. Holdings Co., Ltd. et al v. Bell Northern Rsch., LLC,
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`Case No. 3:21-cv-01598 (S.D. Cal. Sept. 13, 2021) (“TCL Complaint”).
`
`14.
`
`Upon information and belief, TCL Industries Holdings Co. Ltd., either itself or
`
`through its affiliates and corporate relatives, is engaged in the designing, manufacturing, research,
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`development, testing, marketing, distribution, shipping, importation, and selling of televisions,
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`smart devices, and graphics devices that are manufactured outside of the United States. Also, upon
`
`information and belief, TCL Industries Holdings Co. Ltd. is engaged in contributing to (and/or
`
`instructing others, including customers in the United States, regarding) the use, manufacture, sale,
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`and/or importation, of televisions, smart devices, and graphics devices in a directly infringing
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`manner.
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`15.
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`TCL Industries Holdings (H.K.) Limited is a Hong Kong corporation with a
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`principal place of business at 8th Floor, Building 22E, Phase Three, Hong Kong Science Park, Pak
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`Shek Kok, New Territories, Hong Kong. On information and belief, TCL Industries Holdings
`
`(H.K.) Limited is a wholly-owned subsidiary of Respondent TCL Industries Holdings Co., Ltd.
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`According to TCL Annual Report 2020, TCL Industries Holdings (H.K.) Limited is the immediate
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`controlling shareholder of “the Company,” i.e., Respondent TCL Electronics Holdings Ltd. Id.
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`According to S&P Capital IQ, TCL Industries Holdings (H.K.) Limited “offers products such as
`
`television[s].” See, e.g., S&P Capital IQ Company Report for TCL Industries Holdings (H.K.)
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`Limited (Oct. 7, 2021). In addition, TCL Industries Holdings (H.K.) Limited has represented in
`
`legal filings that it is one of several TCL entities who “is a manufacturer and seller of consumer
`
`electronics, including . . . televisions[.]” TCL Complaint at ¶ 2.
`
`16.
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`Upon information and belief, TCL Industries Holdings (H.K.) Limited, either itself
`
`and/or through the activities of its affiliates and corporate relatives, is in the business of designing,
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`manufacturing, using, importing, offering to sell, and/or selling, televisions, smart devices, and
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`graphics devices that are manufactured outside of the United States. Also, upon information and
`
`belief, TCL Industries Holdings (H.K.) Limited is engaged in contributing to (and/or instructing
`
`others, including customers in the United States, regarding) the use, manufacture, sale, offer for
`
`sale, and/or importation, of televisions, smart devices, and graphics devices in a directly infringing
`
`manner.
`
`17.
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`TCL Electronics Holdings Limited is a Cayman Islands corporation with a
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`principal place of business at 7/F, Building 22E, 22 Science Park East Avenue, Hong Kong Science
`
`Park, Sha Tin, New Territories, Hong Kong. On information and belief, TCL Electronics Holdings
`
`Limited is (i) a subsidiary of Defendant TCL Industries Holdings Co. Ltd., and (ii) a direct or
`
`indirect parent of Defendants TCL Holdings (BVI) Limited, TCL King Electrical Appliances
`
`(Huizhou) Co. Ltd., Shenzhen TCL New Technologies Co., Ltd., TCL MOKA International
`
`Limited, and TCL Smart Device (Vietnam) Co., Ltd. According to Bloomberg’s Company Profile,
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`“TCL Electronics Holdings Limited manufactures televisions and display products” in addition to
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`“produc[ing] and sell[ing] television sets, audio visual products, company monitors, and other
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`products.” (emphasis added) (https://www.bloomberg.com/profile/company/1070:HK) (accessed
`
`Mar. 8, 2022). In addition, TCL Electronics Holdings Limited has represented in legal filings that
`
`it is one of several TCL entities who “is a manufacturer and seller of consumer electronics,
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`including . . . televisions[.]” TCL Complaint at ¶ 2.
`
`18.
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`Upon information and belief, TCL Electronics Holdings Limited, either itself or
`
`through its affiliates and corporate relatives, is engaged in the manufacturing, research,
`
`development, testing, marketing, distribution, shipping, importation, and selling of televisions,
`
`smart devices, and graphics devices that are manufactured outside of the United States. Also, upon
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`information and belief, TCL Electronics Holdings Limited is engaged in contributing to (and/or
`
`instructing others, including customers in the United States, regarding) the use, manufacture, sale,
`
`offer for sale, and/or importation, of televisions, smart devices, and graphics devices in a directly
`
`infringing manner.
`
`19.
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`TCL Technology Group Corporation is a Chinese corporation with a principal
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`place of business at TCL Technology Building, No. 17, Huifeng Third Road, Zhongkai High-tech
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`Zone, Huizhou, Guangdong, P.R. China 516006. On information and belief, TCL Technology
`
`Group Corporation is (i) a subsidiary of Defendant TCL Electronics Holdings Limited, and (ii) a
`
`direct or indirect parent corporation of the other TCL Defendants named in this action. According
`
`to Bloomberg’s Company Profile, TCL Technology Group Corporation “operates as a
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`semiconductor display manufacturer[,]” “researches, develops, manufactures, and distributes
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`flexible printing display organic light emitting diode, active matrix organic light emitting diode,
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`thin film transistor liquid crystal display, and other products[,]” and “conducts businesses
`
`globally.” (https://www.bloomberg.com/profile/company/000100:CH) (accessed Mar. 8, 2022).
`
`In addition, TCL Technology Group Corporation has represented in legal filings that it is one of
`
`several TCL entities who “is a manufacturer and seller of consumer electronics, including . . .
`
`televisions[.]” TCL Complaint at ¶ 2.
`
`20.
`
`Upon information and belief, TCL Technology Group Corporation, either itself or
`
`through its affiliates and corporate relatives, is engaged in the manufacturing, research,
`
`development, testing, marketing, distribution, shipping, importation, and selling of televisions,
`
`smart devices, and graphics devices that are manufactured outside of the United States. Also, upon
`
`information and belief, TCL Technology Group Corporation is engaged in contributing to (and/or
`
`instructing others, including customers in the United States, regarding) the use, manufacture, sale,
`
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`offer for sale, and/or importation, of televisions, smart devices, and graphics products in a directly
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`infringing manner.
`
`21.
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`TTE Corporation is a British Virgin Islands corporation with a principal place of
`
`business at 7/F, Building 22E, 22 Science Park East Avenue, Hong Kong Science Park, Sha Tin,
`
`New Territories, Hong Kong. On information and belief, TTE Corporation is a direct or indirect
`
`subsidiary of Respondent TCL Electronics Holdings Ltd. See, e.g., Certificate of Interest at 4, In
`
`re TCL Electronics Holdings Ltd., Case No. 20-129 (Fed. Cir. May 26, 2020). According to S&P
`
`Capital IQ, TTE Corporation manufactures and markets colored television sets in Europe, North
`
`America, and China]. See, e.g., S&P Capital IQ Company Report for TTE Corporation (Oct. 7,
`
`2021). Also, according to Zoominfo, “TTE Corporation is the world’s largest TV company in
`
`volume.” (emphasis added) (https://www.zoominfo.com/c/tte-corporation/147603476) (accessed
`
`Mar. 8, 2022). In addition, TTE Corporation has represented in legal filings that it is one of several
`
`TCL entities who “is a manufacturer and seller of consumer electronics, including . . .
`
`televisions[.]” TCL Complaint at ¶ 2.
`
`22.
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`TTE Corporation, either itself and/or through the activities of its affiliates and
`
`corporate relatives, is in the business of designing, manufacturing, importing, offering for sale,
`
`and/or selling, televisions, smart devices, and graphics devices that are manufactured outside of
`
`the United States. Also, upon information and belief, TTE Corporation is engaged in contributing
`
`to (and/or instructing others, including customers in the United States, regarding) the use,
`
`manufacture, sale, offer for sale, and/or importation, of televisions, smart devices, and graphics
`
`devices in a directly infringing manner.
`
`23.
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`TCL Holdings (BVI) Limited is a British Virgin Islands corporation with a
`
`principal place of business at 5/F, Building 22E, 22 Science Park East Avenue, Hong Kong Science
`
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`Park, Sha Tin, New Territories, Hong Kong. On information and belief, TCL Holdings (BVI)
`
`Limited is a direct or indirect subsidiary of Defendant TCL Electronics Holdings Limited, which
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`is engaged “mainly engaged in the R&D, production and sales of large-screen display terminals”
`
`including TVs. See, e.g., Decl. of Jin Yang Ex. A at 9, 35, 93, Canon, Inc. v. TCL Electronics
`
`Holdings Ltd., No. 2:18-cv-546 (E.D. Tex. Aug. 12, 2019). According to World Box’s company
`
`profile, TCL Holdings (BVI) Limited is also subsidiary of Defendant TCL Industries Holdings
`
`Co., Limited, and a parent of Defendant TCL King Electrical Appliances (Huizhou) Company
`
`Limited. World Box (https://worldbox.net/company/tcl-holdings-bvi-limited_VG0000026731)
`
`(accessed Mar. 8, 2022). In addition, TCL Holding (BVI) Limited has represented in legal filings
`
`that it is one of several TCL entities who “is a manufacturer and seller of consumer electronics,
`
`including . . . televisions[.]” TCL Complaint at ¶ 2.
`
`24.
`
`Upon information and belief, TCL Holdings (BVI) Limited, either itself or through
`
`its affiliates and corporate relatives, is engaged in the manufacturing, research, development,
`
`testing, marketing, distribution, shipping, importation, and selling of televisions, smart devices,
`
`and graphics devices that are manufactured outside of the United States. Also, upon information
`
`and belief, TCL Holdings (BVI) Limited is engaged in contributing to (and/or instructing others,
`
`including customers in the United States, regarding) the use, manufacture, sale, offer for sale,
`
`and/or importation, of televisions, smart devices, and graphics devices in a directly infringing
`
`manner.
`
`25.
`
`TCL King Electrical Appliances (Huizhou) Co. Ltd. is a Chinese corporation
`
`with its principal place of business located at No. 78, Huifeng Fourth Road, Zhongkai
`
`Development Zone, Huizhou, Guangdong, P.R. China 516006. On information and belief, TCL
`
`King Electrical Appliances (Huizhou) Co. Ltd. is (i) a subsidiary of Defendant TCL Holdings
`
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`(BVI) Limited, and (ii) a direct or indirect parent of Defendants Shenzhen TCL New Technologies
`
`Co., Ltd., TCL MOKA International Limited, and TCL Smart Device (Vietnam) Co., Ltd.
`
`According to Bloomberg’s Company Profile, TCL King Electrical Appliances (Huizhou) Co. Ltd.
`
`“develops, produces and sells color televisions, liquid crystal display and plasma display panel[s]”
`
`and “markets their products throughout the world.” (https://www.bloomberg.com/profile/
`
`company/HIALRZ:CH) (accessed Mar. 8, 2022). In addition, TCL King Electrical Appliances
`
`(Huizhou) Co. Ltd. has represented in legal filings that it is one of several TCL entities who “is a
`
`manufacturer and seller of consumer electronics, including . . . televisions[.]” TCL Complaint at
`
`¶ 2.
`
`26.
`
`Upon information and belief, TCL King Electrical Appliances (Huizhou) Co. Ltd.,
`
`either itself or through its affiliates and corporate relatives, is engaged in the manufacturing,
`
`research, development, testing, marketing, distribution, shipping, importation, and selling of
`
`televisions, smart devices, and graphics devices that are manufactured outside of the United States.
`
`Also, upon information and belief, TCL King Electrical Appliances (Huizhou) Co. Ltd. is engaged
`
`in contributing to (and/or instructing others, including customers in the United States, regarding)
`
`the use, manufacture, sale, offer for sale, and/or importation, of televisions, smart devices, and
`
`graphics products in a directly infringing manner.
`
`27.
`
`Shenzhen TCL New Technologies Co., Ltd. is a Chinese corporation with a
`
`principal place of business at 9th Floor, TCL Electronics Holdings Limited Building, TCL
`
`International E City, No. 1001, Zhongshan Park Road, Nanshan District, Shenzhen, Guangdong,
`
`P.R. China 518067. On information and belief, Shenzhen TCL New Technologies Co., Ltd. is a
`
`direct or indirect subsidiary of TCL King Electrical Appliances (Huizhou) Co. Ltd. According to
`
`Crunchbase’s Company Profile, Shenzhen TCL New Technologies Co., Ltd. is described as
`
`
`
`- 13 -
`
`

`

`Case 2:22-cv-00134-JRG-RSP Document 1 Filed 05/05/22 Page 14 of 58 PageID #: 14
`
`“manufacturing . . . radio and television broadcasting and communications equipment.”
`
`(https://www.crunchbase.com/organization/shenzhen-tcl-new-technology)
`
`(accessed Mar. 8,
`
`2022). In addition, Shenzhen TCL New Technologies Co., Ltd. has represented in legal filings
`
`that it is one of several TCL entities who “is a manufacturer and seller of consumer electronics,
`
`including . . . televisions[.]” TCL Complaint at ¶ 2.
`
`28.
`
`Upon information and belief, Shenzhen TCL New Technologies Co., Ltd., either
`
`itself or through its affiliates and corporate relatives, is engaged in the manufacturing, research,
`
`development, testing, marketing, distribution, shipping, importation, and selling of televisions,
`
`smart devices, and graphics devices that are manufactured outside of the United States. Also, upon
`
`information and belief, Shenzhen TCL New Technologies Co., Ltd. is engaged in contributing to
`
`(and/or instructing others, including customers in the United States, regarding) the use,
`
`manufacture, sale, offer for sale, and/or importation, of televisions, smart devices, and graphics
`
`devices in a directly infringing manner.
`
`29.
`
`TCL MOKA International Limited is a Hong Kong corporation with a principal
`
`place of business at 7/F Hong Kong Science Park, Building 22 E, 22 Science Park East Avenue,
`
`Sha Tin, New Territories, Hong Kong. On information and belief, TCL MOKA International
`
`Limited is a direct or indirect subsidiary of TCL Electronics Holdings Ltd. According to Panjiva,
`
`TCL MOKA International Limited’s “[t]op products” include “led television[s]” and, for example,
`
`it imported a “SMART TV 8528729600” on August 7, 2021. (https://panjiva.com/Tcl-Moka-
`
`International-Ltd/26640824) (accessed Mar. 8, 2022).
`
`30.
`
`Upon information and belief, TCL MOKA International Limited, either itself or
`
`through its affiliates and corporate relatives, is engaged in the manufacturing, research,
`
`development, testing, marketing, distribution, shipping, importation, and selling of televisions,
`
`
`
`- 14 -
`
`

`

`Case 2:22-cv-00134-JRG-RSP Document 1 Filed 05/05/22 Page 15 of 58 PageID #: 15
`
`smart devices, and graphics devices that are manufactured outside of the United States. Also, upon
`
`information and belief, TCL MOKA International Limited is engaged in contributing to (and/or
`
`instructing others, including customers in the United States, regarding) the use, manufacture, sale,
`
`offer for sale, and/or importation, of televisions, smart devices, and graphics devices in a directly
`
`infringing manner.
`
`31.
`
`TCL Smart Device (Vietnam) Co., Ltd. is a Vietnam corporation with its
`
`principal place of business at No. 26 VSIP II-A, Street 32, Vietnam Singapore Industrial Park II-
`
`A, Tan Binh Commune, Bac Tan Uyen District, Binh Duong Province, Vietnam 75000. On
`
`information and belief, TCL Smart Device (Vietnam) Co., Ltd. is a direct or indirect subsidiary of
`
`Defendant TCL Electronics Holdings Ltd. According to Panjiva, TCL Smart Device (Vietnam)
`
`Co., Ltd., whose “[t]op products” include “led television[s],” regularly imports led televisions to
`
`the United States,
`
`including “50" LED TV MODEL 50S431” on July 24, 2021.
`
`(https://panjiva.com/Tcl-Smart-Device-Vietnam-Co/71214654)
`
`(accessed Mar. 8, 2022).
`
`Furthermore, according to TCL’s website, TCL Smart Device (Vietnam) Co., Ltd. “will supply
`
`products to both the Vietnam market and other overseas markets, including . . . the U.S. . . . , to
`
`meet
`
`the
`
`growing
`
`demand
`
`for
`
`superior
`
`quality
`
`TVs.”
`
`(https://www.tcl.com/au/en/blogs/constructions-starts-on-new-tcl-integrated-manufacturing-
`
`base-in-vietnam.html) (accessed Mar. 8, 2022). In addition, TCL Smart Device (Vietnam) Co.,
`
`Ltd. has represented in legal filings that it is one of several TCL entities who “is a manufacturer
`
`and seller of consumer electronics, including . . . televisions[.]” TCL Complaint at ¶ 2.
`
`32.
`
`Upon information and belief, TCL Smart Device (Vietnam) Co., Ltd., either itself
`
`or through its affiliates and corporate relatives, is engaged in the manufacturing, research,
`
`development, testing, marketing, distribution, shipping, importation, and selling of televisions,
`
`
`
`- 15 -
`
`

`

`Case 2:22-cv-00134-JRG-RSP Document 1 Filed 05/05/22 Page 16 of 58 PageID #: 16
`
`smart devices, and graphics devices that are manufactured outside of the United States. Also, upon
`
`information and belief, TCL Smart Device (Vietnam) Co., Ltd. is engaged in contributing to
`
`(and/or instructing others, including customers in the United States, regarding) the use,
`
`manufacture, sale, offer for sale, and/or importation, of televisions, smart devices, and graphics
`
`devices in a directly infringing manner.
`
`33. Manufacturas Avanzadas SA de CV is a Mexican corporation located at Blvd.
`
`Independencia #2151, Parque Industrial Salvacar, Ciudad Juárez, Chihuahua, Mexico 32574. On
`
`information and belief, Manufacturas Avanzadas SA de CV is a (direct or indirect) subsidiary of
`
`Respondent TCL Electronics Holdings Ltd. TCL Annual Report 2020 at 140, 313. According to
`
`TCL Annual Report 2020, Manufacturas Avanzadas SA de CV manufactures TV products. Id. In
`
`addition, Manufacturas Avanzadas SA de CV has represented in legal filings that it is one of
`
`several TCL entities who “is a manufacturer and seller of consumer electronics, including . . .
`
`televisions[.]” TCL Complaint at ¶ 2.
`
`34.
`
`Upon information and belief, Manufacturas Avanzadas SA de CV, either itself
`
`and/or through the activities of its affiliates and corporate relatives, is in the business of designing,
`
`manufacturing, importing, and/or selling, televisions, smart devices, and graphics devices that are
`
`manufactured outside of the