Case 6:20-cv-00967 Document 1 Filed 10/15/20 Page 1 of 78
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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`6:20-CV-00967
`Civil Action No. ______________
`
`JURY TRIAL DEMANDED
`
`ACQIS LLC,
`a Texas limited liability company,
`
`Plaintiff,
`
`v.
`
`LENOVO GROUP LTD., a China
`corporation, LENOVO PC HK
`LIMITED, a China corporation, LCFC
`(HEFEI) ELECTRONICS
`TECHNOLOGY CO., LTD., a China
`corporation, LENOVO
`INTERNATIONAL INFORMATION
`PRODUCTS (SHENZHEN) CO. LTD., a
`China corporation, LENOVO (BEIJING)
`INFORMATION TECHNOLOGY LTD.,
`a China corporation, LENOVO CENTRO
`TECHNOLOGICO S DE R.L. DE CV, a
`Mexico corporation,
`
`Defendants.
`
`COMPLAINT FOR PATENT INFRINGEMENT
`Plaintiff ACQIS LLC (“Plaintiff” or “ACQIS”), by its attorneys, hereby alleges patent
`
`infringement against Defendants Lenovo Group Ltd., Lenovo PC HK Limited, LCFC (Hefei)
`
`Electronics Technology Co., Ltd., Lenovo International Information Products (Shenzhen) Co.
`
`Ltd., Lenovo (Beijing) Information Technology Co., Ltd., Lenovo Centro Tecnológico S. de R.L.
`
`de C.V (collectively “Defendants” or “Lenovo”) as follows:
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`INTRODUCTION
`This is an action for patent infringement under the United States Patent Laws, 35
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`1.
`
`U.S.C. § 1 et seq. Beginning in the late 1990s, Dr. William Chu founded ACQIS and invented a
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`variety of pioneering computer technologies that employed serial transmission along low voltage
`
`differential signal (LVDS) channels to dramatically increase the speed at which data can be
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`transmitted while also reducing power consumption and noise. Dr. Chu’s inventions have become
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`foundational in the computer industry, and are found in a variety of data transmission systems,
`
`including PCI Express (PCIe) and/or USB 3.x1 transactions.
`
`2.
`
`Lenovo has infringed and continues to infringe, directly and/or indirectly, the
`
`following patents owned by ACQIS: U.S. Patent Nos. 9,529,768 (“’768 patent”), 9,703,750 (“’750
`
`patent”), 8,756,359 (“’359 patent”), 8,626,977 (“’977 patent”), RE44,739 (“’739 patent”),
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`8,977,797 (“’797 patent”), 9,529,769 (“’769 patent”), RE45,140 (“’140 patent”), and RE44,654
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`(“’654 patent”) (collectively, the “ACQIS Patents”). Copies of the ACQIS Patents are attached to
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`this Complaint as Exhibits 1-9.
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`3.
`
`Specifically, Lenovo has directly and/or indirectly infringed and continues to
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`infringe the ACQIS Patents through: (1) the manufacture, use, offering to sale, and/or sale in the
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`United States, and/or the importation into the United States, of infringing Lenovo-brand computer
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`products; (2) the practice of claimed methods of the ACQIS Patents by manufacturing, using
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`and/or testing Lenovo-brand computer products in the United States; (3) the importation into the
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`United States of Lenovo-brand computer products made abroad using ACQIS’s patented
`
`processes; and (4) the inducement of third parties to engage in the activity described above with
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`knowledge of the ACQIS Patents and of the third parties’ infringing actions.
`
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`1 As used herein, “USB 3.x” refers to USB 3.0 and subsequent versions, including USB 3.1, USB
`3.2, and any other subsequent versions.
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`4.
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`ACQIS seeks damages and other relief for Lenovo’s infringement of the ACQIS
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`Patents. ACQIS is entitled to past damages because, without limitation, it has provided actual
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`notice to Lenovo and for method claims which do not require marking.
`
`THE PARTIES
`Plaintiff ACQIS LLC, is a limited liability company organized and existing under
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`5.
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`the laws of the State of Texas, with offices at 411 Interchange Street, McKinney, Texas 75071. A
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`related entity, ACQIS Technology, Inc., is a corporation organized under the laws of the State of
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`Delaware, having its principal place of business at 1503 Grant Road, Suite 100, Mountain View,
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`California 94040. ACQIS LLC is operated from California, where its President, Dr. William Chu,
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`resides. Dr. Chu is also the Chief Executive Officer of ACQIS Technology, Inc.
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`6.
`
`Lenovo Group Limited is a Chinese company with its principal place of business
`
`in Hong Kong at 23rd Floor, Lincoln House, Taikoo Place, 979 King’s Road, Quarry Bay, Hong
`
`Kong Island, Hong Kong S.A.R. Lenovo Group Limited is the parent company of a multinational
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`conglomerate that operates under the name “Lenovo” and is a global leader in the personal and
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`business computer market. Lenovo purports to be a US$50 billion Fortune Global 500 company,
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`with 63,000 employees and operating in 180 markets around the world.
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`7.
`
`Lenovo PC HK Limited is a wholly-owned subsidiary of Lenovo Group Limited
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`and a Chinese company with its principal place of business in Hong Kong at 23rd Floor, Lincoln
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`House, Taikoo Place, 979 King’s Road, Quarry Bay, Hong Kong Island, Hong Kong S.A.R.
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`Lenovo PC HK Limited is listed on at least one infringing Lenovo-brand product and on various
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`manufacturing certification certificates applicable to products sold in the United States. Lenovo
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`Group Limited’s 2019/2020 Annual Report indicates that Lenovo PC HK Limited distributes IT
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`products.
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`8.
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`LCFC (Hefei) Electronics Technology Co., Ltd. is a wholly-owned subsidiary of
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`Lenovo Group Limited and a Chinese company with a manufacturing center at NO.1-3188, Yungu
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`Road, Hefei Export Processing Zone, Anhui Province Hefei, China. Publicly available import
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`data indicates that LCFC (Hefei) Electronics Technology Co., Ltd. imports notebook computers
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`into the United States. Lenovo Group Limited’s 2019/2020 Annual Report indicates that LCFC
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`(Hefei) Electronics Technology Co., Ltd. manufactures and distributes IT products.
`
`9.
`
`Lenovo International Information Products (Shenzhen) Co. Ltd., a Chinese
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`company, 1/#1 Great Wall Technology Building Science & Industry Park, Nanshan District.
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`Shenzhen, China 518057. Publicly available import data indicates that Lenovo International
`
`Information Products (Shenzhen) Co. Ltd., is a prolific importer of Lenovo products, including
`
`laptop and desktop computers, into the United States.
`
`10.
`
`Lenovo (Beijing) Information Technology Ltd. is a wholly-owned subsidiary of
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`Lenovo Group Limited and is a Chinese company with its principal place of business at 3406
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`Room in No. 6 Chuangye Road, Shangdi Information Industry Base, Haidan District, Beijing
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`China, 100085. It is listed as a manufacturer of Lenovo products on various manufacturing
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`certification certificates applicable to products sold in the United States. Lenovo Group Limited’s
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`2019/2020 Annual Report indicates that Lenovo (Beijing) Information Technology Ltd.
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`distributes IT products.
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`11.
`
`Lenovo Centro Tecnológico S. de R.L. de C.V is a Mexican company with its
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`principal place of business at No. 316, Boulevard Escobedo Apodaca, Technology Park Apodaca,
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`Nuevo Leon, P.O. 66600, México. It is listed as Lenovo’s Monterrey, México manufacturing
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`center on the Lenovo website. Publicly available import data indicates that Lenovo Centro
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`Tecnológico is a prolific importer of Lenovo products, including desktop computers, into the
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`United States and specifically into Houston, Texas. A Lenovo-brand ThinkStation P330 SFF
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`desktop and Lenovo ThinkSystem SR650 server which were purchased in the U.S. and delivered
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`to this District are both marked as “Made in Mexico” with the ThinkStation P330 SFF specifically
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`labeled as “Made in Monterrey.”
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`12.
`
`Defendants are part of the same corporate structure and distribution chain (together
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`with other Lenovo subsidiaries, affiliates, and intermediaries) with respect to the manufacture,
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`use, offering to sell, and/or sale of infringing Lenovo-brand computer products and with respect
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`to the importation into the United States of infringing Lenovo-brand computer products and of
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`Lenovo-brand computer products made abroad using patented processes claimed in the ACQIS
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`Patents.
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`JURISDICTION AND VENUE
`This is an action for patent infringement under the United States patent laws, 35
`
`13.
`
`U.S.C. § 101 et seq.
`
`14.
`
`This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
`
`1338(a).
`
`15.
`
`This Court has personal jurisdiction over the Defendants consistent with the
`
`requirements of the Due Process Clause of the United States Constitution and the Texas Long Arm
`
`Statute. On information and belief, Defendants have purposefully manufactured and/or distributed
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`Lenovo-brand computer products that infringe the ACQIS Patents, or that were made abroad using
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`patented processes claimed in the ACQIS Patents, through established distribution channels with
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`the expectation that those products would be sold in the United States, State of Texas, and in this
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`District. Further, Defendants have (themselves and/or through the activities of subsidiaries,
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`affiliates, or intermediaries) committed and continue to commit acts of patent infringement in the
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`United States, State of Texas and this District, including by making, using, offering to sell, and/or
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`selling infringing Lenovo-brand computer products in the United States, State of Texas and this
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`District; importing infringing Lenovo-brand computer products and/or Lenovo-brand computer
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`products made abroad using ACQIS’s patented processes into the United States for sale in the
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`State of Texas and this District; and/or inducing others to commit acts of patent infringement in
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`the United States, State of Texas and this District. Accordingly, Lenovo has established minimum
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`contacts within Texas and purposefully availed itself of the benefits of Texas, and the exercise of
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`personal jurisdiction over Lenovo would not offend traditional notions of fair play and substantial
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`justice. In addition, or in the alternative, this Court has personal jurisdiction over Lenovo pursuant
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`to Federal Rule of Civil Procedure 4(k)(2).
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`16.
`
`Venue is proper in this District pursuant to 28 U.S.C. § 1391(c)(3) because
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`Defendants do not reside in the United States and thus may be sued in any judicial district in the
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`United States pursuant to 28 U.S.C. § 1391(c)(3).
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`FACTUAL BACKGROUND
`Dr. Chu and the ACQIS Patents
`
`17.
`
`Dr. William Chu has been a prolific innovator in the computing industry since the
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`1970s.
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`18.
`
`In 1976, Dr. Chu received his Ph.D. in Electrical Engineering from the University
`
`of California, Berkeley. Dr. Chu then began working in semiconductor design for American
`
`Microsystems, Inc. from 1976 to 1977, and then for Zilog, Inc. from 1977 to 1982.
`
`19.
`
`In 1982, Dr. Chu founded Verticom, Inc., which developed innovative technologies
`
`relating to video transmission over telephone lines. Verticom also developed graphics products
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`for the PC computer-aided design (CAD) market. Verticom’s success resulted in its stock being
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`listed on the NASDAQ exchange in 1997. In 1998, Verticom was acquired by Western Digital
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`Imaging, Inc.
`
`20.
`
`Dr. Chu served as Vice President of Engineering for Western Digital from 1988 to
`
`1991, overseeing a development team in the desktop and portable graphics chip division. In the
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`course of his work at Western Digital, Dr. Chu in 1988 started the company’s portable graphics
`
`chip business, which became #1 in the portable graphics chip market by 1991. Dr. Chu also led
`
`Western Digital to achieve the #1 market share in the PC graphics market in 1990.
`
`21.
`
`After Western Digital, Dr. Chu worked for Acumos, Inc. from 1991 to 1992 as a
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`Vice President managing engineering for computer graphics chip development. Acumos was
`
`acquired by Cirrus Logic, Inc. in 1992.
`
`22.
`
`Dr. Chu then worked for Cirrus Logic from 1992 to 1997, first as a General
`
`Manager in the Desktop Graphics Division and later as Co-President of the Graphics Chip
`
`Business Unit. During Dr. Chu’s time at Cirrus Logic, the company achieved #1 market share in
`
`the PC graphics chip market.
`
`23.
`
`In 1998, Dr. Chu founded ACQIS Technology, Inc. to pursue his vision of
`
`developing a small, portable computer module that could be interchangeably connected with a
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`variety of different peripheral consoles. In the course of this development effort, Dr. Chu
`
`recognized the need for a better interconnection between the core computing module and a
`
`peripheral console. Such interconnections traditionally conveyed peripheral component
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`interconnect (PCI) bus transactions in parallel using a large number of signal channels and
`
`connector pins. This made it difficult to employ LVDS channels, which are more “cable friendly,”
`
`consume less power, and generate less noise. Dr. Chu wanted to develop an interconnection
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`system that was scalable, used connectors with low pin counts, was power-efficient, high
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`performing, and easily extendible for future computing needs and technologies. This development
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`work resulted in a large family of patents now owned by ACQIS, which disclose and claim a
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`variety of pioneering inventions relating to improved, high-performance and low-power
`
`consuming interconnection technologies for computer modules.
`
`24.
`
`After several decades in the industry, Dr. Chu is now a named inventor of
`
`approximately forty-one (41) U.S. Patents.
`
`25.
`
`Among the patent portfolio covering Dr. Chu’s inventions and owned by ACQIS
`
`are the ACQIS Patents asserted in this case.
`
`26.
`
`The ’768 patent, entitled “Computer System Including CPU or Peripheral Bridge
`
`Directly Connected to a Low Voltage Differential Signal Channel that Communicates Serial Bits
`
`of a Peripheral Component Interconnect Bus Transaction in Opposite Directions,” was duly and
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`legally issued on December 27, 2016, from a patent application filed March 13, 2014, with
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`William W.Y. Chu as the sole named inventor. The ’768 patent claims priority to U.S. Provisional
`
`Patent Application No. 60/134,122, filed on May 14, 1999.
`
`27.
`
`The ’750 patent, entitled “Computer System Including CPU or Peripheral Bridge
`
`Directly Connected to a Low Voltage Differential Signal Channel that Communicates Serial Bits
`
`of a Peripheral Component Interconnect Bus Transaction in Opposite Directions,” was duly and
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`legally issued on July 11, 2017, from a patent application filed October 9, 2014, with William
`
`W.Y. Chu as the sole named inventor. The ’750 patent claims priority to U.S. Provisional Patent
`
`Application No. 60/134,122, filed on May 14, 1999.
`
`28.
`
`The ’359 patent, entitled “Computer System Including CPU or Peripheral Bridge
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`to Communicate Serial Bits of Peripheral Component Interconnect Bus Transaction and Low
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`Voltage Differential Signal Channel to Convey the Serial Bits,” was duly and legally issued on
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`June 17, 2014, from a patent application filed January 17, 2013, with William W.Y. Chu as the
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`sole named inventor. The ’359 patent claims priority to U.S. Provisional Patent Application No.
`
`60/134,122, filed on May 14, 1999.
`
`29.
`
`The ’977 patent, entitled “Computer System Including CPU or Peripheral Bridge
`
`to Communicate Serial Bits of Peripheral Component Interconnect Bus Transaction and Low
`
`Voltage Differential Signal Channel to Convey the Serial Bits,” was duly and legally issued on
`
`January 7, 2014, from a patent application filed July 27, 2012, with William W.Y. Chu as the sole
`
`named inventor. The ’977 patent claims priority to U.S. Provisional Patent Application No.
`
`60/134,122, filed on May 14, 1999.
`
`30.
`
`The ’739 patent, entitled “Data Security Method and Device for Computer
`
`Modules,” was duly and legally issued on January 28, 2014, from a patent application filed May
`
`21, 2013, with William W.Y. Chu as the sole named inventor. The ’739 patent claims priority to
`
`U.S. Patent Application No. 11/056,604, filed on February 10, 2005.
`
`31.
`
`The ’797 patent, entitled “Method of Improving Peripheral Component Interface
`
`Communications Utilizing a Low Voltage Differential Signal Channel,” was duly and legally
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`issued on March 10, 2015, from a patent application filed October 10, 2012, with William W.Y.
`
`Chu as the sole named inventor. The ’797 patent claims priority to U.S. Provisional Patent
`
`Application No. 60/134,122, filed on May 14, 1999.
`
`32.
`
`The ’769 patent, entitled “Computer System Including CPU or Peripheral Bridge
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`Directly Connected to a Low Voltage Differential Signal Channel that Communicates Serial Bits
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`of a Peripheral Component Interconnect Bus Transaction In Opposite Directions,” was duly and
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`legally issued on December 27, 2016, from a patent application filed February 26, 2016, with
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`William W.Y. Chu as the sole named inventor. The ’769 patent claims priority to U.S. Patent
`
`Application No. 11/097,694, filed on March 31, 2005.
`
`33.
`
`The ’140 patent, entitled “Data Security Method and Device for Computer
`
`Modules,” was duly and legally issued on September 16, 2014, from a reissue application filed
`
`December 17, 2013, with William W.Y. Chu as the sole named inventor. The ’140 patent is a
`
`reissue of U.S. Patent No. 6,643,777, which issued on November 4, 2003, from a patent application
`
`filed May 14, 1999. The ’140 patent claims priority to U.S. Patent Application No. 09/312,199,
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`filed on May 14, 1999.
`
`34.
`
`The ’654 patent, entitled “Data Security Method and Device for Computer
`
`Modules,” was duly and legally issued on December 17, 2013, from a reissue application filed
`
`October 10, 2012, with William W.Y. Chu as the sole named inventor. The ’654 patent is a reissue
`
`of U.S. Patent No. 6,643,777, which issued on November 4, 2003, from a patent application filed
`
`May 14, 1999. The ’654 patent claims priority to U.S. Patent Application No. 09/312,199, filed
`
`on May 14, 1999.
`
`35.
`
`The inventions claimed in the ACQIS Patents enable computers to operate faster
`
`with better efficiency through faster interconnections including between the core computing
`
`power modules and any connected consoles.
`
`36.
`
`The claims in the ACQIS Patents generally relate to computers and computer
`
`systems that employ CPUs coupled to LVDS channels that convey various types of data (e.g., PCI
`
`bus transactions, USB 3.x data, and/or digital video data) in a serial bit stream using pairs of
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`unidirectional channels to convey the data in opposite directions.
`
`37.
`
`Over the years, Dr. Chu’s inventive developments have become more and more
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`widely used in computing technologies. One prime example is the computing industry’s adoption
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`of PCI Express, which post-dates Dr. Chu’s inventions but embodies Dr. Chu’s patented
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`interconnection invention by using “high speed, low voltage, differential serial pathway for two
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`devices … to communicate simultaneously by implementing dual unidirectional paths between
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`two devices[.]”
`
`
`
`See Introduction to PCI Express – A Hardware and Software Developers Guide, Intel Press (2003),
`
`at 1-2 (“There are certain times in the evolution of technology that serve as inflection points that
`
`forever change the course of events. For the computing sector and communications, the adoption
`
`of PCI Express, a groundbreaking new general input/output architecture, will serve as one of these
`
`inflection points.”).
`
`38.
`
`PCI Express connections transmit data packets known as transaction layer packets
`
`(TLP) that include data bits, address bits, and byte enable (BE) information bits.
`
`
`
`Id. at 93-114.
`
`39.
`
`In sum, PCI Express connections are LVDS channels that convey data bits, address
`
`bits, and byte enable information bits of a PCI bus transaction in a serial bit stream using pairs of
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`unidirectional, differential signal lanes to convey the information in opposite directions allowing
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`the connection to be scalable and dramatically reducing the pin-count required for connectors, as
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`well as other benefits. “Currently PCI Express defines the following configuration of serial links:
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`x1, x2, x4, x8, x12, x16, and x32. … An x2 configuration indicates two serial paths to and from a
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`device[.]”
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`Id. at 3, 50.
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`
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`
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`40.
`
`Another example of a computer-to-peripheral interconnection that embodies Dr.
`
`Chu’s patented invention is the USB 3.x connection. The “Super Speed” USB 3.0 architecture
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`uses at least two pairs of unidirectional, point-to-point differential signal paths. Each pair includes
`
`a transmit path and a receiving path, thus transmitting the USB data packet information in opposite
`
`directions.
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`Universal Serial Bus 3.0 Specification, Rev. 1.0 (Nov. 12, 2008), at 3-1 to 3.5. In sum, USB 3.x
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`connections are LVDS channels using two unidirectional, differential signal pairs that transmit
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`USB protocol data packets in opposite directions.
`
`41.
`
`The DMI is similar to PCIe and implements at least four serial lanes that all use
`
`differential signaling constituting 2 transmit lanes and 2 receive lanes and, therefore, transmitting
`
`data
`
`in
`
`opposite
`
`directions.
`
`See
`
`https://www.intel.com/content/dam/www/public/us/en/documents/white-papers/ia-introduction-
`
`basics-paper.pdf . See also https://en.wikipedia.org/wiki/Direct_Media_Interface (“DMI shares
`
`many characteristics with PCI Express, using multiple lanes and differential signaling to form a
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`point-to-point link.”).
`
`42.
`
`Each claim of the ACQIS Patents is a patentable, valid and enforceable invention
`
`that is novel and non-obvious over the prior art.
`
`43. ACQIS has not authorized or licensed Lenovo to practice any of the inventions
`
`claimed in the ACQIS Patents.
`
`Lenovo’s Infringing Products
`
`44.
`
`Lenovo is a global leader in the personal and business computer market. Lenovo
`
`makes and sells a variety of laptop computers, desktop computers, and computer servers. Lenovo
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`imports infringing laptop computers, desktop computers, and computer servers, and laptop
`
`computers, desktop computers, and computer servers made using infringing processes, into the
`
`United States through established distribution channels with the expectation that those products
`
`would be sold in the United States, State of Texas and this District.
`
`45.
`
`Infringing Lenovo-brand laptop computers, desktop computers, and computer
`
`servers have been sold in the Western District of Texas through one or more Lenovo U.S.
`
`subsidiaries and their distributors, through the Lenovo website, and/or through retailers. Indeed,
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`the infringing Lenovo-brand products can be purchased for delivery into this District through one
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`or more websites available to the general public. By way of illustration, on October 6, 2020,
`
`Plaintiff purchased a Lenovo-brand ThinkPad P1 Gen 3 Mobile Workstation and a Lenovo-brand
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`ThinkStation P330 SFF from the Lenovo website (Lenovo.com), as well as a Lenovo ThinkSystem
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`SR650 from the CDW website (www.cdw.com), for delivery to the offices of Scott, Douglass, and
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`McConnico, 303 Colorado Street, Suite 2400, Austin, Texas 78701-4654, and those products were
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`in fact delivered into this District at the designated address. Each of these products and their
`
`packaging confirm that the products were manufactured abroad (for example in China or Mexico),
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`then imported, offered for sale, and sold into the United States and this District.
`
`46.
`
`On information and belief, Lenovo’s sale of laptops, desktops and servers generates
`
`billions of dollars in revenue every year.
`
`47.
`
`In 2019, Lenovo achieved its highest ever annual revenue at $51 billion,
`
`constituting a 12.5% increase from the prior year. This included record revenues from Lenovo’s
`
`PC and Smart Devices group of over $38 billion and form its Data Center Group of over $6 billion.
`
`48. Lenovo has directly infringed, and continues to infringe, one or more claims of
`
`each of the ACQIS Patents under at least 35 U.S.C. §§ 271(a) and (g), by making, using,
`
`offering to sell, and/or selling within the United States, and/or importing into the United States,
`
`computer products that embody the claimed inventions of Dr. Chu, and/or by importing into
`
`the United States computer products that were made abroad using patented processes claimed
`
`in the ACQIS Patents.
`
`49. Lenovo makes, uses, imports and sells a variety of laptop computer products in
`
`the United States that infringe one or more of the claims in the ACQIS Patents, and/or imports
`
`into the United States laptop computer products that were made abroad using patented
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`Case 6:20-cv-00967 Document 1 Filed 10/15/20 Page 15 of 78
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`processes claimed in the ACQIS Patents including, without limitation, laptops sold under the
`
`brand names ThinkPad®, ThinkBook®, YOGA®, Legion®, ideapad®, and Lenovo®. These
`
`products are collectively referred to as the “Accused Laptops.”
`
`50. Lenovo makes, uses, imports and sells a variety of desktop computer products in
`
`the United States that infringe one or more of the claims in the ACQIS Patents, and/or imports
`
`into the United States desktop computer products that were made abroad using patented
`
`processes claimed in the ACQIS Patents including, without limitation, desktop computers sold
`
`under the brand names ThinkStation®, ideacentre®, ThinkCentre®, and Legion®. These
`
`products are collectively referred to as the “Accused Desktops.”
`
`51. Lenovo makes, uses, imports and sells a variety of computer server products in
`
`the United States that infringe one or more of the claims in the ACQIS Patents, and/or imports
`
`into the United States computer server products that were made abroad using patented processes
`
`claimed in the ACQIS Patents including, without limitation, edge, rack, tower and node servers
`
`sold under the brand names ThinkSystem® and ThinkServer®. These products are collectively
`
`referred to as the “Accused Servers.”
`
`52.
`
`The Accused Laptops, Accused Desktops, and Accused Servers are collectively
`
`referred to herein as the “Accused Lenovo Products.”
`
`53.
`
`On information and belief, Lenovo manufactures and tests at least certain of the
`
`Accused Lenovo Products abroad and directly or indirectly uses, offers to sell, and/or sells such
`
`products in the United States, and/or imports such products into the United States.
`
`54.
`
`On information and belief, at least certain of the Accused Lenovo Products that
`
`Lenovo imports into the United States are manufactured outside the United States using one or
`
`more processes claimed in the ACQIS Patents.
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`Case 6:20-cv-00967 Document 1 Filed 10/15/20 Page 16 of 78
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`55.
`
`The Accused Lenovo Products include products made, used, offered for sale, sold
`
`within the United States, and/or imported into the United States, at least since ACQIS provided
`
`Lenovo actual notice of its infringement on or around May 15, 2018.
`
`56.
`
`The Accused Lenovo Products also include products made using the processes
`
`claimed in the ACQIS Patents and imported into the United States within the six years preceding
`
`the date of this Complaint.
`
`57.
`
`The Accused Lenovo Products also include products that are used to perform one
`
`or more methods claimed in the ACQIS Patents within the six years preceding the date of this
`
`Complaint.
`
`The Accused Laptops
`
`58.
`
`On information and belief, all of the Accused Laptops are configured and operate
`
`in substantially the same way as explained below using the ThinkPad® P1 Mobile Workstation as
`
`an example for illustrative purposes.
`
`59.
`
` The ThinkPad® P1 is a computer system that runs the Windows operation system.
`
`https://www.lenovo.com/us/en/laptops/thinkpad/thinkpad-p/ThinkPad-P1-Gen-
`
`
`
`
`
`3/p/22WS2P1P1N3
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`60.
`
`The ThinkPad® P1 uses an Intel® Core processor, such as the 10th Gen Intel® Core
`
`i7-10750H.
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`Case 6:20-cv-00967 Document 1 Filed 10/15/20 Page 17 of 78
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`
`
`https://www.lenovo.com/us/en/laptops/thinkpad/thinkpad-p/ThinkPad-P1-Gen-
`
`3/p/22WS2P1P1N3
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`61.
`
`Intel’s standard core architecture (including the 10th Gen Intel® Core i7-10750H
`
`architecture) integrates the central processing unit (CPU) with a graphics subsystem and an
`
`interface controller. On information and belief, the Intel Core processors integrate one or more
`
`interface controllers within Intel’s “System Agent” to control PCIe and other data transmissions
`
`from the CPU.
`
`https://www.intel.com/content/dam/www/public/us/en/documents/white-papers/ia-introduction-
`
`basics-paper.pdf
`
`
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`Case 6:20-cv-00967 Document 1 Filed 10/15/20 Page 18 of 78
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`https://ark.intel.com/content/www/us/en/ark/products/201837/intel-core-i7-10750h-processor-
`
`12m-cache-up-to-5-00-ghz.html?wapkw=Core%20i7-10750H
`
`
`
`https://www.lenovo.com/us/en/laptops/thinkpad/thinkpad-p/ThinkPad-P1-Gen-
`
`3/p/22WS2P1P1N3
`
`
`
`62.
`
`The ThinkPad® P1 laptops include a variety of connectors that can couple the CPU
`
`to a console, including through Intel’s Embedded DisplayPort® connector and through USB 3.0,
`
`HDMI2, and Thunderbolt3 ports.
`
`
`2 High-Definition Multimedia Interface (HDMI) uses transition minimized differential signaling
`(TMDS) to carry digital video signals. See 10th Generation Intel® CoreTM Processors
`Datasheet, vol. 1 of 2, at p. 41 (July 2020, Rev. 005) (Doc. No. 615211-005).
`3 Thunderbolt 3 connectors can transmit USB 3.x, PCIe and DisplayPort data signals. See
`https://thunderbolttechnology.net/thunderbolt-3-infographic; https://www.engadget.com/2011-
`02-24-intel-thunderbolt-a-closer-look.html.
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`Case 6:20-cv-00967 Document 1 Filed 10/15/20 Page 19 of 78
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`10th Generation Intel® CoreTM Processors Datasheet, vol. 1 of 2, at p. 9-11 (July 2020, Rev. 005)
`
`(Doc. No. 615211-005).
`
`
`
`
`
`https://www.lenovo.com/us/en/laptops/thinkpad/thinkpad-p/ThinkPad-P1-Gen-
`
`3/p/22WS2P1P1N3
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`63.
`
`The Intel processors employed in the ThinkPad® P1 laptops connect directly to a
`
`variety of LVDS channels that convey data bits in a serial stream using unidirectional pairs of
`
`lanes transmitting data in opposite direction, including Intel’s DMI and PCIe channels, and the
`
`directly-connected PCIe channels connect the CPU to a graphics card.
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`Case 6:20-cv-00967 Document 1 Filed 10/15/20 Page 20 of 78
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`10th Generation Intel® CoreTM Processors Datasheet, vol. 1 of 2, at p. 9-11, 26-30 (July 2020, Rev.
`
`005) (Doc. No. 615211-005).
`
`
`
`
`https://www.lenovo.com/us/en/laptops/thinkpad/thinkpad-p/ThinkPad-P1-Gen-
`
`3/p/22WS2P1P1N3
`
`64.
`
`The Intel processors employed in the ThinkPad® P1 laptops also connect directly
`
`to a variety of differential signal channels that output digital video signals through a connector,
`
`including HDMI and DisplayPort.
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`Case 6:20-cv-00967 Document 1 Filed 10/15/20 Page 21 of 78
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`
`
`10th Generation Intel® CoreTM Processors Datasheet, vol. 1 of 2, at p. 9-11 (July 2020, Rev. 005)
`
`(Doc. No. 615211-005).
`
`65.
`
`The Intel processors employed in the ThinkPad® P1 laptops also connect to LVDS
`
`channels that convey USB data packets through pairs of unidirectional differential signal paths in
`
`opposite directions—USB 3.x ports.
`
`10th Generation Intel® CoreTM Processors Datasheet, vol. 1 of 2, at p. 9-11 (July 2020, Rev. 005)
`
`(Doc. No. 615211-005).
`
`66.
`
`The ThinkPad® P1 laptops have DDR4 system memory connected directly to the
`
`
`
`CPU.
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`Case 6:20-cv-00967 Document 1 Filed 10/15/20 Page 22 of 78
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`https://www.lenovo.com/us/en/laptops/thinkpad/thinkpad-p/ThinkPad-P1-Gen-
`
`3/p/22WS2P1P1N3
`
`
`
`10th Gene