Case 6:21-cv-00361-ADA Document 1 Filed 04/12/21 Page 1 of 10
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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`SONRAI MEMORY LIMITED,
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`
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`
`
`Plaintiff,
`
`
`
`Case No.
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`
`
`
`
`
`
`v.
`
`JURY TRIAL DEMANDED
`
`DELL TECHNOLOGIES, INC.,
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`
`
`
`
`
`
`Defendant.
`
`
`
`
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`AGAINST DELL TECHNOLOGIES, INC.
`
`This is an action for patent infringement arising under the Patent Laws of the United States
`
`of America, 35 U.S.C. § 1 et seq., in which Plaintiff Sonrai Memory Limited (“Plaintiff” or
`
`“Sonrai”) makes the following allegations against Defendant Dell Technologies, Inc. (“Defendant”
`
`or “Dell”):
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`INTRODUCTION
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`1.
`
`This complaint arises from Defendant’s unlawful infringement of United States
`
`patents owned by Plaintiff which relate to improvements in charge pump circuits, United States
`
`Patent No. 6,724,241 (“’241 Patent”), portable memory devices with both volatile and non-volatile
`
`memory, United States Patent No. 6,920,527 (“’527 Patent”), and regenerative clock repeating,
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`United States Patent No. 7,436,232 (“’232 Patent”) (collectively, the “Asserted Patents”).
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`PARTIES
`
`2.
`
`Plaintiff Sonrai Memory Limited is a limited liability company organized and
`
`existing under the law of Ireland, with its principal place of business at The Hyde Building, Suite
`
`
`
`1
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`6:21-cv-0036
`
`
`
`
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`SONRAI MEMORY LIMITED,
`
`
`
`
`
`
`
`Plaintiff,
`
`
`
`Case No.
`
`
`
`
`
`
`
`v.
`
`JURY TRIAL DEMANDED
`
`DELL TECHNOLOGIES, INC.,
`
`
`
`
`
`
`
`Defendant.
`
`
`
`
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`AGAINST DELL TECHNOLOGIES, INC.
`
`This is an action for patent infringement arising under the Patent Laws of the United States
`
`of America, 35 U.S.C. § 1 et seq., in which Plaintiff Sonrai Memory Limited (“Plaintiff” or
`
`“Sonrai”) makes the following allegations against Defendant Dell Technologies, Inc. (“Defendant”
`
`or “Dell”):
`
`INTRODUCTION
`
`1.
`
`This complaint arises from Defendant’s unlawful infringement of United States
`
`patents owned by Plaintiff which relate to improvements in charge pump circuits, United States
`
`Patent No. 6,724,241 (“’241 Patent”), portable memory devices with both volatile and non-volatile
`
`memory, United States Patent No. 6,920,527 (“’527 Patent”), and regenerative clock repeating,
`
`United States Patent No. 7,436,232 (“’232 Patent”) (collectively, the “Asserted Patents”).
`
`PARTIES
`
`2.
`
`Plaintiff Sonrai Memory Limited is a limited liability company organized and
`
`existing under the law of Ireland, with its principal place of business at The Hyde Building, Suite
`
`
`
`1
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`6:21-cv-0036
`
`
`
`Case 6:21-cv-00361-ADA Document 1 Filed 04/12/21 Page 2 of 10
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`23, The Park, Carrickmines, Dublin 18, Ireland. Sonrai is the sole owner by assignment of all right,
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`title, and interest in the Asserted Patents.
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`3.
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`On information and belief, Defendant Dell Technologies, Inc. is a corporation
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`organized under the laws of Delaware, with its principal place of business at One Dell Way, Round
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`Rock, Texas 78682.
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`JURISDICTION AND VENUE
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`4.
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`This action arises under the patent laws of the United States, Title 35 of the United
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`States Code. This Court has original subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
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`1338(a).
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`5.
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`This Court has personal jurisdiction over Dell in this action because Dell has
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`committed acts within this District giving rise to this action and has established minimum contacts
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`with this forum such that the exercise of jurisdiction over Dell would not offend traditional notions
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`of fair play and substantial justice. Dell, directly and through subsidiaries or intermediaries, has
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`committed and continues to commit acts of infringement in this District by, among other things,
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`importing, offering to sell, and selling products that infringe the Asserted Patents.
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`6.
`
`Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b). Defendant is
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`registered to do business in Texas, and on information and belief has transacted business in this
`
`District by, among other things, making, using, offering to sell, selling, and importing products
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`that infringe the Asserted Patents. Defendant has a regular and established place of business in this
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`District, including its headquarters at One Dell Way, Round Rock, Texas 78682.
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`2
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`Case 6:21-cv-00361-ADA Document 1 Filed 04/12/21 Page 3 of 10
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`COUNT I
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`INFRINGEMENT OF U.S. PATENT NO. 6,724,241
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`7.
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`Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully
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`set forth herein.
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`8.
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`Plaintiff owns by assignment all rights, title, and interest in U.S. Patent No.
`
`6,724,241, entitled “Variable Charge Pump Circuit with Dynamic Load.” The ’241 Patent was
`
`duly and legally issued by the United States Patent and Trademark Office on April 20, 2004. A
`
`true and correct copy of the ’241 Patent is attached as Exhibit 1.
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`9.
`
`On information and belief, Dell makes, uses, offers for sale, sells, and/or imports
`
`certain products and services, including without limitation laptops, desktop computers, and servers
`
`with SanDisk/Toshiba 64L 3D NAND flash chips, for example, Dell/EMC XPS 15 2-in-1 9575
`
`(“Accused Products”), that directly infringe, literally and/or under the doctrine of equivalents, one
`
`or more claims of the ’241 Patent.
`
`10.
`
`Dell also knowingly and intentionally induces infringement of one or more claims
`
`of the ’241 Patent in violation of 35 U.S.C. § 271(b). Through at least the filing and service of this
`
`Complaint, Dell has had knowledge of the ’241 Patent and the infringing nature of the Accused
`
`Products. Despite this knowledge of the ’241 Patent, Dell continues to actively encourage and
`
`instruct its customers and end users (for example, through user manuals and online instruction
`
`materials on its website) to use the Accused Products in ways that directly infringe the ’241 Patent.
`
`Dell does so knowing and intending that its customers and end users will commit these infringing
`
`acts. Dell also continues to make, use, offer for sale, sell, and/or import the Accused Products,
`
`despite its knowledge of the ’241 Patent, thereby specifically intending for and inducing its
`
`
`
`3
`
`
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`Case 6:21-cv-00361-ADA Document 1 Filed 04/12/21 Page 4 of 10
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`
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`customers to infringe the ’241 Patent through the customers’ normal and customary use of the
`
`Accused Products.
`
`11.
`
`Dell has also infringed, and continues to infringe, one or more claims of the ’241
`
`Patent by selling, offering for sale, or importing into the United States, the Accused Products,
`
`knowing that the Accused Products constitute a material part of the inventions claimed in the ’241
`
`Patent, are especially made or adapted to infringe the ’241 Patent, and are not staple articles or
`
`commodities of commerce suitable for non-infringing use. Dell has been, and currently is,
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`contributorily infringing the ’241 Patent in violation of 35 U.S.C. §§ 271(c) and (f).
`
`12.
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`The Accused Products satisfy all claim limitations of one or more claims of the
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`’241 Patent. A claim chart comparing exemplary independent claim 1 of the ’241 Patent to
`
`representative Accused Products is attached as Exhibit 2.
`
`13.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Products, Dell has injured Plaintiff and is liable for infringement of the ’241 Patent
`
`pursuant to 35 U.S.C. § 271.
`
`14.
`
`As a result of Dell’s infringement of the ’241 Patent, Plaintiff is entitled to monetary
`
`damages in an amount adequate to compensate for Dell’s infringement, but in no event less than a
`
`reasonable royalty for the use made of the invention by Dell, together with interest and costs as
`
`fixed by the Court.
`
`15.
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`Dell’s infringing activities have injured and will continue to injure Plaintiff, unless
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`and until this Court enters an injunction prohibiting further infringement of the ’241 Patent, and,
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`specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that come
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`within the scope of the patent claims.
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`4
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`Case 6:21-cv-00361-ADA Document 1 Filed 04/12/21 Page 5 of 10
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`COUNT II
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`INFRINGEMENT OF U.S. PATENT NO. 6,920,527
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`16.
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`Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`17.
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`Plaintiff owns by assignment all rights, title, and interest in U.S. Patent No.
`
`6,920,527, entitled “Portable RAM drive.” The ’527 Patent was duly and legally issued by the
`
`United States Patent and Trademark Office on July 19, 2005. A true and correct copy of the ’527
`
`Patent is attached as Exhibit 3.
`
`18.
`
`On information and belief, Dell makes, uses, offers for sale, sells, and/or imports
`
`certain products and services, including without limitation laptops, desktop computers, and servers
`
`with SSDs including Silicon Motion SSD Controllers, including without limitation the Dell/EMC
`
`Vostro 15 5568 P62F (“Accused Products”), that directly infringe, literally and/or under the
`
`doctrine of equivalents, one or more claims of the ’527 Patent.
`
`19.
`
`Dell also knowingly and intentionally induces infringement of one or more claims
`
`of the ’527 Patent in violation of 35 U.S.C. § 271(b). Through at least the filing and service of this
`
`Complaint, Dell has had knowledge of the ’527 Patent and the infringing nature of the Accused
`
`Products. Despite this knowledge of the ’527 Patent, Dell continues to actively encourage and
`
`instruct its customers and end users (for example, through user manuals and online instruction
`
`materials on its website) to use the Accused Products in ways that directly infringe the ’527 Patent.
`
`Dell does so knowing and intending that its customers and end users will commit these infringing
`
`acts. Dell also continues to make, use, offer for sale, sell, and/or import the Accused Products,
`
`despite its knowledge of the ’527 Patent, thereby specifically intending for and inducing its
`
`
`
`5
`
`
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`Case 6:21-cv-00361-ADA Document 1 Filed 04/12/21 Page 6 of 10
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`
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`customers to infringe the ’527 Patent through the customers’ normal and customary use of the
`
`Accused Products.
`
`20.
`
`Dell has also infringed, and continues to infringe, one or more claims of the ’527
`
`Patent by selling, offering for sale, or importing into the United States, the Accused Products,
`
`knowing that the Accused Products constitute a material part of the inventions claimed in the ’527
`
`Patent, are especially made or adapted to infringe the ’527 Patent, and are not staple articles or
`
`commodities of commerce suitable for non-infringing use. Dell has been, and currently is,
`
`contributorily infringing the ’527 Patent in violation of 35 U.S.C. §§ 271(c) and (f).
`
`21.
`
`The Accused Products satisfy all claim limitations of one or more claims of the
`
`’527 Patent. A claim chart comparing exemplary independent claim 15 of the ’527 Patent to
`
`representative Accused Products is attached as Exhibit 4.
`
`22.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Products, Dell has injured Plaintiff and is liable for infringement of the ’527 Patent
`
`pursuant to 35 U.S.C. § 271.
`
`23.
`
`As a result of Dell’s infringement of the ’527 Patent, Plaintiff is entitled to monetary
`
`damages in an amount adequate to compensate for Dell’s infringement, but in no event less than a
`
`reasonable royalty for the use made of the invention by Dell, together with interest and costs as
`
`fixed by the Court.
`
`24.
`
`Dell’s infringing activities have injured and will continue to injure Plaintiff, unless
`
`and until this Court enters an injunction prohibiting further infringement of the ’527 Patent, and,
`
`specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that come
`
`within the scope of the patent claims.
`
`
`
`6
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`Case 6:21-cv-00361-ADA Document 1 Filed 04/12/21 Page 7 of 10
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`COUNT III
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`INFRINGEMENT OF U.S. PATENT NO. 7,436,232
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`25.
`
`Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`26.
`
`Plaintiff owns by assignment all rights, title, and interest in U.S. Patent No.
`
`7,436,232, entitled “Regenerative clock repeater.” The ’232 Patent was duly and legally issued by
`
`the United States Patent and Trademark Office on October 14, 2008. A true and correct copy of
`
`the ’232 Patent is attached as Exhibit 5.
`
`27.
`
`On information and belief, Dell makes, uses, offers for sale, sells, and/or imports
`
`certain products and services, including without limitation laptops, desktop computers, and servers
`
`with SanDisk/Toshiba 64L 3D NAND flash chips, for example, Dell/EMC XPS 15 2-in-1 9575
`
`(“Accused Products”), that directly infringe, literally and/or under the doctrine of equivalents, one
`
`or more claims of the ’232 Patent.
`
`28.
`
`Dell also knowingly and intentionally induces infringement of one or more claims
`
`of the ’232 Patent in violation of 35 U.S.C. § 271(b). Through at least the filing and service of this
`
`Complaint, Dell has had knowledge of the ’232 Patent and the infringing nature of the Accused
`
`Products. Despite this knowledge of the ’232 Patent, Dell continues to actively encourage and
`
`instruct its customers and end users (for example, through user manuals and online instruction
`
`materials on its website) to use the Accused Products in ways that directly infringe the ’232 Patent.
`
`Dell does so knowing and intending that its customers and end users will commit these infringing
`
`acts. Dell also continues to make, use, offer for sale, sell, and/or import the Accused Products,
`
`despite its knowledge of the ’232 Patent, thereby specifically intending for and inducing its
`
`
`
`7
`
`
`
`Case 6:21-cv-00361-ADA Document 1 Filed 04/12/21 Page 8 of 10
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`
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`customers to infringe the ’232 Patent through the customers’ normal and customary use of the
`
`Accused Products.
`
`29.
`
`Dell has also infringed, and continues to infringe, one or more claims of the ’232
`
`Patent by selling, offering for sale, or importing into the United States, the Accused Products,
`
`knowing that the Accused Products constitute a material part of the inventions claimed in the ’232
`
`Patent, are especially made or adapted to infringe the ’232 Patent, and are not staple articles or
`
`commodities of commerce suitable for non-infringing use. Dell has been, and currently is,
`
`contributorily infringing the ’232 Patent in violation of 35 U.S.C. §§ 271(c) and (f).
`
`30.
`
`The Accused Products satisfy all claim limitations of one or more claims of the
`
`’232 Patent. A claim chart comparing exemplary independent claim 14 of the ’232 Patent to
`
`representative Accused Products is attached as Exhibit 6.
`
`31.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Products, Dell has injured Plaintiff and is liable for infringement of the ’232 Patent
`
`pursuant to 35 U.S.C. § 271.
`
`32.
`
`As a result of Dell’s infringement of the ’232 Patent, Plaintiff is entitled to monetary
`
`damages in an amount adequate to compensate for Dell’s infringement, but in no event less than a
`
`reasonable royalty for the use made of the invention by Dell, together with interest and costs as
`
`fixed by the Court.
`
`33.
`
`Dell’s infringing activities have injured and will continue to injure Plaintiff, unless
`
`and until this Court enters an injunction prohibiting further infringement of the ’232 Patent, and,
`
`specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that come
`
`within the scope of the patent claims.
`
`
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`8
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`Case 6:21-cv-00361-ADA Document 1 Filed 04/12/21 Page 9 of 10
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff respectfully requests that this Court enter:
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`a.
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`A judgment in favor of Plaintiff that Dell has infringed, either literally and/or under
`
`the doctrine of equivalents, the ’241, ’527, and ’232 Patents;
`
`b.
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`A permanent injunction prohibiting Dell from further acts of infringement of
`
`the ’241, ’527, and ’232 Patents;
`
`c.
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`A judgment and order requiring Dell to pay Plaintiff its damages, costs, expenses,
`
`and pre-judgment and post-judgment interest for Dell’s infringement of the ’241, ’527, and ’232
`
`Patents; and
`
`d.
`
`A judgment and order requiring Dell to provide an accounting and to pay
`
`supplemental damages to Plaintiff, including without limitation, pre-judgment and post-judgment
`
`interest;
`
`e.
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`A judgment and order finding that this is an exceptional case within the meaning
`
`of 35 U.S.C. § 285 and awarding to Plaintiff its reasonable attorneys’ fees against Dell; and
`
`f.
`
`Any and all other relief as the Court may deem appropriate and just under the
`
`circumstances.
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`DEMAND FOR JURY TRIAL
`
`Plaintiff, under Rule 38 of the Federal Rules of Civil Procedure, requests a trial by jury of
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`any issues so triable by right.
`
`
`
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`Dated: April 12, 2021
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`
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`Respectfully submitted,
`
`/s/ Reza Mirzaie
`
`Reza Mirzaie (CA SBN 246953)
`
`
`
`9
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`Case 6:21-cv-00361-ADA Document 1 Filed 04/12/21 Page 10 of 10
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`rmirzaie@raklaw.com
`Marc A. Fenster (CA SBN 181067)
`mfenster@raklaw.com
`Brian D. Ledahl (CA SBN 186579)
`bledahl@raklaw.com
`James A. Milkey (CA SBN 281283)
`jmilkey@raklaw.com
`Christian W. Conkle (CA SBN 306374)
`cconkle@raklaw.com
`Jonathan Ma (CA SBN 312773)
`jma@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`Facsimile: (310) 826-6991
`
`Attorneys for Plaintiff Sonrai Memory Limited
`
`10
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