Case 6:22-cv-00029-ADA Document 1 Filed 01/07/22 Page 1 of 5
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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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`
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`Plaintiff,
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`
`
`Case No.
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`
`
`
`
`
`
`v.
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`JURY TRIAL DEMANDED
`
`LENOVO GROUP LTD.; MOTOROLA
`MOBILITY LLC,
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`
`
`
`
`
`
`Defendants.
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`
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`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`AGAINST LENOVO GROUP LTD.; MOTOROLA MOBILITY LLC.
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`This is an action for patent infringement arising under the Patent Laws of the United States
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`of America, 35 U.S.C. § 1 et seq., in which Plaintiff Sonrai Memory Limited (“Plaintiff” or
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`“Sonrai”) makes the following allegations against Defendants Lenovo Group Ltd. and Motorola
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`Mobility LLC (“Defendants”):
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`INTRODUCTION
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`1.
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`This complaint arises from Defendants’ unlawful infringement of the following
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`United States patent owned by Plaintiff, which relates to improvements in computer chip
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`architecture having multiple processors on a single die: United States Patent No. 6,874,014 (“’014
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`Patent” or the “Asserted Patent”).
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`PARTIES
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`2.
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`Plaintiff Sonrai Memory Limited is a limited liability company organized and
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`existing under the law of Ireland, with its principal place of business at The Hyde Building, Suite
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`
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`1
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`6:22-cv-00029
`
`
`
`
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`SONRAI MEMORY LIMITED,
`
`
`
`
`
`
`
`Plaintiff,
`
`
`
`Case No.
`
`
`
`
`
`
`
`v.
`
`JURY TRIAL DEMANDED
`
`LENOVO GROUP LTD.; MOTOROLA
`MOBILITY LLC,
`
`
`
`
`
`
`
`Defendants.
`
`
`
`
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`AGAINST LENOVO GROUP LTD.; MOTOROLA MOBILITY LLC.
`
`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 Defendants Lenovo Group Ltd. and Motorola
`
`Mobility LLC (“Defendants”):
`
`INTRODUCTION
`
`1.
`
`This complaint arises from Defendants’ unlawful infringement of the following
`
`United States patent owned by Plaintiff, which relates to improvements in computer chip
`
`architecture having multiple processors on a single die: United States Patent No. 6,874,014 (“’014
`
`Patent” or the “Asserted Patent”).
`
`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
`
`6:22-cv-00029
`
`
`
`Case 6:22-cv-00029-ADA Document 1 Filed 01/07/22 Page 2 of 5
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`
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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 Patent.
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`3.
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`On information and belief, Defendant Lenovo Group Ltd. is organized under the
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`laws of the People’s Republic of China, with its principal place of business at 6 Chuang ye Road,
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`Haidan District, Beijing 100085, China.
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`4.
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`On information and belief, Defendant Motorola Mobility LLC is a limited liability
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`company organized under the laws of the State of Delaware, with its principal office at 222 W.
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`Merchandise Mart Plaza, Suite 1800, Chicago, Illinois 60654.
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`JURISDICTION AND VENUE
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`5.
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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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`6.
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`This Court has personal jurisdiction over Defendants in this action because each
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`Defendant has committed acts within this District giving rise to this action and has established
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`minimum contacts with this forum such that the exercise of jurisdiction over Defendants would
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`not offend traditional notions of fair play and substantial justice. Defendants, directly and through
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`subsidiaries or intermediaries, have each committed and continues to commit acts of infringement
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`in this District by, among other things, importing, offering to sell, and selling products that infringe
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`the asserted patents.
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`7.
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`Venue is proper in this District under 28 U.S.C. §1400 (b). Defendant Motorola
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`Mobility LLC is registered to do business in Texas, and upon information and belief, has transacted
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`business in this District and has committed acts of direct and indirect infringement in this District
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`by, among other things, importing, offering to sell, and selling products that infringe the asserted
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`2
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`Case 6:22-cv-00029-ADA Document 1 Filed 01/07/22 Page 3 of 5
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`
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`patents. On information and belief, Defendant Lenovo Group Ltd. has also committed such acts of
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`direct and indirect infringement, on its own and through its subsidiary Motorola Mobility LLC.
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`On information and belief, Motorola Mobility LLC has regular and established places of business
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`in the District, as evidenced by its job listing for an “Android Software Developer” position in
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`Austin, TX. See Exhibit 1.
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`COUNT I
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`INFRINGEMENT OF U.S. PATENT NO. 6,874,014
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`8.
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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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`9.
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`Plaintiff owns by assignment all rights, title, and interest in U.S. Patent No.
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`6,874,014, entitled “Chip Multiprocessor with Multiple Operating Systems.” The ’014 Patent was
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`duly and legally issued by the United States Patent and Trademark Office on March 29, 2005. A
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`true and correct copy of the ’014 Patent is attached as Exhibit 2.
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`10.
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`On information and belief, Defendants make, use, offer for sale, sell, and/or import
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`certain products and services, including without limitation mobile phones with Qualcomm
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`Snapdragon SoCs containing at least one Hexagon DSP, including without limitation the Motorola
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`Edge (“Accused Products”), that directly infringe, literally and/or under the doctrine of equivalents,
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`one or more claims of the ’014 Patent.
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`11.
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`The Accused Products satisfy all claim limitations of one or more claims of the
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`’014 Patent. A claim chart comparing exemplary independent claim 1 of the ’014 Patent to
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`representative Accused Products is attached as Exhibit 3 and incorporated by reference herein.
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`3
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`Case 6:22-cv-00029-ADA Document 1 Filed 01/07/22 Page 4 of 5
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`12.
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`By making, using, offering for sale, selling and/or importing into the United States
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`the Accused Products, Defendants have injured Plaintiff and is liable for infringement of the ’014
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`Patent pursuant to 35 U.S.C. § 271.
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`13.
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`As a result of Defendants’ infringement of the ’014 Patent, Plaintiff is entitled to
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`monetary damages in an amount adequate to compensate for Defendants’ infringement, but in no
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`event less than a reasonable royalty for the use made of the invention by Defendant, together with
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`interest and costs as fixed by the Court.
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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 each Defendant has infringed, either literally
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`and/or under the doctrine of equivalents, the ’014 Patent;
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`b.
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`A judgment and order requiring each Defendant, jointly and severally, to pay
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`Plaintiff its damages, costs, expenses, and pre-judgment and post-judgment interest for Defendants’
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`infringement of the ’014 Patent; and
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`d.
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`A judgment and order requiring each Defendant, jointly and severally, to provide
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`an accounting and to pay supplemental damages to Plaintiff, including without limitation, pre-
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`judgment and post-judgment interest;
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`e.
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`A judgment and order finding that this is an exceptional case within the meaning
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`of 35 U.S.C. § 285 and awarding to Plaintiff its reasonable attorneys’ fees against Defendants,
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`jointly and severally; and
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`f.
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`Any and all other relief as the Court may deem appropriate and just under the
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`circumstances.
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`4
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`Case 6:22-cv-00029-ADA Document 1 Filed 01/07/22 Page 5 of 5
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`DEMAND FOR JURY TRIAL
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`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: January 7, 2022
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`Respectfully submitted,
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`/s/ Reza Mirzaie
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`Reza Mirzaie (CA SBN 246953)
`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 281213)
`jmilkey@raklaw.com
`Amy Hayden (CA SBN 287026)
`ahayden@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
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`5
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