Crucial 2012 Annual Report Download - page 23

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A number of other suits involving Rambus are currently pending in Europe alleging that certain of our SDRAM and DDR
SDRAM products infringe various of Rambus' country counterparts to its European patent 525 068, including: on September 1,
2000, Rambus filed suit against Micron Semiconductor (Deutschland) GmbH in the District Court of Mannheim, Germany; on
September 22, 2000, Rambus filed a complaint against us and Reptronic (a distributor of our products) in the Court of First
Instance of Paris, France; on September 29, 2000, we filed suit against Rambus in the Civil Court of Milan, Italy, alleging
invalidity and non-infringement. In addition, on December 29, 2000, we filed suit against Rambus in the Civil Court of
Avezzano, Italy, alleging invalidity and non-infringement of the Italian counterpart to European patent 1 004 956. Additionally,
on August 14, 2001, Rambus filed suit against Micron Semiconductor (Deutschland) GmbH in the District Court of Mannheim,
Germany alleging that certain of our DDR SDRAM products infringe Rambus' country counterparts to its European patent 1
022 642. In the European suits against us, Rambus is seeking monetary damages and injunctive relief. Subsequent to the filing
of the various European suits, the European Patent Office (the "EPO") declared Rambus' 525 068, 1 022 642, and 1 004 956
European patents invalid and revoked the patents. The declaration of invalidity with respect to the '068 and '642 patents was
upheld on appeal. The original claims of the '956 patent also were declared invalid on appeal, but the EPO ultimately granted a
Rambus request to amend the claims by adding a number of limitations.
On March 6, 2009, Panavision Imaging, LLC ("Panavision") filed suit against us and Aptina Imaging Corporation, then a
wholly-owned subsidiary, in the U.S. District Court for the Central District of California. The complaint alleged that certain of
our and Aptina's image sensor products infringed four Panavision U.S. patents and sought injunctive relief, damages, attorneys'
fees, and costs. On February 7, 2011, the Court ruled that one of the four patents in suit was invalid for indefiniteness. On
March 10, 2011, claims relating to the remaining three patents in suit were dismissed with prejudice. Panavision subsequently
filed a motion for reconsideration of the Court's decision regarding invalidity of the first patent, and we filed a motion for
summary judgment of non-infringement of such patent. On July 8, 2011, the Court issued an order that rescinded its prior
indefiniteness decision, and held that the disputed term does not render the claims in suit indefinite. On February 3, 2012, the
Court granted our motion for summary judgment of non-infringement. On March 20, 2012, we executed a settlement
agreement with Panavision pursuant to which the parties agreed to a settlement and release of all claims and a dismissal with
prejudice of the litigation, which did not have a material effect on our business, results of operations or financial condition.
On September 1, 2011, HSM Portfolio LLC and Technology Properties Limited LLC filed a patent infringement action in
the U.S. District Court for the District of Delaware against us and seventeen other defendants. The complaint alleges that
certain of our DRAM and image sensor products infringe two U.S. patents and seeks injunctive relief, damages, attorneys' fees,
and costs.
On September 9, 2011, Advanced Data Access LLC filed a patent infringement action in the U.S. District Court for the
Eastern District of Texas (Tyler) against us and seven other defendants. On November 16, 2011, Advanced Data Access filed
an amended complaint. The amended complaint alleges that certain of our DRAM products infringe two U.S. patents and seeks
injunctive relief, damages, attorneys' fees, and costs.
On September 14, 2011, Smart Memory Solutions LLC filed a patent infringement action in the U.S. District Court for the
District of Delaware against us and Winbond Electronics Corporation of America. The complaint alleges that certain of our
NOR Flash products infringe a single U.S. patent and seeks injunctive relief, damages, attorneys' fees, and costs.
On December 5, 2011, the Board of Trustees for the University of Illinois filed a patent infringement action against us in
the U.S. District Court for the Central District of Illinois. The complaint alleges that unspecified semiconductor products of
ours infringe three U.S. patents and seeks injunctive relief, damages, attorneys' fees, and costs.
On March 26, 2012, Semiconductor Technologies, LLC filed a patent infringement action in the U.S. District Court for the
Eastern District of Texas (Marshall) against us. The complaint alleges that certain of our DRAM products infringe five U.S.
patents and seeks injunctive relief, damages, attorneys' fees, and costs.
On March 28, 2012, Technology Partners Limited LLC (“TPL”) filed a patent infringement action in the U.S. District
Court for the Eastern District of Texas (Tyler) against us. The complaint alleges that certain of our Lexar flash card readers
infringe four U.S. patents and seeks injunctive relief, damages, attorneys' fees, and costs. On March 26, 2012, TPL filed a
parallel complaint with the U.S. International Trade Commission under Section 337 of the Tariff Act of 1930 against us and
numerous other companies alleging infringement of the same patents and seeking an exclusion order preventing the importation
of certain flash card readers. The District Court action has been stayed pending the outcome of the ITC matter. The ITC matter
was scheduled for trial on January 7, 2013. On October 8, 2012, we executed a settlement agreement with TPL pursuant to
which the parties agreed to a settlement and release of all claims and a dismissal with prejudice of the litigation, which did not
have a material effect on our business, results of operations or financial condition.