Crucial 2013 Annual Report Download - page 28

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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 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, including Elpida Memory, Inc.
and Elpida Memory (USA) Inc. (collectively “Elpida”). The complaint alleges that certain of our DRAM and image sensor
products infringe two U.S. patents and that certain Elpida DRAM products infringe two U.S. patents and seeks damages,
attorneys' fees, and costs. On March 23, 2012, Elpida filed a Notice of Filing and Hearing on Petition Under Chapter 15 of the
U.S. Bankruptcy Code and Issuance of Provisional Relief that included an order of the U.S. Bankruptcy Court for the District
of Delaware staying judicial proceedings against Elpida. Accordingly, the plaintiffs’ case against Elpida is stayed. On August
21, 2013, the Court granted a motion by the plaintiffs to amend the complaint to assert two additional patents against us and
one additional patent against Elpida.
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 alleged that certain of our DRAM products infringed two U.S. patents and
sought injunctive relief, damages, attorneys' fees, and costs. On March 20, 2013, we executed a settlement agreement resolving
this litigation. The settlement amount did not have a material effect on our business, results of operations or financial
condition.
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 alleged that certain of our
NOR Flash products infringed a single U.S. patent and sought injunctive relief, damages, attorneys' fees, and costs. On March
20, 2013, we executed a settlement agreement resolving this litigation. The settlement amount did not have a material effect on
our business, results of operations or financial condition.
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. We have filed three petitions
for inter-partes review by the Patent and Trademark Office, challenging the validity of each of the patents in suit. The District
Court has stayed the litigation pending the outcome of the inter-partes review by the Patent Office.
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 alleged that certain of our DRAM products infringed five U.S.
patents and sought injunctive relief, damages, attorneys' fees, and costs. On March 20, 2013, we executed a settlement
agreement resolving this litigation. The settlement amount did not have a material effect on our business, results of operations
or financial condition.
On April 27, 2012, Semcon Tech, LLC filed a patent infringement action against us in the U.S. District Court for the
District of Delaware. The complaint alleges that our use of various chemical mechanical planarization systems purchased from
Applied Materials and others infringes a single U.S. patent and seeks injunctive relief, damages, attorneys' fees, and costs. On
September 24, 2013, the Court entered an order staying our case pending the resolution of co-pending cases brought by Semcon
Tech, LLC against Applied Materials and Ebara Technologies, Inc.