Technology licensing company Rambus Inc. today announced it has
filed a complaint with the United States International Trade
Commission (ITC) requesting the commencement of an investigation pertaining to products from Broadcom Corporation, Freescale Semiconductor, Inc., LSI Corporation, MediaTek Inc., NVIDIA
Corporation and STMicroelectronics N. V.
The complaint seeks an exclusion order barring the importation,
sale for importation, or sale after importation of products from
Broadcom, Freescale, LSI, NVIDIA and STMicroelectronics that
infringe certain patents from the Dally family of patents and of
products from Broadcom, Freescale, LSI, MediaTek and
STMicroelectronics that infringe certain patents from the Barth
family of patents.
Rambus is the exclusive licensee for the Dally family of patents
which are owned by Massachusetts Institute of Technology. This
license was assigned to Rambus as a part of its 2003 acquisition
of technology and IP from Velio Communications, a company founded
by Dr. William Dally.
In an earlier investigation requested by Rambus, the ITC found
that these same Barth patents were valid and infringed by NVIDIA
products, and issued an exclusion order in July of this year.
"We have been attempting to license these companies for some time
to no avail. One of the respondents frankly told us that the only
way they would get serious is if we sued them. Others pursued a
strategy of delay rather than negotiate a reasonable resolution,"
said Harold Hughes, president and chief executive officer at
Rambus. "Rambus has invested hundreds of millions of dollars
developing a portfolio of technologies that are foundational for
many digital electronics. There is widespread knowledge within
the industry about our patents including their use in
standards-compatible products accused in these actions. In
fairness to our shareholders and to our paying licensees, we take
these steps to protect our patented innovations and pursue fair
compensation for their use."
For the Dally patents, the accused semiconductor products from
these companies include ones that incorporate PCI Express,
certain Serial ATA, certain Serial Attached SCSI (SAS), and
DisplayPort interfaces. In the case of the Barth patents, the
accused semiconductor products include ones that incorporate DDR,
DDR2, DDR3, mobile DDR, LPDDR, LPDDR2, and GDDR3 memory
controllers. Accused semiconductor products in the complaint
include graphics processors, media processors, communications
processors, chip sets and other logic integrated circuits (ICs).
In addition to Broadcom, Freescale, LSI, MediaTek, NVIDIA and
STMicroelectronics, the ITC complaint names companies whose
products incorporate the accused semiconductor products and are
imported, sold for importation, or sold after importation into
the United States. These products include personal computers,
workstations, servers, routers, mobile phones and other handheld
devices, set-top boxes, Blu-ray players, motherboards, plug-in
cards, hard drives and modems. The ITC is expected to decide
whether to initiate an investigation under this complaint within
Rambus today also filed separate actions for patent infringement
against Broadcom, Freescale, LSI, MediaTek and STMicroelectronics
in the United States District Court for the Northern District of
California. The lawsuits allege that semiconductor products with
certain memory controllers and/or serial links from the above
companies infringe certain patents from the Farmwald-Horowitz,
Barth, and Dally patent families. In the case of MediaTek, only
infringement of the Barth and Farmwald-Horowitz patents for
certain memory controllers is alleged. Rambus also filed an
action in the United States District Court for the Northern
District of California against NVIDIA for infringement of certain
Dally patents. The categories of accused semiconductor products
in the District Court complaints include the same categories
accused in the ITC complaint, as well as SDR memory controllers.
Rambus is seeking injunctive relief barring the infringement,
contributory infringement, and inducement to infringe the
patents, as well as monetary damages.