On January 24, 2017, Advanced Micro Devices, Inc. of Sunnyvale, California and ATI Technologies ULC of Canada (collectively, “AMD”) filed a complaint requesting that the ITC commence an investigation pursuant to Section 337.
The complaint alleges that the following entities (collectively, the “Proposed Respondents”) unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain graphics systems, components thereof, and consumer products containing the same that infringe one or more claims of U.S. Patent Nos. 7,633,506 (the ’506 patent), 7,796,133 (the ’133 patent) and 8,760,454 (the ’454 patent) (collectively, the “asserted patents”):
- LG Electronics, Inc. of South Korea
- LG Electronics U.S.A., Inc. of Englewood Cliffs, New Jersey
- LG Electronics MobileComm U.S.A., Inc. of San Diego, California
- VIZIO, Inc. of Irvine, California
- MediaTek Inc. of Taiwan
- MediaTek USA Inc. of San Jose, California
- Sigma Designs, Inc. of Fremont, California
According to the complaint, the asserted patents generally relate to architectures for graphics processing unit (GPU) circuitry. In particular, the ’506 patent relates to a graphics processing architecture that enables a large amount of graphics data to be rendered to a frame buffer. The ’133 patent relates to specialized “texture” processing circuitry that is employed by GPUs. Lastly, the ’454 patent relates to a “unified shader” hardware architecture for GPUs.
In the complaint, AMD states that the Proposed Respondents import and sell products that infringe the asserted patents. The complaint specifically refers to various televisions and smartphones—and graphics processing systems within those televisions and smartphones—as infringing products.
Regarding domestic industry, AMD states that it and its manufacturing supplier, GlobalFoundries, have made significant and substantial investments in the U.S. relating to graphics systems, components thereof, and products containing same that practice claims of the asserted patents. AMD specifically refers to multiple facilities in the U.S. where AMD conducts activities relating to, among other things, research, development, and technical support in connection with products that practice the asserted patents. AMD also states that GlobalFoundries owns and operates semiconductor fabrication facilities in New York and that AMD is working with GlobalFoundries to manufacture products in the U.S. that practice the asserted patents. AMD further states that its licensees Samsung Electronics and Samsung Austin Semiconductor LLC have made investments in the U.S. relating to products that practice the asserted patents.
As to related litigation, AMD states that it is currently asserting a patent related to the asserted patents against LG Electronics, Inc. and others in the U.S. District Court for the Northern District of California. AMD also states that patents related to the asserted patents have been the subject of inter partes review (IPR) proceedings at the U.S. Patent and Trademark Office. AMD further states that it recently filed complaints against some of the Proposed Respondents in the U.S. District Court for the District of Delaware, asserting infringement of the asserted patents.
With respect to potential remedy, AMD requests that the Commission issue a limited exclusion order and permanent cease and desist orders directed at the domestic Proposed Respondents.