HD Silicon Solutions LLC v. Microchip Technology Inc.

I. FACTUAL BACKGROUND

Plaintiff HDSS filed this lawsuit accusing Microchip of infringing U.S. Patent Nos. 7,260,731 (the “’731 Patent”); 7,870,404 (the “’404 Patent”); 7,810,002 (the “’002 Patent”); 6,748,577 (the “’577 Patent”); 7,154,299 (the “’299 Patent”); 7,302,619 (the “’619 Patent”); and 6,774,033 (the “’033 Patent”) (collectively, the “Asserted Patents”). HDSS also identifies the following products in its Complaint: Microchip’s PIC24 family of microcontrollers with eXtreme Low- Power or XLP technology (ECF No. 1 ¶¶ 16, 31); Microchip’s PIC32MZ DA, PIC 32MZ EF, and PIC32MK microcontrollers (ECF No. 1 ¶ 109); Microsemi PolarFire FPGAs (ECF No. 1, ¶¶ 91, 127); and SAM L11 microcontrollers with ARM TrustZone technology (ECF No. 1 ¶ 52) (collectively, the “Accused Products”). Plaintiff HDSS is a limited liability company organized and existing under the laws of the State of Texas, with a principal place of business in the Southern District of California. ECF No. 29 at 1. HDSS is managed by Fahim Aftab, who resides in and conducts HDSS’s business from

the Southern District of California. Id. Defendant Microchip is a Delaware corporation with its headquarters …