Viavi Solutions Inc. v. Platinum Optics Technology Inc.

I. BACKGROUND

19 Plaintiff Viavi Solutions, Inc. (“Viavi”) is a U.S.-based company that designs low angle 20 shift (“LAS”) optical filters using hydrogenated silicon for 3D motion sensing. Compl., ECF No. 21 1 ¶¶ 3, 5, 8. It holds various patents associated with this technology, including U.S. Patent Nos. 22 9,354,369 (“the ’369 patent”), 9,588,269 “(the ’269 patent”), 10,222,526 (“the ’526 patent”), and 23 9,945,995 (“the ’995 patent”) (collectively, the “Asserted Patents”). Id. ¶ 4. Viavi alleges that 24 suppliers to electronic device manufacturers incorporate these LAS patented filter designs into 25 their optical filters, which, in turn, are used to produce sensing systems in mobile phones and 26 tablets that use facial and gesture recognition technology produced by third-party companies. Id. 27 Case No.: 5:20-cv-05501-EJD ¶¶ 10, 13. Defendant Platinum Optics Technology, Inc. (“PTOT”) is a Taiwan-based company. Id. ¶ 19. PTOT manufactures optical filters that employ hydrogenated silicon allegedly using patented technology. Id. ¶ 10. Viavi alleges that PTOT supplies “at least one low angle shift optical filters, the PTOT “11246” optical…