Viavi Solutions Inc. v. Platinum Optics Technology Inc.

I. BACKGROUND

17 Plaintiff Viavi Solutions Inc. (“Viavi”) is a U.S.-based company headquartered in 18 Delaware that designs optical filters using hydrogenated silicon for 3D motion sensing. First Am. 19 Compl. (“FAC”), ECF No. 21 ¶¶ 4, 19. It holds various patents associated with this technology. 20 Id. ¶¶ 3, 5. Suppliers to electronic device manufacturers incorporate these patented filter designs 21 into their optical filters, which are, in turn, used to produce sensing systems in mobile phones and 22 tablets that use facial and gesture recognition technology. Id. ¶ 10. Viavi is purportedly “the 23 industry’s leading supplier of high-performance filters for motion sensing systems in consumer 24 electronics.” Id. ¶ 9. 25 Defendant Platinum Optics Technology Inc. (“PTOT”) is a Taiwan-based company that 26 manufactures optical filters that employ hydrogenated silicon, which allegedly utilizes Viavi’s 27 patented technology. Id. ¶¶ 12, 20. PTOT represents that it is “one of the few manufacturers” that provide optical filters for 3D motion sensing modules to electronic device manufacturers. Id. ¶ 13. Viavi alleges that since May 1, 2020, PTOT has been making and…