MicroUnity Systems Engineering, Inc.

MicroUnity was founded in 1988 by microprocessor technology veterans from MIPS, IBM, HP, Intel, Berkeley, Columbia, and Stanford. With seed funding from W.R. Hearst III and John Moussouris, the company aimed to extend microprocessors beyond their historical role as calculating and control devices, to make them the primary media-processing engines of televisions, set-top boxes, mobile computers, cellphones, and other digital communications devices.

Many competing technologies for processing digital media have been introduced in various products over the past two decades. MicroUnity's methods are the ones actually used in the microprocessors of more than a billion PCs, laptops, set-tops, and mobile devices to execute software for playing movies, music, videogames, and many broadband internet applications.

For more on MicroUnity, visit their website here.

The Case Specific to Apple

MicroUnity is informed and believes, and on that basis alleges, that Defendant Apple, Inc. ("Apple") is a corporation duly organized and existing under the laws of the state of California, with its principal place of business at 1 Infinite Loop, Cupertino, CA 95014; that Apple manufactures and sells products such as the iPhone 3GS cell phone and iPod Touch 32 and 64GB ("iPod Touch 3G") and provides software for such products; and that such cell phones and other products and software are used, offered for sale and sold in this district and throughout the United States and imported into the United States by Apple.

Apple infringed (along with all 22 companies) and continues to infringe one or more of the claims of the following patents:

• 5,737,547
• 5,794,061
• 6,006,318
• 6,725,356
• 7,216,217
• 7,260,708
• 7,353,367
• 7,509,366
• 7,653,806
• 7,660,972
• 7,660,973

JURY DEMAND

115. MicroUnity demands a trial by jury on all issues.

PRAYER FOR RELIEF

'WHEREFORE, Plaintiff MicroUnity Systems Engineering, Inc., requests entry of judgment in its favor and against defendants as follows:

a) Declaration that defendants have infringed U.S. Patent Nos. 5,737,547 Cl, 5,742,840, 5,794,061 Cl, 5,812,799 Cl, 6,006,318 Cl, R839,500 E, 6,725,356 Cl,7,2r3,r3lB.2, 7,216,217 82, 7,260,708 P¡2, 7,353,367 B.2, 7,509,366 82, 7,653,806 F.2, 7,660,972 B2 and 7,660,973 B2;

b) Awarding the damages arising out of defendants' infringement of U.S. Patent Nos. 5,737,547 Cl, 5,742,840, 5,794,061 Cl, 5,812,799 Cl, 6,006,318 Cl, R839,500 E, 6,725,356 Cr, 7,2r3,r31F'2,7,216,217 B,2,7,260,708B'2,7,353,367 82,1,509,366 B.2,7,653,806 B.2,7,660,972 B2 and 7,660,973 82, including enhanced damages pursuant to 35 U.S.C. $ 284, to MicroUnity, together with prejudgment and post-judgment interest, in an amount according to proof;

c) Permanently enjoining defendants and their respective officers, agents, employees, and those acting in privity with them, from further infringement, including contributory infringement and/or inducing infringement, of U.S. Patent Nos. 5,737,547 CI,5,742,840, 5,794,061 CL,5,812,799 CL,6,006,318 Cl, RE39,500F,6,725,356 Cr,7,2r3,l3r B.2,7,216,217 82,7,260,708 82, 7,353,367 B.2,7,509,366 B.2,7,653,806B.2,7,660,97282 and7,660,973 B.2, or in the alternative, a post-judgment royalty for post-judgment infringement;

d) An award of attorney's fees pursuant to 35 U.S.C. $ 285 or as otherwise permitted by law; and

e) For such other costs and further relief as the Court may deem just and proper.

DATED: March 16"2010

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