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ZiiLabs (Formerly 3DLabs) Sues Apple & Samsung for Patent Infringement

50. Patently Legal
Today, ZiiLabs Inc., Ltd. (formerly known as 3DLabs Inc., Ltd) announced that it has filed a patent infringement lawsuit against Samsung and Apple. The lawsuit alleges that certain products of Samsung (including various Galaxy phones and tablets, and laptops) and Apple (including various ranges of the iPhone and iPad, iMac and MacBook Pro) infringe a number of ZiiLabs patents.

 

ZiiLabs owns over 100 US patents in the graphics, processor and 3D spaces. Ten of these patents have been asserted in the lawsuit, in which ZiiLabs is claiming past and future damages for patent infringement, and injunctions against Samsung and Apple.

 

Specifically, the court document lists the following as defendants in this patent infringement lawsuit as being: Samsung Electronics Co. Ltd., Samsung Electronics America, LLC, Samsung Telecommunications America, LLC, Samsung Austin Semiconductor, LLC, and Apple Inc. (collectively "Defendants").

 

Infringement of Patent 5,831,637

 

Two of the patents noted in this report cover the products that are allegedly infringing upon ZiiLabs' patents. These products are then repeated in one form or another in the remaining eight counts brought against Samsung and Apple. The first patent is US patent number 5,831,637 noted below as being a former "Intergraph Corporation" invention.

  2. ZiiLabs sues apple, samsung over 10 patents

 

The court document reads that "Samsung has directly infringed and continues to directly infringe one or more of the claims of the '637 Patent by its manufacture and sale of the Apple A4, A5, A6, A6X, and A7 SoCs with graphics processing systems, which on information and belief are incorporated into the Phone 4S, iPhone 5, iPhone 5C, iPhone 5S, Apple TV 3rd Generation, iPod Nano 7th Generation, iPad Air, iPad Mini 2nd Generation, iPad Mini 1st Generation, iPad 2, iPod Touch 5th Generation, iPod Touch 4th Generation, and all other similar devices. In addition, Samsung has directly infringed and continues to directly infringe one or more claims of the '637 Patent by its manufacture, use, sale, importation, and/or offer to sell its infringing phones, tablets, and other products, including but not limited to the Galaxy Metrix 4G, Galaxy S Relay 4G, Galaxy Legend, Galaxy Stratosphere II, Galaxy Axiom, Galaxy Stellar, Galaxy Admire 2, Galaxy Express, Galaxy Express GoPhone, ATIV Odyssey, Galaxy Rugby Pro, Galaxy Victory 4G LTE, ATIV S Neo, Galaxy Mega, Galaxy S Aviator, Galaxy S Lightray, Galaxy Nexus, Galaxy S3, Galaxy S3 mini, Galaxy S4, Galaxy S4 mini, Galaxy Note 2, Galaxy Note 3, Galaxy Note 10.1, Galaxy Note Pro, Galaxy Tab 2, Galaxy Tab 3, Galaxy Tab 7.0, Galaxy Tab Pro, and all other similar devices."

 

The court document reads that "Apple has directly infringed and continues to directly infringe one or more of the claims of the '637 Patent by its manufacture, use, sale, importation, and/or offer to sell its infringing phones, tablets, and computers, including but not limited to the iPhone 4S, iPhone 5, iPhone 5C, iPhone 5S, Apple TV 3rd Generation, iPod Nano 7th Generation, iPad Air, iPad Mini 2nd Generation, iPad Mini 1st Generation, iPad 2, iPod Touch 5th Generation, iPod Touch 4th Generation, and all other similar devices."

 

Infringement of Patent 6,111,584

 

In respect to patent 6,111,584, ZiiLabs lists new products that are allegedly infringing upon this patent. The ones that stand out are Apple's Mac products with Intel Core processors (iMac, MacBook and Mac Pro). Equally, Samsung products allegedly infringing this patent would include the Chromebook, Chromebook 3G and ATIV Book lineup.

 

3. ZiiLabs sues Apple & Samsung over ten patents

Defendant's Prior Knowledge of the Patent-in-Suit

 

In respect to Samsung: Samsung has had communications and contact with ZiiLabs and is fully aware of ZiiLabs' technology and patent portfolio, including the Patents-in-suit. For example, on August 7, 2013, ZiiLabs notified Samsung of its portfolio and its applicability to Samsung's products. In particular, ZiiLabs informed Samsung that its portfolio may be applicable to a variety of Samsung products, including "various Phones," "various Tablets," and "various laptops."

 

Since at least August 2013, Samsung and ZiiLabs have had continuing communications about the ZiiLabs patent portfolio, including the Patents-in-suit. During that time, Samsung has proceeded to infringe the Patents-in-suit with full and complete knowledge of the patents and their applicability to its products without taking a license under the Patents-in-suit and without a good faith belief that the Patents-in-suit were invalid or not infringed. Thus, Samsung's infringement of the Patents-in-suit is willful and deliberate …"

 

In Respect to Apple: ZiiLabs' predecessor-in-interest 3DLabs Inc., Ltd ("3DLabs") had various meetings with Apple as early as 2006 and 2007, including discussion of the patent portfolio that encompasses the Patents-in-Suit. For example, in December 2006, Apple met with executives from 3DLabs pursuant to a non-disclosure agreement. 3DLabs disclosed to Apple executives information about its media processor technology and intellectual property. The parties met again in January 2007, at which time 3DLabs presented its media processor programming model. On September 5, 2007, 3DLabs executives met again in person with Apple employees and discussed 3DLabs' media processor technology and roadmap.

 

Apple has had further communications and contact with ZiiLabs and is fully aware of ZiiLabs' technology and patent portfolio, including the Patents-in-suit. For example, on August 7, 2013, ZiiLabs notified Apple of its portfolio and its applicability to Apple's products.

 

In particular, ZiiLabs informed Apple that its portfolio may be applicable to a variety of Apple products, including "various iPhones," "various iPads," and "various MacBooks."

 

Since at least August 2013, Apple and ZiiLabs have had continuing communications about the ZiiLabs patent portfolio, including the Patents-in-suit. During that time, Apple has proceeded to infringe the Patents-in-suit with full and complete knowledge of the patents and their applicability to its products without taking a license under the Patents-in-suit and without a good faith belief that the Patents-in-suit are invalid or not infringed. Thus, Apple's infringement of the Patents-in-suit is willful and deliberate …"

 

ZiiLabs' Ten Patents-in-Suit

 

1 - 5,831,637 titled "Video Stream Data Mixing for 3D Graphics Systems"

2 - 5,835,096 titled "Rendering System Using 3D Texture-Processing Hardware for Accelerated 2D Rendering"

3 - 6,111,584 titled "Rendering System with Mini-Patch Retrieval from Local Texture Storage"

4 - 6,650,333 titled "Multi-Pool Texture Memory Management"

5 - 6,683,615 titled "Doubly-Virtualized Texture Memory"

6 - 6,977,649 titled "3D Graphics Rendering with Selective Read Suspend"

7 - 7,050,061 titled "Autonomous Address Translation in Graphic Subsystem

8 - 7,187,383 titled "Yield Enhancement of Complex Chips"

9 - 7,710,425 titled "Graphic Memory Management with Invisible Hardware-Managed Page Faulting"

10 - 8,144,156 titled "Sequencer with Async SIMD Array"

 

Some may find it interesting to note some of ZiiLabs' corporate milestones in respect to their processor technology.

 

  3. ZiiLabs logo

 

The patent infringement case presented in today's report was filed in the Texas Eastern District Court, Marshall Office. At present, no Judge has been assigned to the case.

 

130. PA - Bar - Notice

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