IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION MARVELL SEMICONDUCTOR, INC.

; MARVELL INTERNATIONAL LTD.; MARVELL WORLD TRADE LTD., Plaintiffs, v. FREESCALE SEMICONDUCTOR, INC., Defendant.

CIVIL ACTION NO. 1:13-CV-_________ 5 JURY TRIAL DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT Plaintiffs Marvell Semiconductor, Inc., Marvell International Ltd., and Marvell World Trade Ltd. (together, Marvell) hereby file this Complaint against Defendant Freescale Semiconductor, Inc. (Freescale) for infringement of U.S. Patent Nos. 6,903,448 (the 448 Patent); 7,216,276 (the 276(I) Patent); 7,379,718 B2 (the 718 Patent); 7,444,571 (the 571 Patent); 7,496,818 (the 818 Patent); 7,562,276 (the 276(II) Patent); and 7,573,249 B2 (the 249 Patent) (collectively, Patents-In-Suit). PARTIES 1. Marvell Semiconductor, Inc. is a California Corporation with its principal place

of business at 5488 Marvell Lane, Santa Clara, California 95054. 2. Marvell International Ltd. is a Bermuda Corporation with its principal place of

business at Canon's Court, 22 Victoria Street, Hamilton HM 12, Bermuda. 3. Marvell World Trade Ltd. is a Barbados Corporation with its principal place of

business at LHorizon, Gunsite Road, Brittons Hill, BB14027, St. Michael, Barbados.

4.

Upon information and belief, Defendant is a corporation organized under the

laws of Delaware, and maintains its principal place of business at 6501 William Cannon Drive West, Austin, Texas 78721. JURISDICTION AND VENUE 5. This lawsuit is an action for patent infringement arising under the patent laws of

the United States, 35 U.S.C. 1, et seq. This Court has jurisdiction over this action pursuant to 28 U.S.C. 1331 and 1338. 6. Upon information and belief, Defendant is subject to personal jurisdiction in

this Court because it does and has done substantial business in this judicial district, including: (i) maintaining its principal place of business in this judicial district; (ii) employing numerous employees in this judicial district; (iii) designating an agent for service of process in this judicial district; (iv) regularly receiving shipments of infringing display devices within this judicial district; (v) committing acts of patent infringement and/or contributing to or inducing acts of patent infringement by others in this judicial district and elsewhere in Texas and the United States; and (vi) regularly doing business or soliciting business, engaging in other persistent courses of conduct, and/or deriving substantial revenue from products and/or services provided to individuals in this judicial district and in this State. 7. Venue is proper in this judicial district pursuant to 28 U.S.C. 1391 and

1400(b) because Defendant regularly conducts business in this judicial district, has regular and established places of business in this judicial district, and/or because certain of the acts complained of herein occurred in this judicial district.

U.S. PATENT NO. 6,903,448 8. On June 7, 2005, the United States Patent and Trademark Office duly and

legally issued the 448 Patent, High Performance Leadframe in Electronic Package, to Sehat Sutardja, Vincent Kao, and Hendrick Santo. A true and correct copy of the 448 Patent is attached as Exhibit 1. 9. Marvell International Ltd. is the sole owner and assignee of all right, title, and

interest in and to the 448 Patent and possesses all rights of recovery under the 448 Patent, including the right to recover damages for past infringements. 10. The 448 Patent is valid and enforceable. U.S. PATENT NO. 7,216,276 11. On May 8, 2007, the United States Patent and Trademark Office duly and

legally issued the 276(I) Patent, Apparatus and Method for Testing and Debugging an Integrated Circuit, to Saeed Azimi and Son Ho. A true and correct copy of the 276(I) Patent is attached as Exhibit 2. 12. Marvell International Ltd. is the sole owner and assignee of all right, title, and

interest in and to the 276(I) Patent and possesses all rights of recovery under the 276(I) Patent, including the right to recover damages for past infringements. 13. The 276(I) Patent is valid and enforceable. U.S. PATENT NO. 7,379,718 B2 14. On May 27, 2008, the United States Patent and Trademark Office duly and

legally issued the 718 Patent, Method and Apparatus to Manage Power Consumption of a Semiconductor Device, to Amit Dor, Charles Roth, and Mark Fullerton. A true and correct copy of the 718 Patent is attached as Exhibit 3.

15.

Marvell World Trade Ltd. is the sole owner and assignee of all right, title, and

interest in and to the 718 Patent and possesses all rights of recovery under the 718 Patent, including the right to recover damages for past infringements. 16. The 718 Patent is valid and enforceable. U.S. PATENT NO. 7,444,571 17. On October 28, 2008, the United States Patent and Trademark Office duly and

legally issued the 571 Patent, Apparatus and Method for Testing and Debugging an Integrated Circuit, to Saeed Azimi, Son Ho, and Daniel Smathers. A true and correct copy of the 571 Patent is attached as Exhibit 4. 18. Marvell International Ltd. is the sole owner and assignee of all right, title, and

interest in and to the 571 Patent and possesses all rights of recovery under the 571Patent, including the right to recover damages for past infringements. 19. The 571 Patent is valid and enforceable. U.S. PATENT NO. 7,496,818 20. On February 24, 2009, the United States Patent and Trademark Office duly and

legally issued the 818 Patent, Apparatus and Method for Testing and Debugging an Integrated Circuit, to Saeed Azimi, Son Ho, and Daniel Smathers. A true and correct copy of the 818 Patent is attached as Exhibit 5. 21. Marvell International Ltd. is the sole owner and assignee of all right, title, and

interest in and to the 818 Patent and possesses all rights of recovery under the 818 Patent, including the right to recover damages for past infringements. 22. The 818 Patent is valid and enforceable.

U.S. PATENT NO. 7,562,276 23. On July 14, 2009, the United States Patent and Trademark Office duly and

legally issued the 276(II) Patent, Apparatus and Method for Testing and Debugging an Integrated Circuit, to Saeed Azimi and Son Ho. A true and correct copy of the 276(II) Patent is attached as Exhibit 6. 24. Marvell International Ltd. is the sole owner and assignee of all right, title, and

interest in and to the 276(II) Patent and possesses all rights of recovery under the 276(II) Patent, including the right to recover damages for past infringements. 25. The 276(II) Patent is valid and enforceable. U.S. PATENT NO. 7,573,249 B2 26. On August 11, 2009, the United States Patent and Trademark Office duly and

legally issued the 249 Patent, Power Array System and Method, to Sehat Sutardja, Runsheng He, and Jiancheng Zhang. A true and correct copy of the 249 Patent is attached as Exhibit 7. 27. Marvell World Trade Ltd. is the sole owner and assignee of all right, title, and

interest in and to the 249 Patent and possesses all rights of recovery under the 249 Patent, including the right to recover damages for past infringements. 28. The 249 Patent is valid and enforceable. GENERAL ALLEGATIONS 29. Marvell re-alleges and incorporates herein the allegations of the preceding

paragraphs of this Complaint as if fully set forth herein. 30. Upon information and belief, Defendant makes, uses, sells, and offers to sell

within the United States, and/or imports into the United States one or more products, including

but not limited to certain integrated circuits and/or chipsets that practice each of the elements of one or more claims of the Patents-In-Suit, without license from Marvell, in the Western District of Texas and throughout the United States. Examples of those integrated circuits and/or chipsets include but are not limited to the Freescale MC34671, MC34672, MC34673, MC34674, MC34675, MC34676, MC34700, MC34704, MC34712, MC34713, MC34716, MC34717, MC34727, MC34848, MC34933, MCIMX233, MCIMX251, MCIMX253, MCIMX255, MCIMX257, MCIMX258, MCIMX27, MCIMX31, MCIMX35, MCIMX351, MCIMX353, MCIMX355, MCIMX356, MCIMX357, P4040, P4080, and Kinetis family. Marvell reserves its right to contend that additional Freescale products infringe the Patents-InSuit. 31. In addition, Freescale indirectly infringes the Patents-In-Suit. Freescale

contributorily infringes by selling or using its integrated circuits and/or chipsets, including those identified above, to distributors, consumers, and end-users to directly infringe the Patents-in-Suit by selling or using the Freescale integrated circuits and/or chipsets. Freescales marketing, sales, and customer support materials, which it makes publicly-available, describe and direct customers to use infringing features of its integrated circuits and/or chipsets in an infringing manner. For example, Freescales website provides customers and potential

customers with product data sheets, technical papers and other marketing materials for Freescales integrated circuits and/or chipsets that tout their infringing features and direct customers to use them in an infringing manner. On information and belief, Freescale also provides verbal and written instructions, including sales support and technical know-how, to its distributors and customers that intentionally aid, assist, and encourage infringement.

32.

Freescales integrated circuits and/or chipsets, which it sells directly to

consumers, assemblers as well as through its distribution partners, are designed to be used (and are used by said distributors, assemblers, consumers, and end-users) in an infringing manner. Additionally, on information and belief, Freescales integrated circuits and/or chipsets were especially designed, made, or adapted for use in an infringing manner. Freescales integrated circuits and/or chipsets either embody the claimed inventions on their own or are material, non-staple components of end-user products which embody the claimed inventions, which components have no substantial non-infringing uses. 33. Defendant's continuing acts of infringement are irreparably harming and

causing damage to Marvell. Marvell has no adequate remedy at law to redress Defendant's continuing acts of infringement. The hardships that would be imposed upon Defendant by an injunction are less than those faced by Marvell should an injunction not issue. Furthermore, the public interest would be served by issuance of an injunction. 34. Upon information and belief, Defendant has knowledge of the Patents-In-Suit,

at least since service of this Complaint, and has not ceased its infringing activities in light of such knowledge. Count One Infringement of U.S. Patent No. 6,903,448 35. forth herein. 36. Upon information and belief, Defendant has infringed and continues to infringe, This count incorporates by reference Paragraphs 1 through 34 as if fully set

has contributed to and continues to contribute to acts of infringement of the 448 Patent by making, using, offering for sale and selling in the United States, and by importing into the Western District of Texas and throughout the United States without authority, and/or by

causing others to make, use, offer for sale and sell in the United States, and import into the Western District of Texas and throughout United States without authority, integrated circuits and/or chipsets, for example the ones identified in paragraph 30. These integrated circuits and/or chipsets practice each of the elements of one or more claims of the 448 Patent, in that they are designed with lead frame packaging technology, including extended leads that are useful for multiple wire bonding and improved thermal and/or electrical properties output regulation and dynamic voltage management. 37. On information and belief, Defendants infringement and contributory

infringement is literal infringement or, in the alternative, infringement under the doctrine of equivalents. 38. Defendants infringing activities have caused and will continue to cause Marvell

irreparable harm, for which it has no adequate remedy at law, unless Freescales infringing activities are enjoined by this Court in accordance with 35 U.S.C. 283. 39. Marvell has been and continues to be damaged by Freescales infringement of

the 448 Patent in an amount to be determined at trial. Count Two Infringement of U.S. Patent No. 7,216,276 40. forth herein. 41. Upon information and belief, Defendant has infringed and continues to infringe, This count incorporates by reference Paragraphs 1 through 39 as if fully set

has contributed to and continues to contribute to acts of infringement of the 276(I) Patent by making, using, offering for sale and selling in the United States, and by importing into the Western District of Texas and throughout the United States without authority, and/or by causing others to make, use, offer for sale and sell in the United States, and import into the

Western District of Texas and throughout United States without authority, integrated circuits and/or chipsets, for example the ones identified in paragraph 30. These integrated circuits and/or chipsets practice each of the elements of one or more claims of the 276(I) Patent, in that they are designed with a serial/deserializer (SERDES) interface which is used for testing and/or debugging. 42. On information and belief, Defendants infringement and contributory

infringement is literal infringement or, in the alternative, infringement under the doctrine of equivalents. 43. Defendants infringing activities have caused and will continue to cause Marvell

irreparable harm, for which it has no adequate remedy at law, unless Freescales infringing activities are enjoined by this Court in accordance with 35 U.S.C. 283. 44. Marvell has been and continues to be damaged by Freescales infringement of

the 276(I) Patent in an amount to be determined at trial. Count Three Infringement of U.S. Patent No. 7,379,718 B2 45. forth herein. 46. Upon information and belief, Defendant has infringed and continues to infringe, This count incorporates by reference Paragraphs 1 through 44 as if fully set

has contributed to and continues to contribute to acts of infringement of the 718 Patent by making, using, offering for sale and selling in the United States, and by importing into the Western District of Texas and throughout the United States without authority, and/or by causing others to make, use, offer for sale and sell in the United States, and import into the Western District of Texas and throughout United States without authority, integrated circuits and/or chipsets, for example the ones identified in paragraph 30. These integrated circuits

and/or chipsets practice each of the elements of one or more claims of the 718 Patent, in that they are designed with power management features intended to provide high performance processing while minimizing power consumption, including the digital control of output regulation and dynamic voltage management. 47. On information and belief, Defendants infringement and contributory

infringement is literal infringement or, in the alternative, infringement under the doctrine of equivalents. 48. Defendants infringing activities have caused and will continue to cause Marvell

irreparable harm, for which it has no adequate remedy at law, unless Freescales infringing activities are enjoined by this Court in accordance with 35 U.S.C. 283. 49. Marvell has been and continues to be damaged by Freescales infringement of

the 718 Patent in an amount to be determined at trial. Count Four Infringement of U.S. Patent No. 7,444,571 50. forth herein. 51. Upon information and belief, Defendant has infringed and continues to infringe, This count incorporates by reference Paragraphs 1 through 49 as if fully set

has contributed to and continues to contribute to acts of infringement of the 571 Patent by making, using, offering for sale and selling in the United States, and by importing into the Western District of Texas and throughout the United States without authority, and/or by causing others to make, use, offer for sale and sell in the United States, and import into the Western District of Texas and throughout United States without authority, integrated circuits and/or chipsets, for example the ones identified in paragraph 30. These integrated circuits and/or chipsets practice each of the elements of one or more claims of the 571 Patent, in that

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they are designed with a serial/deserializer (SERDES) interface which is used for testing and/or debugging. 52. On information and belief, Defendants infringement and contributory

infringement is literal infringement or, in the alternative, infringement under the doctrine of equivalents. 53. Defendants infringing activities have caused and will continue to cause Marvell

irreparable harm, for which it has no adequate remedy at law, unless Freescales infringing activities are enjoined by this Court in accordance with 35 U.S.C. 283. 54. Marvell has been and continues to be damaged by Freescales infringement of

the 571 Patent in an amount to be determined at trial. Count Five Infringement of U.S. Patent No. 7,496,818 55. forth herein. 56. Upon information and belief, Defendant has infringed and continues to infringe, This count incorporates by reference Paragraphs 1 through 54 as if fully set

has contributed to and continues to contribute to acts of infringement of the 818 Patent by making, using, offering for sale and selling in the United States, and by importing into the Western District of Texas and throughout the United States without authority, and/or by causing others to make, use, offer for sale and sell in the United States, and import into the Western District of Texas and throughout United States without authority, integrated circuits and/or chipsets, for example the ones identified in paragraph 30. These integrated circuits and/or chipsets practice each of the elements of one or more claims of the 818 Patent, in that they are designed with a serial/deserializer (SERDES) interface which is used for testing and/or debugging.

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57.

On information and belief, Defendants infringement and contributory

infringement is literal infringement or, in the alternative, infringement under the doctrine of equivalents. 58. Defendants infringing activities have caused and will continue to cause Marvell

irreparable harm, for which it has no adequate remedy at law, unless Freescales infringing activities are enjoined by this Court in accordance with 35 U.S.C. 283. 59. Marvell has been and continues to be damaged by Freescales infringement of

the 818 Patent in an amount to be determined at trial. Count Six Infringement of U.S. Patent No. 7,562,276 60. forth herein. 61. Upon information and belief, Defendant has infringed and continues to infringe, This count incorporates by reference Paragraphs 1 through 59 as if fully set

has contributed to and continues to contribute to acts of infringement of the 276(II) Patent by making, using, offering for sale and selling in the United States, and by importing into the Western District of Texas and throughout the United States without authority, and/or by causing others to make, use, offer for sale and sell in the United States, and import into the Western District of Texas and throughout United States without authority, integrated circuits and/or chipsets, for example the ones identified in paragraph 30. These integrated circuits and/or chipsets practice each of the elements of one or more claims of the 276(II) Patent, in that they are designed with a serial/deserializer (SERDES) interface which is used for testing and/or debugging.

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62.

On information and belief, Defendants infringement and contributory

infringement is literal infringement or, in the alternative, infringement under the doctrine of equivalents. 63. Defendants infringing activities have caused and will continue to cause Marvell

irreparable harm, for which it has no adequate remedy at law, unless Freescales infringing activities are enjoined by this Court in accordance with 35 U.S.C. 283. 64. Marvell has been and continues to be damaged by Freescales infringement of

the 276(II) Patent in an amount to be determined at trial. Count Seven Infringement of U.S. Patent No. 7,573,249 B2 65. forth herein. 66. Upon information and belief, Defendant has infringed and continues to infringe, This count incorporates by reference Paragraphs 1 through 64 as if fully set

has contributed to and continues to contribute to acts of infringement of the 249 Patent by making, using, offering for sale and selling in the United States, and by importing into the Western District of Texas and throughout the United States without authority, and/or by causing others to make, use, offer for sale and sell in the United States, and import into the Western District of Texas and throughout United States without authority, integrated circuits and/or chipsets, for example the ones identified in paragraph 30. These integrated circuits and/or chipsets practice each of the elements of one or more claims of the 249 Patent, in that they are designed with power management features intended to provide high performance processing while minimizing power consumption, including the digital control of output regulation and dynamic voltage management.

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67.

On information and belief, Defendants infringement and contributory

infringement is literal infringement or, in the alternative, infringement under the doctrine of equivalents. 68. Defendants infringing activities have caused and will continue to cause Marvell

irreparable harm, for which it has no adequate remedy at law, unless Freescales infringing activities are enjoined by this Court in accordance with 35 U.S.C. 283. 69. Marvell has been and continues to be damaged by Freescales infringement of

the 249 Patent in an amount to be determined at trial. REQUEST FOR A JURY TRIAL 70. Marvell requests a jury trial of all issues in this action so triable. PRAYER FOR RELIEF WHEREFORE, Marvell prays for the following relief:

(a)

That Defendant be ordered to pay damages adequate to compensate

Marvell for Defendant's infringement of each of the Patents-In-Suit pursuant to 35 U.S.C. 284;

(b)

That Defendant be ordered to pay attorneys fees pursuant to 35 U.S.C.

285 for each of the Patents-In-Suit;

(c)

That Defendant, its officers, agents, servants, employees, and those

persons acting in active concert or in participation with them be enjoined from further infringement of each of the Patents-In-Suit pursuant to 35 U.S.C. 283;

(d) (e) (f)

That Defendant be ordered to pay prejudgment interest; That Defendant be ordered to pay all costs associated with this action; and That Marvell be granted such other and additional relief as the Court

deems just and proper.

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Dated: January 4, 2013

Respectfully submitted: By: /s/ B. Russell Horton B. Russell Horton State Bar No. 10014450 GEORGE BROTHERS KINCAID & HORTON, L.L.P. 114 W. 7th Street, Suite 1100 Austin, Texas 78701 (512) 495-1400 (512) 499-0094 facsimile
Email: rhorton@gbkh.com

Kevin P.B. Johnson (to be admitted pro hac vice) QUINN EMANUEL URQUHART & SULLIVAN, LLP 555 Twin Dolphin Drive, Suite 560 Redwood Shores, California 94065 Telephone:(650) 801-5000 Facsimile: (650) 801-5100 E-mail: kevinjohnson@quinnemanuel.com Sean S. Pak (to be admitted pro hac vice) Peter A. Klivans (to be admitted pro hac vice) James D. Judah (to be admitted pro hac vice) QUINN EMANUEL URQUHART & SULLIVAN, LLP 50 California Street, 22nd Floor San Francisco, California 94111 Telephone:(415) 875-6600 Facsimile: (415) 875-6700 E-mail: seanpak@quinnemanuel.com E-mail: jamesjudah@quinnemanuel.com ATTORNEYS FOR PLAINTIFFS MARVELL SEMICONDUCTOR, INC., MARVELL INTERNATIONAL LTD., AND MARVELL WORLD TRADE LTD.

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