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RICKY D. HANGARTNER,
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Plaintiff,
v.
INTEL CORPORATION
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Defendant.
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1.
This is a claim for patent infringement arising under the patent laws of the
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2.
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Corvallis, Oregon. Dr. Hangartner is the named inventor in, and owner of, U.S. Patent No.
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6,463,422 (the '422 Patent) issued October 8, 2002 and entitled Probabilistic Computing
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Methods and Apparatus (copy attached as Exhibit A). Dr. Hangartner owns all right, title,
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and interest in, and has standing to sue for infringement of U.S. Patent No. 6,463,422.
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3.
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Corporation having a principal place of business at 2200 Mission College Boulevard, Santa
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COMPLAINT - 1
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This is an action for patent infringement arising under the patent laws of the
United States of America, Title 35 U.S.C. This Court has jurisdiction over the subject matter
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Defendant Intel has done, and continues to do business in this district. Venue in this judicial
district is proper under 28 U.S.C. 1391(b), (c) and/or 1400(b) in that a substantial part of
the events giving rise to the patent infringement claims herein have taken place and may still
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probability and statistics. Utilizing his knowledge and experience, Dr. Hangartner conceived
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and developed a unique and highly effective way of generating truly random sequences of
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In 1994, shortly after receiving his doctorate, Dr. Hangartner applied for, and
later received, the '422 patent claiming various aspects of his original technology.
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wherein random numbers are generated as part of proposed solutions to computing problems.
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One key feature of the method and apparatus includes the generation of truly random numbers
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through use of a cross-coupled pair of transistor inverter circuits. When power is removed
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and reapplied, the circuit will assume one of two opposite states depending on intrinsic circuit
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noise. Because such noise is inherently random, the resulting circuit state is, itself, inherently
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random. Additional circuitry is provided to ensure that charges on the gates of the inverters in
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the cross-coupled circuit are equalized when power is removed. Still further circuity is
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COMPLAINT - 2
included for synchronizing operation of the power control and charge equalization circuitry
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In early 1997, while interviewing for possible employment with Intel, Dr.
Hangartner met with Intel's Strategic CAD group, including Dr. Carl-Johan Seger, and
discussed in great detail the technology Dr. Hangartner had developed and was then patenting.
As a result of these discussions and disclosures, Intel had knowledge, at least as early as 1997,
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computers, mobile devices, and other systems distributed and used throughout the world. In
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or about April, 2012, Intel introduced to the marketplace an updated series of microprocessors
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it code named, Ivy Bridge. Upon information and belief, Intel has subsequently introduced
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Incorporated into the Ivy Bridge, Haswell and Silvermont series of processors
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are circuitry and an instruction set that, among other things, enable users of the processors to
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importance to users of the processors and is a valuable feature of the Ivy Bridge series of
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processors.
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Silvermont series of processors is made available to users through the so-called, RDRAND
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The generation of such random numbers in the Ivy Bridge, Haswell and
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In the Ivy Bridge, Haswell and Silvermont series of processors made, sold,
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offered for sale and used by Intel, the RDRAND instruction that generates random numbers is
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implemented through use of circuitry and techniques developed by Dr. Hangartner and
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disclosed and claimed in his '422 Patent. In the Haswell series of processors, an additional
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COMPLAINT - 3
instruction named RDSEED is also implemented through use of circuitry and techniques
developed by Dr. Hangartner and disclosed and claimed in his '422 Patent.
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Intel has been and is infringing Dr. Hangartner's '422 Patent by making, using,
offering for sale, selling and/or importing processors incorporating the RDRAND and/or
RDSEED instructions and including circuitry constructed in accordance with the '422 Patent.
In particular, Defendant Intel Corporation has been and is directly infringing at least Claim 1
of the 422 Patent under 35 U.S.C. 271(a) by providing to customers, including customers in
this judicial district, processors that include probabilistic computing methods and apparatus
constructed in accordance with that claim. Defendant Intel Corporation has also been, and is,
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directly infringing at least Claim 1 of the 422 Patent under 35 U.S.C. 271(a) by making,
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offering for sale, selling, using and/or importing such processors in and/or into the United
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States. Upon information and belief, infringing devices made, offered for sale, sold, or
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imported into the United States by Defendant Intel Corporation include, by way of example
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but not limitation, the Ivy Bridge, Haswell and Silvermont series of processors as well
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Corporation has also infringed the 422 patent under 35 U.S.C. 271(b) by knowingly and
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actively inducing others to infringe through the sale, distribution and use of such processors
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incorporating such probabilistic computing methods and apparatus. By way of example, not
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limitation, a representative claim chart showing how the processors made, sold, offered for
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sale, used or imported into the United States by Intel Corporation infringe at least Claim 1 of
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Intel
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willful and have deliberately injured and will continue to injure Dr. Hangartner unless and
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until the Court enters an injunction prohibiting further infringement and, specifically,
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enjoining further manufacture, use, importation, sale and/or offer for sale of products that fall
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COMPLAINT - 4
WHEREFORE, Dr. Hangartner asks this Court to enter judgment against Defendant
and against its subsidiaries, affiliates, agents, servants, employees and all persons in active
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infringement that has occurred, together with prejudgment interest from the date infringement
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A finding that this case is exceptional and an award to Dr. Hangartner of his
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attorneys fees and costs as may be appropriate and as provided by 35 U.S.C. 285;
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Pre-judgment interest calculated from the time of the first occurrence of any
Such other and further relief as this Court or a jury may deem proper and just.
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JURY DEMAND
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Dr. Hangartner demands a trial by jury on all issues presented in this Complaint.
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Respectfully submitted,
/Philip P. Mann
Philip P. Mann, WSBA No: 28860
MANN LAW GROUP
1218 Third Avenue, Suite 1809
Seattle, Washington 98101
Phone (206) 436-0900
Fax (866) 341-5140
phil@mannlawgroup.com
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COMPLAINT - 5