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ALAN H. BLANKENHEIMER (AZ Bar No. 006164) ablankenheimer@cov.com JO DALE CAROTHERS (AZ Bar No. 020402) jcarothers@cov.com COVINGTON & BURLING LLP 9191 Towne Centre Drive, Suite 600 San Diego, CA 92122 Telephone: (858) 678-1800 Facsimile: (858) 678-1600 Attorneys for Plaintiff MICROCHIP TECHNOLOGY INCORPORATED UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA MICROCHIP TECHNOLOGY INCORPORATED, Plaintiff, Case No. _____________ COMPLAINT FOR PATENT INFRINGEMENT DEMAND FOR JURY TRIAL INTERSIL CORPORATION, TECHWELL, INC. and ZILKER LABS, INC. Defendants.

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Microchip Technology Incorporated hereby alleges for its complaint against Intersil Corporation, Zilker Labs, Inc. and Techwell, Inc. on personal knowledge as to its own activities and on information and belief as to the activities of others, as follows: THE PARTIES 1. Microchip Technology Incorporated (Microchip) is a corporation

organized and existing under the laws of the State of Delaware, with its principal place of business at 2355 West Chandler Blvd., Chandler, Arizona 85224. Microchip is a leading provider of microcontroller, analog, memory and Flash-IP solutions. 2. On information and belief, Defendant Intersil Corporation (Intersil) is a

corporation organized under the laws of the State of Delaware with its principal place of business at 1001 Murphy Ranch Road, Milpitas, California 95035 and regularly conducts business in the District of Arizona.
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3.

On information and belief, Defendant Zilker Labs, Inc. (Zilker) is

currently a wholly owned subsidiary of Intersil. 4. On information and belief, products starting with ZL, including ZL2106,

ZL6100, ZL6105 and ZL9101M, are Zilker products. 5. On information and believe, Defendant Techwell, Inc. (Techwell) is

currently an indirect wholly owned subsidiary of Intersil. 6. On information and belief, products starting with TW, including TW2865,

are Techwell products. PERSONAL JURISDICTION AND VENUE 7. This is an action for patent infringement arising under the patent laws of

the United States. Title 35 U.S.C. 271, et seq. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 and 1338(a). 8. On information and belief, Intersil conducts business in this district, on

behalf of itself and its subsidiaries Zilker and Techwell, and as a result of this business has continuous and systematic contacts with this district including, but not limited to, having a sales representative who maintains an office in Arizona, having distributors in and assigned to Arizona and providing a webpage with Arizona-specific, customer information. Furthermore, on information and belief, Intersil has purposefully directed activities to Arizona, such as directly distributing, offering for sale, selling, and advertising its products and services, including Zilker and Techwell products, within the State of Arizona and this judicial district, and Microchips claims for relief arise from and relate to those activities. Accordingly, Intersil, and its subsidiaries Zilker and Techwell, are subject to personal jurisdiction in this judicial district. 9. 1400(b). NATURE OF THE ACTION 10. Microchip is the assignee of United States Patent No. 5,760,720 (the 720 Venue is proper in this district under 28 U.S.C. 1391(b) and (c) and

Patent), entitled Digital Trimming of On-Chip Analog Components, issued on June 2,

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1998. Microchip is owner of all rights, title and interest in and to this patent, including the right to recover for infringement. A true and correct copy of the 720 patent is attached hereto as Exhibit A. 11. Microchip is the assignee of United States Patent No. 6,559,783 (the 783

Patent), entitled Programmable Auto-Converting Analog To Digital Conversion Module, issued on May 6, 2003. Microchip is owner of all rights, title and interest in and to this patent, including the right to recover for infringement. A true and correct copy of the 783 patent is attached hereto as Exhibit B. 12. Microchip is the assignee of United States Patent No. 6,847,904 (the 904

Patent), entitled Multi-Channel Programmable Gain Amplifier Controlled with a Serial Interface, issued on January 25, 2005. Microchip is owner of all rights, title and interest in and to this patent, including the right to recover for infringement. A true and correct copy of the 904 patent is attached hereto as Exhibit C. 13. Microchip is the assignee of United States Patent No. 7,225,088 (the 088

Patent), entitled Programmable Power Supply and Brownout Detector for Electronic Equipment, issued on May 29, 2007. Microchip is owner of all rights, title and interest in and to this patent, including the right to recover for infringement. A true and correct copy of the 088 patent is attached hereto as Exhibit D. 14. Microchip is the assignee of United States Patent No. 6,245,597 (the 597

Patent), entitled Method for Reducing Die Cracking in Integrated Circuits, issued on June 12, 2001. Microchip is owner of all rights, title and interest in and to this patent, including the right to recover for infringement. A true and correct copy of the 597 patent is attached hereto as Exhibit E. 15. Microchip is the assignee of United States Patent No. 6,159,765 (the 765

Patent), entitled Integrated Circuit Package Having Interchip Bonding and Method Therefor, issued on December 12, 2000. Microchip is owner of all rights, title and interest in and to this patent, including the right to recover for infringement. A true and correct copy of the 765 patent is attached hereto as Exhibit F.
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FIRST CAUSE OF ACTION: INFRINGEMENT OF U.S. PATENT NO. 5,760,720 (INTERSIL) 16. Microchip realleges and incorporates the allegations of Paragraphs 1-15 as

if set forth herein in their entirety. 17. Microchip is informed and believes and thereon alleges that Intersil has

been and is now infringing, inducing infringement and/or contributing to infringement of the 720 Patent by making, using, selling and/or offering for sale in and/or importing into the United States without authority products, including, without limitation, the ISL12022M, ISL12022MA, ISL12022MR5421, ISL6296A products, that incorporate and/or utilize the invention claimed in the 720 Patent. 18. By reason of Intersils acts alleged herein, Microchip has suffered damage

in an amount to be proved at trial. 19. On information and belief, Intersil threatens to continue to do the acts

complained herein, and unless restrained and enjoined will continue to do so, all to Microchips irreparable damage. It would be difficult to ascertain the amount of compensation which would afford Microchip adequate relief for such future and continuing acts. Microchip does not have an adequate remedy at law to compensate it for injuries threatened. SECOND CAUSE OF ACTION: INFRINGEMENT OF U.S. PATENT NO. 6,559,783 (INTERSIL) 20. Microchip realleges and incorporates the allegations of Paragraphs 1-15 as

if set forth herein in their entirety. 21. Microchip is informed and believes and thereon alleges that Intersil has

been and is now infringing, inducing infringement and/or contributing to infringement of the 783 Patent by making, using, selling and/or offering for sale in and/or importing into the United States without authority products, including, without limitation, the ZL2004, ZL2004-01, ZL2006, ZL2008, ZL6100, ZL6105, and ISL6295 products, that incorporate and/or utilize the invention claimed in the 783 Patent.
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22.

By reason of Intersils acts alleged herein, Microchip has suffered damage

in an amount to be proved at trial. 23. On information and belief, Intersil threatens to continue to do the acts

complained herein, and unless restrained and enjoined will continue to do so, all to Microchips irreparable damage. It would be difficult to ascertain the amount of compensation which would afford Microchip adequate relief for such future and continuing acts. Microchip does not have an adequate remedy at law to compensate it for injuries threatened. THIRD CAUSE OF ACTION: INFRINGEMENT OF U.S. PATENT NO. 6,559,783 (ZILKER) 24. Microchip realleges and incorporates the allegations of Paragraphs 1-15 as

if set forth herein in their entirety. 25. Microchip is informed and believes and thereon alleges that Zilker has

been and is now infringing, inducing infringement and/or contributing to infringement of the 783 Patent by making, using, selling and/or offering for sale in and/or importing into the United States without authority products, including, without limitation, the ZL2004, ZL2004-01, ZL2006, ZL2008, ZL6100 and ZL6105 products, that incorporate and/or utilize the invention claimed in the 783 Patent. 26. By reason of Zilkers acts alleged herein, Microchip has suffered damage

in an amount to be proved at trial. 27. On information and belief, Zilker threatens to continue to do the acts

complained herein, and unless restrained and enjoined will continue to do so, all to Microchips irreparable damage. It would be difficult to ascertain the amount of compensation which would afford Microchip adequate relief for such future and continuing acts. Microchip does not have an adequate remedy at law to compensate it for injuries threatened.

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FOURTH CAUSE OF ACTION: INFRINGEMENT OF U.S. PATENT NO. 6,847,904 (INTERSIL) 28. Microchip realleges and incorporates the allegations of Paragraphs 1-15 as

if set forth herein in their entirety. 29. Microchip is informed and believes and thereon alleges that Intersil has

been and is now infringing, inducing infringement and/or contributing to infringement of the 904 Patent by making, using, selling and/or offering for sale in and/or importing into the United States without authority products, including, without limitation, the ISL51002 product, that incorporate and/or utilize the invention claimed in the 904 Patent. 30. By reason of Intersils acts alleged herein, Microchip has suffered damage

in an amount to be proved at trial. 31. On information and belief, Intersil threatens to continue to do the acts

complained herein, and unless restrained and enjoined will continue to do so, all to Microchips irreparable damage. It would be difficult to ascertain the amount of compensation which would afford Microchip adequate relief for such future and continuing acts. Microchip does not have an adequate remedy at law to compensate it for injuries threatened. FIFTH CAUSE OF ACTION: INFRINGEMENT OF U.S. PATENT NO. 7,225,088 (INTERSIL) 32. Microchip realleges and incorporates the allegations of Paragraphs 1-15 as

if set forth herein in their entirety. 33. Microchip is informed and believes and thereon alleges that Intersil has

been and is now infringing, inducing infringement and/or contributing to infringement of the 088 Patent by making, using, selling and/or offering for sale in and/or importing into the United States without authority products, including, without limitation, the ZL2004, ZL2004-01, ZL2005, ZL2005P, ZL2006, ZL2008, ZL2101, ZL2103, ZL2105, ZL2106, ZL6100, ZL6105, ZL9101M, ZL9117M, ISL9305 and ISL9305H products, that incorporate and/or utilize the invention claimed in the 088 Patent.
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34.

By reason of Intersils acts alleged herein, Microchip has suffered damage

in an amount to be proved at trial. 35. On information and belief, Intersil threatens to continue to do the acts

complained herein, and unless restrained and enjoined will continue to do so, all to Microchips irreparable damage. It would be difficult to ascertain the amount of compensation which would afford Microchip adequate relief for such future and continuing acts. Microchip does not have an adequate remedy at law to compensate it for injuries threatened. SIXTH CAUSE OF ACTION: INFRINGEMENT OF U.S. PATENT NO. 7,225,088 (ZILKER) 36. Microchip realleges and incorporates the allegations of Paragraphs 1-15 as

if set forth herein in their entirety. 37. Microchip is informed and believes and thereon alleges that Intersil has

been and is now infringing, inducing infringement and/or contributing to infringement of the 088 Patent by making, using, selling and/or offering for sale in and/or importing into the United States without authority products, including, without limitation, the ZL2004, ZL2004-01, ZL2005, ZL2005P, ZL2006, ZL2008, ZL2101, ZL2103, ZL2105, ZL2106, ZL6100, ZL6105, ZL9101M and ZL9117M products, that incorporate and/or utilize the invention claimed in the 088 Patent. 38. By reason of Zilkers acts alleged herein, Microchip has suffered damage

in an amount to be proved at trial. 39. On information and belief, Zilker threatens to continue to do the acts

complained herein, and unless restrained and enjoined will continue to do so, all to Microchips irreparable damage. It would be difficult to ascertain the amount of compensation which would afford Microchip adequate relief for such future and continuing acts. Microchip does not have an adequate remedy at law to compensate it for injuries threatened.

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SEVENTH CAUSE OF ACTION: INFRINGEMENT OF U.S. PATENT NO. 6,245,597 (INTERSIL) 40. Microchip realleges and incorporates the allegations of Paragraphs 1-15 as

if set forth herein in their entirety. 41. Microchip is informed and believes and thereon alleges that Intersil has

been and is now infringing, inducing infringement and/or contributing to infringement of the 597 Patent by making, using, selling and/or offering for sale in and/or importing into the United States without authority products, including, without limitation, the ISL12022M, ISL28195FHZ-TZ, ISL3282E, ISL51002, ISL55211 and TW2865 products, that incorporate and/or utilize the invention claimed in the 597 Patent. 42. By reason of Intersils acts alleged herein, Microchip has suffered damage

in an amount to be proved at trial. 43. On information and belief, Intersil threatens to continue to do the acts

complained herein, and unless restrained and enjoined will continue to do so, all to Microchips irreparable damage. It would be difficult to ascertain the amount of compensation which would afford Microchip adequate relief for such future and continuing acts. Microchip does not have an adequate remedy at law to compensate it for injuries threatened. EIGHTH CAUSE OF ACTION: INFRINGEMENT OF U.S. PATENT NO. 6,245,597 (TECHWELL) 44. Microchip realleges and incorporates the allegations of Paragraphs 1-15 as

if set forth herein in their entirety. 45. Microchip is informed and believes and thereon alleges that Techwell has

been and is now infringing, inducing infringement and/or contributing to infringement of the 597 Patent by making, using, selling and/or offering for sale in and/or importing into the United States without authority products, including, without limitation, the TW2865 products, that incorporate and/or utilize the invention claimed in the 597 Patent.

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46.

By reason of Techwells acts alleged herein, Microchip has suffered

damage in an amount to be proved at trial. 47. On information and belief, Techwell threatens to continue to do the acts

complained herein, and unless restrained and enjoined will continue to do so, all to Microchips irreparable damage. It would be difficult to ascertain the amount of compensation which would afford Microchip adequate relief for such future and continuing acts. Microchip does not have an adequate remedy at law to compensate it for injuries threatened. NINTH CAUSE OF ACTION: INFRINGEMENT OF U.S. PATENT NO. 6,159,765 (INTERSIL) 48. Microchip realleges and incorporates the allegations of Paragraphs 1-15 as

if set forth herein in their entirety. 49. Microchip is informed and believes and thereon alleges that Intersil has

been and is now infringing, inducing infringement and/or contributing to infringement of the 765 Patent by making, using, selling and/or offering for sale in and/or importing into the United States without authority products, including, without limitation, the ZL6105 product, that incorporate and/or utilize the invention claimed in the 765 Patent. 50. By reason of Intersils acts alleged herein, Microchip has suffered damage

in an amount to be proved at trial. 51. On information and belief, Intersil threatens to continue to do the acts

complained herein, and unless restrained and enjoined will continue to do so, all to Microchips irreparable damage. It would be difficult to ascertain the amount of compensation which would afford Microchip adequate relief for such future and continuing acts. Microchip does not have an adequate remedy at law to compensate it for injuries threatened.

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TENTH CAUSE OF ACTION: INFRINGEMENT OF U.S. PATENT NO. 6,159,765 (ZILKER) 52.
Microchip realleges and incorporates the allegations of Paragraphs 1-15 as if set

forth herein in their entirety.

53.

Microchip is informed and believes and thereon alleges that Intersil has

been and is now infringing, inducing infringement and/or contributing to infringement of the 765 Patent by making, using, selling and/or offering for sale in and/or importing into the United States without authority products, including, without limitation, the ZL6105 product, that incorporate and/or utilize the invention claimed in the 765 Patent. 54. By reason of Zilkers acts alleged herein, Microchip has suffered damage

in an amount to be proved at trial. 55. On information and belief, Zilker threatens to continue to do the acts

complained herein, and unless restrained and enjoined will continue to do so, all to Microchips irreparable damage. It would be difficult to ascertain the amount of compensation which would afford Microchip adequate relief for such future and continuing acts. Microchip does not have an adequate remedy at law to compensate it for injuries threatened. DEMAND FOR JURY TRIAL Plaintiff Microchip demands a jury trial on all claims and issues so triable. PRAYER FOR RELIEF WHEREFORE, Microchip prays for an Order and entry of Judgment against Intersil as follows: A. For judgment that Intersil has infringed, induced infringement of, and

contributorily infringed, and continues to infringe, induce infringement of, and contributorily infringe the 720 Patent, the 783 Patent, the 904 Patent, the 088 Patent, the 597 Patent and the 765 Patent;

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B.

For a permanent injunction prohibiting Intersil, and all persons or entities

acting in concert with Intersil, from infringing the 720 Patent, the 783 Patent, the 904 Patent, the 088 Patent, the 597 Patent and the 765 Patent; C. For judgment that Zilker has infringed, induced infringement of, and

contributorily infringed, and continues to infringe, induce infringement of, and contributorily infringe the 783 Patent, the 088 Patent and the 765 Patent; D. For a permanent injunction prohibiting Zilker, and all persons or entities

acting in concert with Zilker, from infringing the 783 Patent, the 088 Patent and the 765 Patent; E. For judgment that Techwell has infringed, induced infringement of, and

contributorily infringed, and continues to infringe, induce infringement of, and contributorily infringe the 597 Patent; F. For a permanent injunction prohibiting Techwell, and all persons or

entities acting in concert with Techwell, from infringing the 597 Patent; G. For an award to Microchip of all damages resulting from the infringement

of the 720 Patent, the 783 Patent, the 904 Patent, the 088 Patent, the 597 Patent and the 765 Patent, together with pre-judgment and post-judgment interest; H. For the Court to declare this case exceptional under 35 U.S.C. 285 and to

award Microchip its reasonable attorneys fees in this action; I. J. For an award to Microchip of all costs and expenses of this action; and For such other and further relief as this Court deems proper and just.

DATED this 23rd day of March, 2012. By: Alan H. Blankenheimer Jo Dale Carothers COVINGTON & BURLING LLP 9191 Towne Centre Drive, Suite 600 San Diego, CA 92122 Attorneys for Plaintiff Microchip Technology Incorporated
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