COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

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JAQUEZ & ASSOCIATES
Martin Joseph Jaquez (SBN 162975)
(martyjaquez-associates.com)
6265 Greenwich Drive, Suite 100D
San Diego, CA 92122-5916
Telephone: (858) 453-2004
Facsimile: (858) 453-1280
Attorneys Ior PlaintiII
Peregrine Semiconductor Corporation

81,7('67$7(6',675,&7&2857
6287+(51',675,&72)&$/,)251,$

PEREGRINE SEMICONDUCTOR
CORPORATION, a Delaware
corporation,

PlaintiII,

vs.

RF MICRO DEVICES, INC., a North
Carolina corporation, MOTOROLA
MOBILITY, INC., a Delaware
corporation, and JOHN DOES 1-10,

DeIendants.
CASE NO.


&203/$,17)25'$0$*(6$1'
,1-81&7,9(5(/,()

(1) Patent InIringement under
35 U.S.C. 271, 281, 283-85

'(0$1')25-85<75,$/


'12CV0911 WMc AJB

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

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For its complaint against DeIendants RF Micro Devices, Inc. ('RFMD), Motorola
Mobility, Inc. ('MMI), and John Does 1-10 (collectively, 'DeIendants), PlaintiII
Peregrine Semiconductor Corporation ('Peregrine) complains and alleges as Iollows:
1$785(2)$&7,21
This is an action Ior patent inIringement arising under the patent laws oI the
United States, Title 35 oI the United States Code. PlaintiII seeks damages, attorneys`
Iees, costs, and preliminary and permanent injunctive relieI.
-85,6',&7,21
1. This Court has subject matter jurisdiction over this case pursuant to 28
U.S.C. 1338(a).
2. This Court has personal jurisdiction over DeIendant RFMD based upon the
Iollowing: (a) DeIendant RFMD maintains an oIIice in the Southern District oI
CaliIornia; (b) DeIendant RFMD transacts substantial business in and maintains
continuous and systematic contacts with this District and the State oI CaliIornia; and (c)
DeIendant RFMD has committed tortious acts that RFMD knew or should have known
would cause injury to PlaintiII in the Southern District oI CaliIornia.
3. This Court has personal jurisdiction over DeIendant MMI based upon the
Iollowing: (a) DeIendant MMI transacts substantial business in and maintains continuous
and systematic contacts with this District and the State oI CaliIornia; (b) DeIendant MMI
maintains oIIices in the Southern District oI CaliIornia, (c) DeIendant MMI has
committed tortious acts that MMI knew or should have known would cause injury to
PlaintiII in the Southern District oI CaliIornia, and (d) DeIendant MMI has appointed an
agent in CaliIornia to receive service oI process.
4. This Court has personal jurisdiction over DeIendants John Does 1-10 based
on the Iollowing: (a) DeIendants John Does 1-10 are present and/or doing business in the
Southern District oI CaliIornia; and (b) DeIendants John Does 1-10 have committed
tortious acts that they knew or should have known would cause injury to PlaintiII in the
Southern District oI CaliIornia.

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

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5. Venue is proper in the United States District Court Ior the Southern District
oI CaliIornia under 28 U.S.C. 1391(b), 1400(b).
3$57,(6
6. PlaintiII Peregrine is a Delaware corporation with a principal place oI
business at 9380 Carroll Park Drive, San Diego, CaliIornia 92121.
7. Upon inIormation and belieI, DeIendant RFMD is a North Carolina
corporation with a principal place oI business at 7628 Thorndike Road, Greensboro,
North Carolina 27409.
8. Upon inIormation and belieI, DeIendant MMI is a Delaware corporation
with a principal place oI business at 600 N. US Hwy 45, Libertyville, Illinois 60048.
9. DeIendants John Does 1-10 are parties whose identities are not yet known to
Peregrine. To the extent their identities become known to PlaintiII Peregrine, the John
Doe deIendants will be named and their activities pleaded in an amended complaint.
)$&78$/$//(*$7,216
PlaintiII Peregrine is the owner by assignment oI all rights, title, and interest in and
to United States Patent Nos. 7,910,993 (the '993 Patent), 7,123,898 (the '898
Patent), 7,460,852 (the '852 Patent), 7,796,969 (the '969 Patent), and 7,860,499
(the '499 Patent) (collectively, the 'Peregrine Patents) (Exhibits A-E). The 993
Patent is entitled 'Method and Apparatus Ior Use in Improving Linearity oI MOSFET`s
Using an Accumulated Charge Sink and issued March 22, 2011. The 898 Patent is
entitled 'Switch Circuit and Method oI Switching Radio Frequency Signals and issued
October 17, 2006. The 852 Patent is entitled 'Switch Circuit and Method oI Switching
Radio Frequency Signals and issued December 2, 2008. The 969 Patent is entitled
'Symmetrically and Asymmetrically Stacked Transistor Group RF Switch and issued
September 14, 2010. Lastly, the 499 Patent is entitled 'Switch Circuit and Method oI
Switching Radio Frequency Signals and issued December 28, 2010. Accordingly,
Peregrine has standing to sue Ior inIringement oI the Asserted Patents.
The Asserted Patents disclose advanced integrated circuit technologies Ior use in

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

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radio Irequency circuits, including but not limited to radio Irequency switches. Radio
Irequency circuits practicing the Asserted Patents can be used in a variety oI devices
including, Ior example, antenna tuning circuits, devices that use diversity or multiple-
input and multiple-output (MMO) antennas, and mobile wireless devices that use cellular
technologies and wireless local area network (WLAN) technologies. Mobile wireless
devices that use radio Irequency circuits practicing the Asserted Patents may (a) transmit
and/or receive wireless signals more eIIiciently while consuming less power, (b) be
smaller in size because the Asserted Patents disclose techniques that allow the integration
oI Iunctions that previously had to be handled by separate components, and (c) be less
expensive to manuIacture due to the ability to leverage the established global
Complimentary Metal Oxide Semiconductor ('CMOS) manuIacturing inIrastructure,
rather than needing to rely on the more specialized manuIacturing processes required by
the devices that utilized previously available technologies and techniques. AIter
signiIicant investments in research and development, engineering, labor, plant and
equipment, manuIacturing and marketing, Peregrine-branded radio Irequency switches
that practice the Asserted Patents have been selected Ior use in wireless handsets by
many oI the leading wireless handset manuIacturers including Apple, LG, Nokia,
Samsung, and Sony Ericsson.
Upon inIormation and belieI, RFMD has and continues to inIringe, contributorily
inIringe, and/or induce inIringement oI the Asserted Patents by knowingly and actively
(1) making, having made, importing, using, oIIering Ior sale and/or selling products that
inIringe one or more claims oI the Asserted Patents, including integrated circuits with
integrated circuit die markings M1D1604 and M1D1293 such as RF1603, RF1604, and
RF1293, (2) inducing others to do the same, and (3) contributing to the manuIacture,
import, use, sale, or oIIer Ior sale products that inIringe one or more claims oI the
Asserted Patents. In addition, upon inIormation and belieI, MMI has and continues to
inIringe, contributorily inIringe, and/or induce inIringement oI the Asserted Patents by
knowingly and actively (1) making, having made, importing, using, oIIering Ior sale

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

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and/or selling products that inIringe one or more claims oI the Asserted Patents,
including MMI`s DROID RAZR and DROID BIONIC handsets (Model Nos. XT912 and
XT875, respectively), both oI which contain RF1603, which contains integrated circuit
die marking M1D1604, (2) inducing others to do the same, and (3) contributing to the
manuIacture, import, use, sale, or oIIer Ior sale products that inIringe one or more claims
oI the Asserted Patents. The RF1603, RF1604, RF1293, DROID RAZR handset, and
DROID BIONIC handset inIringe at least claims 14-16 and 23-25 oI the 993 Patent,
claims 1-3, 5-7, and 15 oI the 898 Patent, claims 1-4, 7, 13, 14, 20, 22, 24, and 25 oI the
852 Patent, claims 6-8 and 29-30 oI the 969 Patent, and claims 1, 3, 5 and 6 oI the 499
Patent.
),567&$86(2)$&7,21
(InIringement oI the 993 Patent)
10. PlaintiII incorporates the allegations in the preceding paragraphs as iI Iully
set Iorth herein.
11. PlaintiII Peregrine is the owner by assignment oI all rights, title, and interest
in and to the 993 Patent. Peregrine thereIore has standing to sue Ior inIringement oI the
993 Patent.
12. Upon inIormation and belieI, DeIendants have inIringed and continue to
inIringe the 993 Patent by knowingly and actively making, having made, importing,
using, oIIering to sell, or selling products that inIringe one or more claims oI the 993
Patent, including but not limited to certain integrated circuits (including those with
integrated circuit die markings M1D1604 and M1D1293 such as RF1603, RF1604, and
RF1293, which are marketed and sold by RFMD), components thereoI, and/or devices
using certain integrated circuits or components thereoI (such as MMI`s DROID RAZR
and DROID BIONIC handsets, which are marketed and sold by MMI) that incorporate,
without license, the inventions developed by Peregrine and protected by one or more
claims in the 993 Patent, or by knowingly and actively inducing or contributing to the
inIringement oI the 993 Patent by others.

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
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13. PlaintiII Peregrine has complied with 35 U.S.C. 287.
14. As a direct and proximate result oI DeIendants` inIringement, PlaintiII
Peregrine has suIIered, and will continue to suIIer, injury.
15. As a result oI the harm suIIered as alleged herein, PlaintiII Peregrine is
entitled to all oI the remedies available under the Patent Act, including damages adequate
to compensate it Ior such inIringement, but in no event less than a reasonable royalty,
costs and attorneys` Iees.
6(&21'&$86(2)$&7,21
(InIringement oI the 898 Patent)
16. PlaintiII incorporates the allegations in the preceding paragraphs as iI Iully
set Iorth herein.
17. PlaintiII Peregrine is the owner by assignment oI all rights, title, and interest
in and to the 898 Patent. Peregrine thereIore has standing to sue Ior inIringement oI the
898 Patent.
18. Upon inIormation and belieI, DeIendants have inIringed and continue to
inIringe the 898 Patent by knowingly and actively making, having made, importing,
using, oIIering to sell, or selling products that inIringe one or more claims oI the 898
Patent, including but not limited to certain integrated circuits (including those with
integrated circuit die markings M1D1604 and M1D1293 such as RF1603, RF1604, and
RF1293, which are marketed and sold by RFMD), components thereoI, and/or devices
using certain integrated circuits or components thereoI (such as MMI`s DROID RAZR
and DROID BIONIC handsets, which are marketed and sold by MMI) that incorporate,
without license, the inventions developed by Peregrine and protected by one or more
claims in the 898 Patent, or by knowingly and actively inducing or contributing to the
inIringement oI the 898 Patent by others.
19. PlaintiII Peregrine has complied with 35 U.S.C. 287.
20. As a direct and proximate result oI DeIendants` inIringement, PlaintiII
Peregrine has suIIered, and will continue to suIIer, injury.

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

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21. As a result oI the harm suIIered as alleged herein, PlaintiII Peregrine is
entitled to all oI the remedies available under the Patent Act, including damages adequate
to compensate it Ior such inIringement, but in no event less than a reasonable royalty,
costs and attorneys` Iees.
7+,5'&$86(2)$&7,21
(InIringement oI the 852 Patent)
22. PlaintiII incorporates the allegations in the preceding paragraphs as iI Iully
set Iorth herein.
23. PlaintiII Peregrine is the owner by assignment oI all rights, title, and interest
in and to the 852 Patent. Peregrine thereIore has standing to sue Ior inIringement oI the
852 Patent.
24. Upon inIormation and belieI, DeIendants have inIringed and continue to
inIringe the 852 Patent by knowingly and actively making, having made, importing,
using, oIIering to sell, or selling products that inIringe one or more claims oI the 852
Patent, including but not limited to certain integrated circuits (including those with
integrated circuit die markings M1D1604 and M1D1293 such as RF1603, RF1604, and
RF1293, which are marketed and sold by RFMD), components thereoI, and/or devices
using certain integrated circuits or components thereoI (such as MMI`s DROID RAZR
and DROID BIONIC handsets, which are marketed and sold by MMI) that incorporate,
without license, the inventions developed by Peregrine and protected by one or more
claims in the 852 Patent, or by knowingly and actively inducing or contributing to the
inIringement oI the 852 Patent by others.
25. PlaintiII Peregrine has complied with 35 U.S.C. 287.
26. As a direct and proximate result oI DeIendants` inIringement, PlaintiII
Peregrine has suIIered, and will continue to suIIer, injury.
27. As a result oI the harm suIIered as alleged herein, PlaintiII Peregrine is
entitled to all oI the remedies available under the Patent Act, including damages adequate
to compensate it Ior such inIringement, but in no event less than a reasonable royalty,

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

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costs and attorneys` Iees.
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(InIringement oI the 969 Patent)
28. PlaintiII incorporates the allegations in the preceding paragraphs as iI Iully
set Iorth herein.
29. PlaintiII Peregrine is the owner by assignment oI all rights, title, and interest
in and to the 969 Patent. Peregrine thereIore has standing to sue Ior inIringement oI the
969 Patent.
30. Upon inIormation and belieI, DeIendants have inIringed and continue to
inIringe the 969 Patent by knowingly and actively making, having made, importing,
using, oIIering to sell, or selling products that inIringe one or more claims oI the 969
Patent, including but not limited to certain integrated circuits (including those with
integrated circuit die markings M1D1604 and M1D1293 such as RF1603, RF1604, and
RF1293, which are marketed and sold by RFMD), components thereoI, and/or devices
using certain integrated circuits or components thereoI (such as MMI`s DROID RAZR
and DROID BIONIC handsets, which are marketed and sold by MMI) that incorporate,
without license, the inventions developed by Peregrine and protected by one or more
claims in the 969 Patent, or by knowingly and actively inducing or contributing to the
inIringement oI the 969 Patent by others.
31. PlaintiII Peregrine has complied with 35 U.S.C. 287.
32. As a direct and proximate result oI DeIendants` inIringement, PlaintiII
Peregrine has suIIered, and will continue to suIIer, injury.
33. As a result oI the harm suIIered as alleged herein, PlaintiII Peregrine is
entitled to all oI the remedies available under the Patent Act, including damages adequate
to compensate it Ior such inIringement, but in no event less than a reasonable royalty,
costs and attorneys` Iees.
/ / /
/ / /

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

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),)7+&$86(2)$&7,21
(InIringement oI the 499 Patent)
34. PlaintiII incorporates the allegations in the preceding paragraphs as iI Iully
set Iorth herein.
35. PlaintiII Peregrine is the owner by assignment oI all rights, title, and interest
in and to the 499 Patent. Peregrine thereIore has standing to sue Ior inIringement oI the
499 Patent.
36. Upon inIormation and belieI, DeIendants have inIringed and continue to
inIringe the 499 Patent by knowingly and actively making, having made, importing,
using, oIIering to sell, or selling products that inIringe one or more claims oI the 499
Patent, including but not limited to certain integrated circuits (including those with
integrated circuit die markings M1D1604 and M1D1293 such as RF1603, RF1604, and
RF1293, which are marketed and sold by RFMD), components thereoI, and/or devices
using certain integrated circuits or components thereoI (such as MMI`s DROID RAZR
and DROID BIONIC handsets, which are marketed and sold by MMI) that incorporate,
without license, the inventions developed by Peregrine and protected by one or more
claims in the 499 Patent, or by knowingly and actively inducing or contributing to the
inIringement oI the 499 Patent by others.
37. PlaintiII Peregrine has complied with 35 U.S.C. 287.
38. As a direct and proximate result oI DeIendants` inIringement, PlaintiII
Peregrine has suIIered, and will continue to suIIer, injury.
39. As a result oI the harm suIIered as alleged herein, PlaintiII Peregrine is
entitled to all oI the remedies available under the Patent Act, including damages adequate
to compensate it Ior such inIringement, but in no event less than a reasonable royalty,
costs and attorneys` Iees.
35$<(5)255(/,()
:+(5()25(, PlaintiII Peregrine respectIully prays that the Court grant the
Iollowing relieI:
'12CV0911 WMc AJB