On April 27, 2022, Bell Semiconductor, LLC (“Bell Semic” or “Plaintiff”), represented by Raymond P. Ausrotas of Arrowood LLP, filed an intellectual property lawsuit against Advanced Micro Devices, Inc. (“AMD” or “Defendant”), seeking declaratory and injunctive relief and damages for the alleged infringement of United States patent owned by the plaintiff. This case was filed in the U.S. District Court in the District of Massachusetts.
The plaintiff filed this complaint for the alleged infringement of United States Patent No. 7,007,259 (“the ’259 patent”). In the complaint, the plaintiff claimed, “The circuit design methodology claimed in the ʼ259 patent is used by AMD in the production of one or more of its semiconductor chips, including its Ryzen 7 1700 processor device. Semiconductor devices include different kinds of materials to function as intended. For example, these devices typically include both metal (i.e., conductor) and insulator materials, which are deposited or otherwise processed sequentially in layers to form the final device.”
The plaintiff claimed, “Prior to development of the methodology described in the ʼ259 patent, the most widely implemented technology for insertion of dummy metal into a circuit design required hardcoding a large ‘stay–away’ distance between the dummy metal and clock nets, which led to less space available for dummy metal insertion. The plaintiff then alleged, “AMD has and continues to directly infringe pursuant to 35 U.S.C. § 271(a) one or more claims of the ’259 patent by using the patented methodology to design one or more semiconductor devices, including as one example the Ryzen 7 1700 processor device, in the United States.”
The plaintiff then alleged, “AMD employs a variety of design tools, for example, Cadence, Synopsys, and/or Siemens tools, to insert dummy metal into a circuit design (the ‘Accused Processes’) as recited in the ʼ259 patent claims. AMD’s Accused Processes infringe and continue to infringe one or more claims of the ’259 patent during the pendency of the ’259 patent.”
The plaintiff also alleged, “The Bell Semic personnel walked through infringement of the ʼ259 patent and explained that the patent was infringed by a number of AMD devices. After the meeting, Kouros Azimi forwarded the slide deck to the AMD personnel. AMD’s infringement of the ʼ259 patent is thus willful and deliberate. Bell Semic has been damaged by AMD’s infringement of the ʼ259 patent.”
The plaintiff presented one claim for alleged infringement of the ’259 patent owned by the plaintiff. In its prayer for relief, the plaintiff requested judgment declaring that Defendant infringed one or more claims of the ʼ259 patent, a permanent injunction, under 35 U.S.C. § 283, prohibiting Defendant and its officers from committing further acts of infringement, an award of damages, including supplemental post-verdict damages along with pre- and post-judgment interest, and any other relief the court may deem necessary.
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1:22-CV-10632
04/27/2022
Disposed - Other Disposed
Intellectual Property - Patent
Angel Kelley
Bell Semiconductor, LLC
Advanced Micro Devices, Inc.
Raymond P. Ausrotas
Alexandra Figari Easley
Ashley Moore
David Sochia
Richard A. Kamprath
William F. McGonigle, III
Christopher Ponder
David S. Godkin
Ericka Jacobs Schulz
Harper Batts
James E. Kruzer
Jeffrey Liang
(#30) District Judge Angel Kelley: ORDER OF ADMINISTRATIVE STAY/CLOSING entered. (Lara, Miguel) (Entered: 06/22/2022)
(#29) Proposed Document(s) submitted by Advanced Micro Devices, Inc.. Document received: Proposed Order. (Godkin, David) (Entered: 06/16/2022)
(#28) DECLARATION re #26 Assented to MOTION to Stay (Unopposed) of David S. Godkin by Advanced Micro Devices, Inc.. (Godkin, David) (Entered: 06/16/2022)
Exhibit A
Main Document
(#26) Assented to MOTION to Stay (Unopposed) by Advanced Micro Devices, Inc..(Godkin, David) (Entered: 06/16/2022)
(#25) NOTICE of Appearance by Alexandra Figari Easley on behalf of Bell Semiconductor, LLC (Easley, Alexandra) (Entered: 06/14/2022)
(#24) NOTICE of Appearance by Richard A. Kamprath on behalf of Bell Semiconductor, LLC (Kamprath, Richard) (Entered: 06/14/2022)
(#23) NOTICE of Appearance by David Sochia on behalf of Bell Semiconductor, LLC (Sochia, David) (Entered: 06/14/2022)
(#2) REPORT ON THE FILING OF AN ACTION REGARDING PATENT OR TRADEMARK. (de Oliveira, Flaviana) (Entered: 04/28/2022)
AO120
proposed Summons
Category Form
Civil Cover Sheet
Exhibit C
Exhibit B
Exhibit A
Main Document
Docket(#30) District Judge Angel Kelley: ORDER OF ADMINISTRATIVE STAY/CLOSING entered. (Lara, Miguel) (Entered: 06/22/2022)
[-] Read LessDocket(#29) Proposed Document(s) submitted by Advanced Micro Devices, Inc.. Document received: Proposed Order. (Godkin, David) (Entered: 06/16/2022)
[-] Read LessDocket(#28) DECLARATION re #26 Assented to MOTION to Stay (Unopposed) of David S. Godkin by Advanced Micro Devices, Inc.. (Godkin, David) (Entered: 06/16/2022)
[-] Read LessDocket(#27) MEMORANDUM in Support re #26 Assented to MOTION to Stay (Unopposed) filed by Advanced Micro Devices, Inc.. (Attachments: #1 Exhibit A)(Godkin, David) (Entered: 06/16/2022)
[-] Read LessDocket(#26) Assented to MOTION to Stay (Unopposed) by Advanced Micro Devices, Inc..(Godkin, David) (Entered: 06/16/2022)
[-] Read LessDocket(#25) NOTICE of Appearance by Alexandra Figari Easley on behalf of Bell Semiconductor, LLC (Easley, Alexandra) (Entered: 06/14/2022)
[-] Read LessDocket(#24) NOTICE of Appearance by Richard A. Kamprath on behalf of Bell Semiconductor, LLC (Kamprath, Richard) (Entered: 06/14/2022)
[-] Read LessDocket(#23) NOTICE of Appearance by David Sochia on behalf of Bell Semiconductor, LLC (Sochia, David) (Entered: 06/14/2022)
[-] Read LessDocket(#22) NOTICE of Appearance by Ashley Moore on behalf of Bell Semiconductor, LLC (Moore, Ashley) (Entered: 06/14/2022)
[-] Read LessDocket(#21) District Judge Angel Kelley: ELECTRONIC ORDER entered GRANTING #16 Motion for Leave to Appear Pro Hac Vice. Added Harper Batts, Christopher Ponder, Jeffrey Liang, and Ericka Schulz. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. To register for a PACER account, go the Pacer website at # https://pacer.uscourts.gov/register-account.Pro Hac Vice Admission Request Instructions # https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. (Pacho, Arnold) (Entered: 06/08/2022)
[-] Read LessDocket(#10) MOTION for Leave to Appear Pro Hac Vice for admission of Alexandra Easley Filing fee: $ 100, receipt number AMADC-9330889 by Bell Semiconductor, LLC. (Attachments: #1 Text of Proposed Order, #2 Declaration)(McGonigle, William) (Entered: 05/19/2022)
[-] Read LessDocket(#9) MOTION for Leave to Appear Pro Hac Vice for admission of Ashley Moore Filing fee: $ 100, receipt number AMADC-9330888 by Bell Semiconductor, LLC. (Attachments: #1 Text of Proposed Order, #2 Declaration)(McGonigle, William) (Entered: 05/19/2022)
[-] Read LessDocket(#8) MOTION for Leave to Appear Pro Hac Vice for admission of David Sochia Filing fee: $ 100, receipt number AMADC-9330882 by Bell Semiconductor, LLC. (Attachments: #1 Text of Proposed Order, #2 Declaration)(McGonigle, William) (Entered: 05/19/2022)
[-] Read LessDocket(#7) MOTION for Leave to Appear Pro Hac Vice for admission of Richard Kamprath Filing fee: $ 100, receipt number AMADC-9330880 by Bell Semiconductor, LLC. (Attachments: #1 Text of Proposed Order, #2 Declaration)(McGonigle, William) (Entered: 05/19/2022)
[-] Read LessDocket(#6) SUMMONS Returned Executed Bell Semiconductor, LLC served on 5/4/2022, answer due 5/25/2022. (McGonigle, William) (Entered: 05/09/2022)
[-] Read LessDocket(#5) NOTICE of Appearance by William F. McGonigle, III on behalf of Bell Semiconductor, LLC (McGonigle, William) (Entered: 04/29/2022)
[-] Read LessDocket(#4) Summons Issued as to Advanced Micro Devices, Inc.. Counsel receiving this notice electronically should download this summons, complete one for each defendant and serve it in accordance with Fed.R.Civ.P. 4 and LR 4.1. Summons will be mailed to plaintiff(s) not receiving notice electronically for completion of service. (de Oliveira, Flaviana) (Entered: 04/28/2022)
[-] Read LessDocket(#3) ELECTRONIC NOTICE of Case Assignment. District Judge Angel Kelley assigned to case. If the trial Judge issues an Order of Reference of any matter in this case to a Magistrate Judge, the matter will be transmitted to Magistrate Judge Donald L. Cabell. (Finn, Mary) (Entered: 04/28/2022)
[-] Read LessDocket(#2) REPORT ON THE FILING OF AN ACTION REGARDING PATENT OR TRADEMARK. (de Oliveira, Flaviana) (Entered: 04/28/2022)
[-] Read LessDocket(#1) COMPLAINT for Patent Infringement against Advanced Micro Devices, Inc. Filing fee: $ 402, receipt number AMADC-9295432 (Fee Status: Filing Fee paid), filed by Bell Semiconductor, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Civil Cover Sheet, #5 Category Form, #6 proposed Summons (Ausrotas, Raymond) Modified on 4/28/2022 #7 AO120 form deleted and docketed as a separate entry (de Oliveira, Flaviana). (Entered: 04/27/2022)
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