COMPLAINT: M-Red Inc. v. Mediatek Inc.

FACTUAL ALLEGATIONS - The Asserted Patents: US Patent No. 6,853,259; US Patent No. 7,068,557 and US Patent No. 7,209,401 generally cover integrated circuits comprising voltage and temperate sensors which output a voltage and temperate and store the output in memory. The Asserted Patents also cover methods for dynamically adjusting clock frequency based on voltage and temperature values. In some embodiments of the inventions, temperature sensors dynamically monitor environmental parameters and store these parameters on a memory. These temperature monitoring and power saving techniques are incorporated into chips made by numerous manufacturers, including Mediatek. Upon information and belief, these products include all Mediatek SoCs, including at least Mediatek’s MT6XXX, MT8XXX, Helio, and Automotive products. For example, on information and belief, the MT8163 SoC is sold in the United States and incorporated by others into products sold in the United States, such as the Amazon Kindle products.

Case No. 2:19-cv-00141 assigned to Judge Gilstrap

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