Google Inc. v. Rockstar Consortium US LP et al

Filing 67

MOTION to Transfer Case or, in the Alternative to Stay filed by MobileStar Technologies LLC, Rockstar Consortium US LP. Motion Hearing set for 6/26/2014 02:00 PM in Courtroom 2, 4th Floor, Oakland before Hon. Claudia Wilken. Responses due by 5/23/2014. Replies due by 5/30/2014. (Attachments: # 1 Declaration of Joshua Budwin, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18, # 20 Exhibit 19, # 21 Exhibit 20, # 22 Exhibit 21, # 23 Exhibit 22, # 24 Exhibit 23, # 25 Exhibit 24, # 26 Exhibit 25, # 27 Exhibit 26, # 28 Exhibit 27, # 29 Exhibit 28, # 30 Exhibit 29, # 31 Exhibit 30, # 32 Exhibit 31, # 33 Exhibit 32, # 34 Exhibit 33, # 35 Exhibit 34, # 36 Exhibit 35, # 37 Declaration of William Colvin, # 38 Declaration of Brian Egan, # 39 Declaration of Erik Fako, # 40 Declaration of Mark Hearn, # 41 Declaration of Gillian Mccolgan, # 42 Declaration of Matthew Poisson, # 43 Declaration of Donald Powers, # 44 Declaration of Marilyn French-St. George, # 45 Declaration of John Veschi, # 46 Declaration of Bruce Anthony Wootton, # 47 Proposed Order)(Budwin, Joshua) (Filed on 5/9/2014)

EXHIBIT 29

U.S. Patent No. 5,838,551

Claim 1
ACCUSED PRODUCTS1
1.1
An The Accused Products include an electronic package.
electronic
package
For example:
comprising:
The Accused Products include an electronic package (e.g., electronic component(s) covered with an electronic shield). As
an example, a teardown of Pantech Discover smartphone reveals at least two electronic components covered with an EMI
shield. For example only, two of these components are microphones located at the bottom and on the back cover of the
phone respectively. The disassembly of Pantech Discover reveals two MEMS microphone packages: Mic-1 “M3K1 4312”
(at the bottom of the device) on a flex board and Mic-2 “M3K1 4312” (on the back cover of the device) on the main board.

1

The Accused Products include all of the devices listed in the Accused Products Spreadsheet attached to the ’551 patent infringement contentions and any other
product uncovered during discovery that includes an electronic component surrounded by an EMI shield/Faraday cage.

U.S. Patent No. 5,838,551

Claim 1

ACCUSED PRODUCTS1

2

2

All photographs herein are for the exemplary purpose of showing infringement by the Accused Products.

U.S. Patent No. 5,838,551

Claim 1

ACCUSED PRODUCTS1

U.S. Patent No. 5,838,551

Claim 1

ACCUSED PRODUCTS1

U.S. Patent No. 5,838,551

Claim 1

ACCUSED PRODUCTS1

U.S. Patent No. 5,838,551

Claim 1

ACCUSED PRODUCTS1

Rockstar reserves the right to add additional information and infringement theories once discovery begins in this case,

U.S. Patent No. 5,838,551

Claim 1

ACCUSED PRODUCTS1
particularly once the defendant produces its technical documents and circuit schematics.

1.2 a rigid
planar
dielectric
substrate
carrying
a
ground
member
extending
across
substantially
the whole area
within
the
confines of the
edges of the
substrate;

The Accused Products contain a rigid planar dielectric substrate carrying a ground member extending across substantially
the whole area within the confines of the edges of the substrate.
For example, each of the two electronic components in Pantech Discover comprises a rigid planar dielectric substrate
carrying a ground member extending across substantially the whole area of the substrate. The perspective image of the
electronic package for Mic-1, for example, shows the rigid planar dielectric substrate and the ground member extending
across the area of the substrate.

U.S. Patent No. 5,838,551

Claim 1

ACCUSED PRODUCTS1
Rockstar reserves the right to add additional information and infringement theories once discovery begins in this case,
particularly once the defendant produces its technical documents and circuit schematics.

1.3
an
electronic
component
mounted upon
a first side of
the substrate
and
having
terminals
connected to a
plurality
of
first
level
terminal
interconnects
provided upon
the first side of
the board;

The Accused Products contain an electronic component mounted upon a first side of the substrate and having terminals
connected to a plurality of first level terminal interconnects provided upon the first side of the board.
For example, each of the two electronic components in Pantech Discover identified is an electronic component mounted
upon the top side of the substrate. The external X-ray images for Mic-1, for example, show the ASIC and the MEMS die of
Mic-1.

U.S. Patent No. 5,838,551

Claim 1

ACCUSED PRODUCTS1

High resolution images of the decapsulated package also show terminals of Mic-1 that connect to first level interconnects
provided on the substrate. Further delayering of the package reveals the first level interconnects on the top layer that are in
turn also connected to circuit paths in the substrate.

U.S. Patent No. 5,838,551

Claim 1

ACCUSED PRODUCTS1

U.S. Patent No. 5,838,551

Claim 1

ACCUSED PRODUCTS1

Rockstar reserves the right to add additional information and infringement theories once discovery begins in this case,
particularly once the defendant produces its technical documents and circuit schematics.
1.4 a covering The Accused Products contain a covering EMI shield extending over the electronic component to locate the electronic

U.S. Patent No. 5,838,551

Claim 1
EMI
shield
extending over
the electronic
component to
locate
the
electronic
component
between
the
EMI shield and
the
ground
member of the
substrate, the
EMI
shield
being
electrically
interconnected
to the ground
member of the
substrate
to
form with the
ground
member,
a
Faraday cage
around
the
electronic
component;

ACCUSED PRODUCTS1
component between the EMI shield and the ground member of the substrate, the EMI shield being electrically interconnected
to the ground member of the substrate to form with the ground member, a Faraday cage around the electronic component.
For example, each of the two electronic components in Pantech Discover identified above is covered by an EMI shield that
locates the electronic component between the EMI shield and the ground member of the substrate. The external X-ray
images for Mic-1, for example, shows that the EMI shield extends over the electronic components, the ASIC and the MEMS
die of Mic-1.

U.S. Patent No. 5,838,551

Claim 1

ACCUSED PRODUCTS1

A resistance of 1.6 ohms measured between the top of the EMI shield and the bottom side of the substrate indicates that the

U.S. Patent No. 5,838,551

Claim 1

ACCUSED PRODUCTS1
EMI shield is electrically connected to the ground member.

Rockstar reserves the right to add additional information and infringement theories once discovery begins in this case,
particularly once the defendant produces its technical documents and circuit schematics.

U.S. Patent No. 5,838,551

Claim 1
1.5
and
a
plurality
of
second level
interconnects
mounted upon
a second side
of the substrate
and electrically
interconnected
through circuit
paths in the
substrate to the
first
level
interconnects.

ACCUSED PRODUCTS1
The Accused Products contain a plurality of second level interconnects mounted upon a second side of the substrate and
electrically interconnected through circuit paths in the substrate to the first level interconnects.
For example, each of the two electronic components in Pantech Discover identified above has a plurality of second level
interconnects mounted upon the second side of the substrate and electrically interconnected through circuit paths in the
substrate to the first level interconnects. For example, for Mic-1, the bond wires connect to the first level interconnects
which in turn are connected to second level interconnect on layer 2 of the package on the second side of the substrate
through circuit paths.

U.S. Patent No. 5,838,551

Claim 1

ACCUSED PRODUCTS1
Delayering of Mic-1 package, as an example, shows a plurality of second level interconnects mounted upon the second side
of the substrate (Layer 2) and electrically interconnected through circuit paths in the substrate to the first level interconnects.
The two layers between Layer 1 on the top side of the substrate and Layer 2 on the bottom side both contain at least two
interconnects at the identical locations as Layer 1 and Layer 2 to enable the circuit paths.

Rockstar reserves the right to add additional information and infringement theories once discovery begins in this case,

U.S. Patent No. 5,838,551

Claim 1

ACCUSED PRODUCTS1
particularly once the defendant produces its technical documents and circuit schematics.

Claim 2
2. A package
according to
claim
1
wherein
the
electronic
component
comprises an
integrated
circuit
component.

ACCUSED PRODUCTS
The Accused Products comprise a package according to claim 1 wherein the electronic component comprises an integrated
circuit component.
For example, the Accused Products, including Pantech Discover identified above, contain one or more microphones that
comprise an ASIC Die and a MEMS Die covered by an EMI shield. The ASIC Die is an integrated circuit component
manufactured specifically for use in the microphone.

U.S. Patent No. 5,838,551

Rockstar reserves the right to add additional information and infringement theories once discovery begins in this case,
particularly once the defendant produces its technical documents and circuit schematics.

Claim 3
3. A package
according to
claim
1
comprising
two or more
electronic
components
mounted upon
the first side of
the substrate
and at least one
of which is an
integrated
circuit
component and
all
of
the
components
are commonly
shielded by the
EMI shield.

ACCUSED PRODUCTS
The Accused Products include a package according to claim 1 comprising two or more electronic components mounted upon
the first side of the substrate and at least one of which is an integrated circuit component and all of the components are
commonly shielded by the EMI shield.
For example, the Accused Products, including Pantech Discover identified above, contain one or more microphones that
comprise an ASIC Die and a MEMS Die covered by an EMI shield. The ASIC Die is an integrated circuit component
manufactured specifically for use in the microphone.

U.S. Patent No. 5,838,551

Rockstar reserves the right to add additional information and infringement theories once discovery begins in this case,
particularly once the defendant produces its technical documents and circuit schematics.