“Plaintiff Bandspeed, LLC (“Bandspeed”), by and through its attorneys, files its Complaint against defendant Realtek Semiconductor Corporation (“Defendant”), and hereby alleges as follows: I. NATURE OF ACTION 1. This is a patent infringement action to end Defendant’s unauthorized and infringing manufacture, use, sale, offering for sale, and/or importation of methods and products incorporating Bandspeed’s patented inventions. 2. Bandspeed is the owner of all right, title, and interest in and to: a. United States Patent No. 7,027,418 (“the ’418 Patent”), issued on April 11, 2006; b. United States Patent No. 7,477,624 (“the ’624 Patent”), issued on January 13, 2009; c. United States Patent No. 7,570,614 (“the ’614 patent”), issued on August 4, 2009; d. United States Patent No. 7,903,608 (“the ’608 Patent”), issued on March 8, 2011; e. United States Patent No. 8,542,643 (“the ’643 Patent”), issued on September 24, 2013; Case 1:20-cv-00765-DAE Document 1 Filed 07/20/20 Page 1 of 57 2 f. United States Patent No. 8,873,500 (“the ’500 Patent”), issued on October 28, 2014; g. United States Patent No. 9,379,769 (“the ’769 Patent”), issued on June 28, 2016; h. United States Patent No. 9,883,520 (“the ’520 Patent”), issued on January 30, 2018. 3. The ’418 Patent, ’624 Patent, ’614 Patent, ’608 Patent, ’643 Patent, ’500 Patent, ’769 Patent, and ’520 Patent are, collectively, the “Patents.” 4. Bandspeed has all substantial right and interest to the Patents, including all rights to recover for all past and future infringement thereof. 5. Upon information and belief, Defendant has been and currently is infringing, contributing to the infringement of, and/or inducing the infringement of Bandspeed’s Patents, by, among other things, making, using, selling, importing, and/or offering for sale, within the territorial boundaries of the United States and the State of Texas, products that are covered by one or more claims of Bandspeed’s Patents and inducing such conduct by others. 6. Defendant manufactures, provides, sells, offers for sale, imports, and/or distributes Infringing Products (as defined herein) and services; and/or induces others to make and use of its Infringing Products and services in an infringing manner; and/or contributes to the making and use of Infringing Products and services by others, including its customers, who directly infringe the Patents. II. THE PARTIES 7. Plaintiff Bandspeed is a Texas limited liability company with its principal place of business located in Austin, Texas. Case 1:20-cv-00765-DAE Document 1 Filed 07/20/20 Page 2 of 57 3 8. Upon information and belief, Defendant Realtek Semiconductor Corporation is a corporation organized and existing under the laws of Taiwan, with a place of business located at No. 2, Innovation Road II, Hsinchu Science Park, Hsinchu 300, Taiwan. 9. Realtek Semiconductor Corporation may be served with process by serving the Texas Secretary of State, James E. Rudder Building, 1019 Brazos Street, Austin, Texas 78701, as its agent for service because it engages in business in Texas but has not designated or maintained a resident agent for service of process in Texas as required by statute. This action arises out of that business. 10. Defendant manufactures and distributes electronics. Defendant, either itself and/or through the activities of its subsidiaries or agents, makes, uses, sells, offers for sale, and/or imports throughout the United States, including within this District, products, such as electronics, semiconductor devices, and integrated circuits, that infringe the Asserted Patents, defined below.”