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Michael A. Oblon (pro hac vice motion to be filed) MOblon@perkinscoie.com PERKINS COIE LLP 700 13th Street NW, Suite 600 Washington, D.C. 20005 Telephone: 202.434.1607 Facsimile: 202.654.9138 Bryan S. Banks (#023085) BBanks@perkinscoie.com Jerica L. Peters (#027356) JPeters@perkinscoie.com PERKINS COIE LLP 2901 North Central Avenue, Suite 2000 Phoenix, Arizona 85012-2788 Telephone: 602.351.8000 Facsimile: 602.648.7000 Attorneys for Plaintiffs ON Semiconductor Corporation and Semiconductor Components Industries, LLC UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ON Semiconductor Corporation and Semiconductor Components Industries, LLC, Plaintiffs, v. Plasma-Therm Corporation, Defendant. No. COMPLAINT FOR PATENT INFRINGEMENT, BREACH OF CONTRACT, TRADE SECRET MISAPPROPRIATION, AND UNJUST ENRICHMENT JURY TRIAL DEMANDED

For its complaint, Plaintiffs ON Semiconductor Corporation and Semiconductor Components Industries, LLC allege the following: The Parties 1. Plaintiffs ON Semiconductor Corporation and Semiconductor Components Industries, LLC (referred to individually and collectively as ON Semiconductor) are Delaware corporations having their principal place of business at 5005 East McDowell Road, Phoenix, AZ 85008. Semiconductor Components Industries, LLC is the principal

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domestic operating subsidiary of ON Semiconductor Corporation, and does business under the name of ON Semiconductor. 2. ON Semiconductor is a global designer and manufacturer of semiconductor

devices used in the automotive, consumer electronics, medical, military, and other applications. 3. ON Semiconductor was formed in 1999 as a spinoff of Motorolas

Semiconductor Products business and operates design centers and manufacturing facilities throughout North America, Europe, and Asia. 4. ON Semiconductor has invested and continues to invest heavily in

developing innovative new semiconductor products and semiconductor manufacturing technologies. 5. On information and belief, Defendant Plasma-Therm Corporation (Plasma-

Therm or Defendant) is a Florida corporation having its principal place of business at 10050 16th Street. N. St. Petersburg, Florida 33716. 6. Plasma-Therm manufactures and sells equipment that is used to

manufacture semiconductor devices. Jurisdiction 7. ON Semiconductors Complaint includes causes of action for patent infringement against Plasma-Therm arising under the patent laws of the United States, including 35 U.S.C. 271 and 281. Consequently, this Court has original subject matter jurisdiction over this suit pursuant to 28 U.S.C. 1331 and 1338. Additionally, this Court has jurisdiction over the subject matter of the state law claims in this action pursuant to 28 USC 1332(a) because this action is between citizens of different states and the amount in controversy exceeds the sum of $75,000, exclusive of interest and costs. This Court also has supplementary jurisdiction over the state law claims pursuant to 28 U.S.C. 1367. 8. Plasma-Therm is subject to the specific and general personal jurisdiction of

this Court because, among other things, it has established continuous and systematic
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contacts with Arizona and with this judicial district, it has committed acts within Arizona and this judicial district giving rise to this action, and it has minimum contacts with the forum such that the exercise of jurisdiction over the Plasma-Therm would not offend traditional notions of fair play and substantial justice. Plasma-Therm has offered for sale, and sells numerous pieces of semiconductor fabrication equipment to customers in Arizona and in this district. Plasma-Therm has also conducted business with ON

Semiconductor within Arizona and in this district, and that business has given rise to this action. 9. Pursuant to 28 U.S.C. 1391 and/or 1400(b), this Court is a proper venue

for this action. Background Facts 10. Before August of 2007, ON Semiconductors employee Gordon M. Grivna invented a novel technique for separating semiconductor wafers into numerous individual semiconductor chips (a process sometimes called dicing or singulating). 11. On August 7, 2007 Mr. Grivna filed the first of several patent applications

to protect this new technique. 12. Mr. Grivna assigned the patent applications for this new singulation

technique to ON Semiconductor. 13. Following Mr. Grivnas invention, ON Semiconductor began seeking out a

vendor to supply equipment to be used for this new technique. 14. On January 20, 2008 ON Semiconductor and Plasma-Therm entered into a

Confidentiality and Non-Disclosure Agreement (the 2008 NDA) providing among other things that Confidential Information disclosed hereunder may only be used for . . . discussions related to opportunities for joint product development and future business engagements. 15. The January 20, 2008 NDA was renewed on April 2, 2010, when ON

Semiconductor and Plasma-Therm entered a similar Confidential and Non-Disclosure

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Agreement (the 2010 NDA), and was renewed again on March 13, 2013 (the 2013 NDA). 16. During the several years following the 2008 NDA, ON Semiconductor

worked with Plasma-Therm to develop plasma etching equipment useful for performing Mr. Grivnas singulation technique in ON Semiconductors manufacturing operations. 17. In the context of that work, ON Semiconductor provided Plasma-Therm

with confidential information including, without limitation: confidential information about how to carry out Mr. Grivnas singulation technique; confidential information about the design of equipment to carry out the new technique; confidential information about various parameters or recipes to be used to carry out the new technique; confidential information about ON Semiconductors semiconductor manufacturing processes, and how the new technique would fit within those processes; confidential information regarding other related manufacturing processes that would have to be implemented to successfully apply Mr. Grivnas new technique; confidential information regarding supplies and equipment that would be necessary to carry out the new technique; confidential information regarding process requirements that would have to be met for the new technique to work in a production environment; and confidential information regarding the advantages that a

semiconductor manufacturer (such as ON Semiconductor) would obtain by implementing the new technique.

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18.

ON Semiconductor disclosed confidential and proprietary information to

Plasma-Therm on several occasions, including, without limitation: through periodic face-to-face and telephonic engineering

conversations between Plasma-Therm employees and Mr. Grivna and other ON Semiconductors employees; at a July 12, 2010 presentation given at ON Semiconductors Phoenix, Arizona headquarters and attended by several of ON

Semiconductors and Plasma-Therms employees; and at a March 16, 2011 presentation given at ON Semiconductors Phoenix, Arizona headquarters and attended by several of ON Semiconductors and Plasma-Therms employees. 19. When Plasma-Therms employees visited ON Semiconductors

headquarters to attend meetings, including the July 12, 2010 and the March 16, 2011 meetings, the employees signed a log requiring that they preserve ON Semiconductors proprietary information. Specifically, Plasma-Therms employees each agreed that: I will not copy or remove ON Semiconductor proprietary information, nor will I use or disclose to any third party any information which comes to my attention at ON Semiconductor, except as required in the performance of my work at ON Semiconductor and when specifically authorized to do so in writing by ON Semiconductor. I realize that my obligation to this agreement continues after the completion of my work/visit to ON Semiconductor until such information is subsequently released to the public. 20. Before ON Semiconductor had initiated discussions with Plasma-Therm

about altering the design of Plasma-Therms etching equipment so as to perform die singulation, Plasma-Therm had not performed development work and was not aware of a technique for performing die singulation by etching. Plasma-Therm relied extensively upon ON Semiconductors knowledge and expertise concerning semiconductor design and fabrication so as to understand, for example, the technical challenges to overcome, the

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features to be incorporated, and the testing necessary to be performed to develop a tool for performing die singulation. 21. ON Semiconductor and Plasma-Therm ultimately developed a plasma

etching tool (called the MDS) for use in performing ON Semiconductors new singulation technique. Plasma-Therm fabricated an MDS unit to be provided to ON Semiconductor in addition to a lab unit. Plasma-Therm used ON Semiconductors

confidential information to design, develop, and configure the units. At the outset, ON Semiconductor understood that its confidential information was being used for purposes of joint product development efforts. 22. Plasma-Therm understood that it could not market or sell the MDS tool

without authorization from ON Semiconductor, because the tool was developed based upon ON Semiconductors confidential information disclosed pursuant to the parties NDAs, and also because use of the tool practiced several claims of ON Semiconductors patents. 23. Plasma-Therm acknowledged to ON Semiconductor that a license from ON

Semiconductor was necessary before Plasma-Therm could demonstrate the tool and offer it for sale to potential customers. 24. On several occasions, ON Semiconductor and Plasma-Therm engaged in

discussions regarding several potential arrangements under which ON Semiconductor would provide the licenses necessary for Plasma-Therm to market the MDS to third parties. The parties exchanged several draft term sheets in which Plasma-Therm

acknowledged that a license from ON Semiconductor was required before Plasma-Therm could market or sell the MDS tool. The parties agreed to an exclusivity period where Plasma-Therm would not sell the die singulation tool to certain companies specified by ON Semiconductor for a period of time. The parties had agreed that Plasma-Therm would pay ON Semiconductor a license fee associated with each system sold, but the parties did not reach agreement on all aspects of the fee structure, , and a final term sheet was not signed.
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25.

Once the parties could not reach an agreement concerning the licensing

terms, Plasma-Therm continued using ON Semiconductors confidential information to continue developing the MDS lab unit, even though the information was no longer being used for purposes of joint product development as required by the parties 2008, 2010, and 2013 NDAs. 26. Although it had not reached any agreement with ON Semiconductor that

would allow it to do so, Plasma-Therm began demonstrating and offering the MDS for sale, at least as of October 1, 2013 at the International Microelectronics Assembly and Packaging Society (IMAPS) trade show. 27. In connection with its efforts to sell the MDS, Plasma-Therm has publicly

distributed marketing materials that disclose ON Semiconductors confidential and proprietary information, without ON Semiconductors authorization. 28. On information and belief, in connection with its efforts to sell the MDS,

Plasma-Therm demonstrated the MDS to its customers or prospective customers before October 1, 2013 and continues to demonstrate the MDS to its customers, without ON Semiconductors authorization. Patents at Issue 29. On August 24, 2010, the United States Patent and Trademark Office duly and legally issued Mr. Grivnas August 7, 2007 patent application as United States Patent No. 7,781,310 (the 310 patent), entitled Semiconductor Die Singulation Method. ON Semiconductor holds all right, title, and interest in the 310 patent, including the right to sue for past, present, and future infringement. A copy of the 310 patent is attached to this Complaint as Exhibit A. 30. On July 26, 2011, the United States Patent and Trademark Office duly and

legally issued United States Patent No. 7,985,661 (the 661 patent), entitled Semiconductor Die Singulation Method, as a continuation of the 310 patent. ON Semiconductor holds all right, title, and interest in the 661 patent, including the right to

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sue for past, present, and future infringement. A copy of the 661 patent is attached to this Complaint as Exhibit B. COUNT I - INFRINGEMENT OF U.S. PAT. NO. 7,781,310 31. ON Semiconductor realleges and incorporates by reference each of paragraphs 1-30 above. 32. On information and belief, Plasma-Therm has infringed and continues to

infringe at least one of the claims of the 310 patent under 35 U.S.C. 271, either literally or under the doctrine of equivalents. 33. On information and belief, Plasma-Therm directs and controls its customers

or prospective customers to perform certain steps and then itself performs each of the remaining steps of one or more claims of the 310 patent in connection with testing and demonstrations of Plasma-Therms MDS tool. 34. Additionally or alternatively, Plasma-Therm actively induces infringement

of at least one of the claims of the 310 patent under 35 U.S.C. 271(b). 35. On information and belief, Plasma-Therm and its customer(s) together have

performed each and every step of one or more claims of the 310 patent during testing and demonstrations of Plasma-Therms MDS tool. 36. On information and belief, Plasma-Therm teaches, instructs, encourages, or

otherwise causes its customers or potential customers to perform certain steps claimed in the 310 patent. For example, on information and belief, Plasma-Therm instructs its customers or potential customers to provide patterned wafers that are ready to be singulated. 37. After its customers or potential customers provide patterned wafers, Plasma-

Therm itself practices the remaining steps of one or more claims of the 310 patent by singulating wafers provided by its customers. 38. Plasma-Therm has and continues to induce infringement with knowledge of

the 310 patent. For example, Plasma-Therm was on notice of the 310 patent at least as early as July 15, 2010, when Mr. Grivna provided the publication numbers for the
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application that became the 310 patent to David Lishan of Plasma-Therm. Additionally, ON Semiconductor identified the 310 patent in draft term sheets and other documentation relating to proposed licensing. 39. Plasma-Therm therefore has actual knowledge of the infringement which it

has caused and continues to cause. 40. intentional. COUNT II - INFRINGEMENT OF U.S. PAT. NO. 7,985,661 41. ON Semiconductor realleges and incorporates by reference each of paragraphs 1-40 above. 42. On information and belief, Plasma-Therm has infringed and continues to Plasma-Therms infringement of the 310 patent has been willful and

infringe at least one of the method claims of the 661 patent under 35 U.S.C. 271, either literally or under the doctrine of equivalents. 43. On information and belief, Plasma-Therm directs and controls its customers

or prospective customers to perform certain steps and then itself performs each of the remaining steps of one or more claims of the 661 patent in connection with testing and demonstrations of Plasma-Therms MDS tool. 44. Additionally or alternatively, Plasma-Therm actively induces infringement

of the 661 patent under 35 U.S.C. 271(b). 45. On information and belief, Plasma-Therm and its customer(s) together have

performed each and every step of one or more claims of the 661 patent during testing and demonstrations of Plasma-Therms MDS tool. 46. On information and belief, Plasma-Therm teaches, instructs, encourages, or

otherwise causes its customers or prospective customers to perform certain steps claimed in the 661 patent. For example, on information and belief, Plasma-Therm instructs its customers or prospective customers to provide patterned wafers that are ready to be singulated.

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47.

After its customers provide patterned wafers, Plasma-Therm itself practices

the remaining steps of one or more claims of the 661 patent by singulating wafers provided by its customers. 48. Plasma-Therm has and continues to induce infringement with knowledge of

the 661 patent. For example, Plasma-Therm was on notice of the 661 patent at least as early as July 15, 2010, when Mr. Grivna provided the publication numbers for the application that became the 661 patent to David Lishan of Plasma-Therm. Additionally, ON Semiconductor identified the application for 661 patent in draft term sheets and other documentation relating to proposed licensing. Plasma-Therm therefore has actual

knowledge of the infringement which it has caused and continues to cause. 49. intentional. COUNT III - BREACH OF CONTRACT 50. ON Semiconductor realleges and incorporates by reference each of paragraphs 1-49 above. 51. Under the 2008, 2010, and 2013 NDAs, Plasma-Therm was obligated to Plasma-Therms infringement of the 661 patent has been willful and

refrain from publicly disclosing ON Semiconductors confidential information. 52. Under the 2008, 2010, and 2013 NDAs, Plasma-Therm was prohibited from

using ON Semiconductors confidential information for purposes other than the joint product development and future business engagements of ON Semiconductor and Plasma-Therm. 53. Plasma-Therm has publicly disclosed and misused ON Semiconductors

confidential information in breach of the 2008, 2010, and 2013 NDAs and in violation of the agreements that Plasma-Therm had signed upon visiting ON Semiconductors facility, including on July 12, 2010 and March 16, 2011. Such disclosures include, without limitation: disclosures in published patent applications filed by Plasma-Therm claiming technologies relating to Mr. Grivnas invention;
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disclosures in connection with marketing and promotion of PlasmaTherms MDS tool; and disclosures made by public displays and use of the MDS tool.

Plasma-Therms development of an MDS tool that it did not provide to ON

Semiconductor constitutes a misuse of ON Semiconductors confidential information, outside the purpose of ON Semiconductors disclosure of the confidential information pursuant to the parties 2008, 2010, and 2013 NDAs. 55. Plasma-Therm has breached the parties 2008, 2010 and 2013 NDAs and

violated the agreements that it signed upon visiting ON Semiconductors facility. PlasmaTherms conduct has resulted in damages to ON Semiconductor of a type and in an amount to be proven at trial. COUNT IV - TRADE SECRET MISAPPROPRIATION ON Semiconductor realleges and incorporates by reference each of paragraphs 1-55 above. 57. Plasma-Therm has misappropriated ON Semiconductors trade secrets under

the Arizona Uniform Trade Secrets Act, A.R.S. 44-401 et seq. 58. While working with Plasma-Therm, ON Semiconductor disclosed trade

secrets to Plasma-Therm, including, without limitation, the information set forth above. 59. The trade secrets disclosed by ON Semiconductor to Plasma-Therm were

not publicly known or readily ascertainable from public information. 60. The trade secrets disclosed by ON Semiconductor to Plasma-Therm are

independently valuable because they are not generally known to or readily ascertainable to persons who can obtain economic value from their disclosure or use. 61. ON Semiconductors efforts to maintain the confidentiality of the disclosed

trade secrets were reasonable under the circumstances. For example, ON Semiconductor understood that Plasma-Therm had agreed under one or more NDAs to limit its use of ON Semiconductors trade secrets to discussions with ON Semiconductor relating to plasma dicing opportunities and for joint development and future business engagements between
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ON Semiconductor and Plasma-Therm relating to dicing. Plasma-Therm also signed agreements upon visiting ON Semiconductors facilities, obligating Plasma-Therm not to disclose or use ON Semiconductors proprietary information in any unauthorized manner. 62. Plasma-Therm misappropriated ON Semiconductors trade secrets under at

least A.R.S. 44-401(2)(b)(ii) either by obtaining them by improper means or otherwise by disclosing and using them without express or implied consent, and with knowledge that those secrets were acquired under circumstances giving rise to a duty to maintain their secrecy and limit their use. 63. Plasma-Therm has made unauthorized public disclosures of ON

Semiconductors confidential information including, without limitation: 64. disclosures in patent applications filed by Plasma-Therm claiming technologies relating to Mr. Grivnas invention; disclosures in connection with marketing and promotion of PlasmaTherms MDS tool; and disclosures made by public displays and use of the MDS tool.

On information and belief, Plasma-Therm has made unauthorized use of ON

Semiconductors confidential information including, without limitation: Plasma-Therm has used ON Semiconductors confidential

information to market and promote Plasma-Therms MDS tool to third parties, including ON Semiconductors competitors; Plasma-Therm has used ON Semiconductors confidential

information to manufacture MDS tools for sale to third parties including ON Semiconductors competitors; Plasma-Therm has used ON Semiconductors confidential

information to teach its customers how to perform Plaintiffs singulation technique; and

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Plasma-Therm

has

used

ON

Semiconductors

confidential

information to configure MDS tools sold or offered for sale to third parties to perform ON Semiconductors singulation technique. Plasma-Therm knew that the material obtained from ON Semiconductor and

later improperly used constituted trade secrets. Plasma-Therms misappropriation has been willful and malicious. 66. Plasma-Therms conduct has resulted in damages to ON Semiconductor of a

type and in an amount to be proven at trial. COUNT V - UNJUST ENRICHMENT ON Semiconductor incorporates by reference the allegations contained in paragraphs 1-66 above. 68. Over the course of several years, ON Semiconductor provided a business

opportunity, technology, know-how, advice and counsel, hundreds of hours of time for engineering and design services and testing, travel, and other efforts to jointly develop the MDS with Plasma-Therm. ON Semiconductor made these contributions with the

expectation, based upon Plasma-Therms repeated oral and written representations, that ON Semiconductor would become a partner with Plasma-Therm to commercialize the MDS on terms reasonable for both parties, including, at a minimum, royalty payments to ON Semiconductor and limited exclusivity so that the MDS would not be provided to and used by ON Semiconductors competitors for at least a limited period of time. Instead, once the design, development and testing of the MDS was completed, Plasma-Therm ceased having business discussions with ON Semiconductor and instead proceeded to market and promote the MDS on its own, without providing any accounting to ON Semiconductor. 69. Plasma-Therm has been unjustly enriched, at the expense of ON

Semiconductor, through Plasma-Therms conduct described above, for Plasma-Therms own benefit and without compensation to ON Semiconductor.

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70.

Under these circumstances, it would be inequitable for Plasma-Therm to

retain the profits made from such conduct. 71. To the extent there is no remedy at law to recover amounts by which ON

Semiconductor has been impoverished, ON Semiconductor is entitled to recover those amounts by which Plasma-Therm has been unjustly enriched. REQUEST FOR RELIEF WHEREFORE, ON Semiconductor respectfully requests judgment in their favor and against Plasma-Therm as follows: (a) patents; (b) and 661 patents; (c) An award of damages to be paid by Plasma-Therm to ON An injunction prohibiting Plasma-Therm from infringing the 310 An adjudication that Plasma-Therm has infringed the 310 and 661

Semiconductor adequate to compensate ON Semiconductor for Plasma-Therms past infringement of the 310 and 661 patents; (d) An injunction ordering Plasma-Therm to pay an ongoing royalty in

an amount to be determined for any continued infringement of the 310 and 661 patents; (e) An award of enhanced damages under 35 U.S.C. 284 for Plasma-

Therms willful infringement of the 310 and 661 patents; (g) An injunction prohibiting Plasma-Therm from publicly disclosing

ON Semiconductors trade secrets and confidential information; (h) An injunction prohibiting Plasma-Therm from using ON

Semiconductors trade secrets and confidential information; (i) An award for damages for Plasma-Therms breach of contract and

unlawful misappropriation of ON Semiconductors trade secrets under A.R.S. 44403(B); (j) An award for damages for Plasma-Therms unjust enrichment

pursuant to A.R.S. 44-403(A);

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(k)

An award of ON Semiconductors costs and attorneys fees incurred

in this action pursuant to A.R.S. 44-404, A.R.S. 12-341.01, and 35 U.S.C. 285; and (l) For such other or further relief as may be deemed just and

DEMAND FOR JURY TRIAL ON Semiconductor hereby demands a trial by jury on all issues so triable. Dated: October 31, 2013 PERKINS COIE LLP By: /s/ Bryan S. Banks Bryan S. Banks Jerica L. Peters 2901 North Central Avenue, Suite 2000 Phoenix, Arizona 85012-2788 Michael A. Oblon (pro hac vice motion to be filed) PERKINS COIE LLP 700 Thirteenth Street, N.W., Suite 600 Washington, D.C. 20005-3960 Attorneys for Plaintiffs ON Semiconductor Corporation and Semiconductor Components Industries, LLC

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