IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION NARADA SYSTEMS, LLC,

A T EXAS L IMITED L IABILITY C OMPANY , Plaintiff, v. TABULA, INC., A DELAWARE CORPORATION, Defendant. Case No.

COMPLAINT FOR PATENT INFRINGEMENT Plaintiff, Narada Systems, LLC, by its attorneys, hereby complains against Defendant Tabula, Inc. and alleges: The Parties 1. Plaintiff, Narada Systems, LLC (Narada) is a Texas Limited Liability Company

with its principal place of business located in the city of Allen, Texas. 2. Defendant, Tabula, Inc. (Tabula) is, upon information and belief, a corporation

established under the laws of the State of Delaware, with its principal place of business located at 3250 Olcott Street, Santa Clara, California 95054. Jurisdiction and Venue 3. This Court has jurisdiction over the subject matter of this action under 28 U.S.C.

1331 and 1338(a) as this case arises under the Patent Laws of the United States, 35 U.S.C. 1 et seq.

4.

Venue properly lies in the Eastern District of Texas pursuant to 28 U.S.C.

1391(b) and (c) because a substantial part of the events giving rise to these claims occurred in the District, and a number of key witnesses reside in, or close to, the District. Background 5. On November 7, 2000, Inventor Gautam Kavipurapu (Kavipurapu) filed an ap-

plication for patent directed to a High Speed, Scalable, Dynamic Integrated Programmable Switch (DIPS) Device. 6. The aforementioned application duly and properly issued from the United States

Patent & Trademark Office as U.S. Pat. No. 6,504,786 (the 786 patent) on January 7, 2003. A true and correct copy of the 786 patent as issued is attached hereto as Exh. A. All right, title and interest in the 786 patent has been assigned to Narada. 7. On December 4, 2000 Kavipurapu filed a second application for patent directed to

a Dynamically Programmable Integrated Switching Device Using An Asymmetric 5T1C Cell. 8. The aforementioned application duly and properly issued from the United States

Patent & Trademark Office as U.S. Pat. No. 6,901,070 (the 070 patent) on May 31, 2005. A true and correct copy of the 070 patent as issued is attached hereto as Exh. B. All right, title and interest in the 070 patent has been assigned to Narada. 9. On August 9, 2002 Kavipurapu filed a third application based on an earlier filed

provisional application directed to an Intelligent Routing Switching System. 10. The aforementioned application duly and properly issued from the United States

Patent & Trademark Office as U.S. Pat. No. 7,236,488 (the 488 patent) on June 26, 2007. A true and correct copy of the 488 patent as issued is attached hereto as Exh. C. All right, title and interest in the 488 patent has been assigned to Narada.

11.

The patents-in-suit are the result of pioneering research and development con-

ducted by Kavipurapu in the field of switching and routing technologies. This research was performed in Texas, and the patent applications for all three patents were prepared and prosecuted by attorney James Murphy of Thompson & Knight, LLP, who maintains an office in Dallas, Texas. 12. The technology developed by Kavipurapu received substantial attention in the

technology community. For example, the attached paper, which was presented after the priority date of all of the patents-in-suit at the MWSCAS 2001 conference, discusses the use of the technology covered by the patents-in-suit to create a space-time switching fabric for use in a network router. See System Requirements for Super Terabit Routing, by Mehrdad Nourani, Gautam Kavipurapu, and Raju Gadiuraju, 2001, attached hereto as Exh. D. 13. Narada was formed in 2009 for the purpose of commercializing the technology

protected by the aforementioned patents. Narada is headquartered in the Eastern District of Texas and is managed by Richard Burnes, who is a long time resident of Allen Texas. 14. The inventor of the patents-in-suit is the named inventor on no fewer than ten pa-

tents. His inventions have been licensed for many millions of dollars. In particular, the 786 patent and the 488 patent were the subject of a previous case in this district, which was settled amicably by the parties. See Case No. 12-CV-0005 (E.D. Tex.). 15. Tabula has built their business on a switching and routing technology that it refers

to as SpaceTime. Tabula devices that are built on the SpaceTime technology reconfigures and performs eight operations in the same user clock cycle. See Tablua SpaceTime White Paper, attached hereto as Exh. E.

16.

The following figure, taken from Tabulas website, contrasts Tabulas

SpaceTime 3D Architecture with that of a traditional FPGA:

17.

One example of a SpaceTime technology developed and sold by Tabula is

SpaceTime Memory. The following figures, taken from Tabulas website, illustrate the operation of SpaceTime Memory:

18.

On information and belief, Tabulas SpaceTime Memory utilizes a switching

mechanism to couple memory into a logic fabric that is reconfigured up to eight times per cycle. 19. Tabula products that implement its SpaceTime and/or SpaceTime Memory

technologies include its ABAX line of programmable logic, including, but not limited to, the A1EC02, A1EC03 and A1EC04. 20. On information and belief, Tabula produces a number of products that can be used

as network interface chips, include a network port, and incorporate Tabulas SpaceTime and/or SpaceTime Memory technologies. These products include the Tabula I-100 Ethernet-

Interlaken bridge, the I-40 Ethernet-Interlaken bridge, a number of packet search engine chips such as the TSE100x1, and the NetASAPdc virtualized route/switch/firewall/programmable NIC. 21. On information and belief, Tabula generates substantial revenue from sales of

products that incorporate its SpaceTime and/or SpaceTime Memory technologies. For example, Tabula has been identified as one of the Next Big Things startups and has been attributed as raising more than $215 million in capital.

22.

On information and belief, Tabula markets its products to product companies, en-

gineering companies, research organizations, and other entities engaged in the design of electronics requiring programmable logic. These entities are its customers and/or partners. 23. On information and belief, and by way of example, Cisco Systems, Inc. (Cisco)

uses chips designed, developed, and/or manufactured by Tabula in its networking products. Cisco has offices in Irving, Texas; Richardson, Texas; San Antonio, Texas; and Houston, Texas. 24. On information and belief, Tabula does business with other Texas companies, in-

cluding companies with facilities in the Eastern District of Texas. 25. Tabula uses Intel to fabricate its semiconductor products, and advertises that it us-

es Intels 22nm Processing Featuring 3D Tri-Gate Transistors. See Tabula Process, attached hereto as Exh. F. COUNT 1 Infringement of U.S. Pat. No. 6,504,786 26. Plaintiff incorporates by reference and realleges each and every allegation con-

tained in Paragraphs 1 through 25. 27. On information and belief, Tabula SpaceTime and/or SpaceTime Memory tech-

nology(ies) utilize(s) a switching fabric that selectively couples an output port to a memory element through a plurality of input ports. 28. On information and belief, Tabula has infringed and continues to infringe the 786

patent. The infringing acts include, but are not necessarily limited to, making, having made, offering for sale, selling and distributing the Infringing Products identified in Paragraphs 14-18 above. 29. On information and belief, Tabula also induces and/or contributes to infringement

of the 786 by its customers and/or partners, as well as its manufacturers. 6

30.

Tabulas acts of infringement have caused damage to Narada. Under 35 U.S.C.

284, Narada is entitled to recover no less than a reasonable royalty from Tabula for Tabulas infringement of the 786 patent. Tabulas infringement of Naradas exclusive rights under the 786 patent will continue to damage Narada causing irreparable harm, for which there is no adequate remedy of law, unless enjoined by this Court under 35 U.S.C. 283. COUNT 2 Infringement of U.S. Pat. No. 6,901,070 31. Plaintiff incorporates by reference and realleges each and every allegation con-

tained in Paragraphs 1 through 30. 32. On information and belief, Tabula SpaceTime and/or SpaceTime Memory tech-

nology(ies) utilize(s) a switching fabric that incorporates a plurality of memory cells, a plurality of port blocks each of which comprises a plurality of input-output ports, read decoder circuitry to select one of the aforementioned input ports and read data from one of the aforementioned memory cells in a second port block, as well as write decoder circuitry for selecting of the aforementioned input-output ports of a second port block so that data can be written into a memory cell in the second port block. 33. On information and belief, Tabula has infringed and continues to infringe the 070

patent. The infringing acts include, but are not necessarily limited to, making, having made, offering for sale, selling and distributing the Infringing Products identified in Paragraphs 14-18 above. 34. On information and belief, Tabula also induces and/or contributes to infringement

of the 786 by its customers and/or partners, as well as its manufacturers. 35. Tabulas acts of infringement have caused damage to Narada. Under 35 U.S.C.

284, Narada is entitled to recover no less than a reasonable royalty from Tabula for Tabulas in7

fringement of the 070 patent. Tabulas infringement of Naradas exclusive rights under the 070 patent will continue to damage Narada causing irreparable harm, for which there is no adequate remedy of law, unless enjoined by this Court under 35 U.S.C. 283. COUNT 3 Infringement of U.S. Pat. No. 7,236,488 36. Plaintiff incorporates by reference and realleges each and every allegation con-

tained in Paragraphs 1 through 35. 37. On information and belief, certain Tabula products, including the Tabula products

mentioned in Paragraph 19 incorporate an interface for coupling an internal switching fabric implemented using Tabula SpaceTime and/or Tabula SpaceTime Memory technolog(y)(ies). On information and belief, the switching fabric includes an array of multiport switching elements, each including switches and memory elements, and the switching fabric selectively routes bits of data exchanged with the external network through the interface. In addition, on information and belief, the aforementioned Tabula products incorporate one or more controllers that implement a routing table and scheduler along with a sequencing graph that control the flow of bits through the switching fabric. 38. On information and belief, Tabula also induces and/or contributes to infringement

of the 786 by its customers and/or partners, as well as its manufacturers. 39. On information and belief, Tabula has infringed and continues to infringe the 488

patent. The infringing acts include, but are not necessarily limited to, making, having made, offering for sale, selling and distributing the Infringing Products identified in Paragraph 19 above. WHEREFORE, Plaintiff, Narada Systems, LLC, prays that his Court enter judgment in favor of Plaintiff and against Defendant Tabula, Inc. finding that Defendant has infringed the

claims of U.S. Pat. Nos. 6,504,786, 6,901,070, and 7,236,488 patents (the patents-in-suit) and Ordering as follows: A. B. C. D. E. F. G. U.S. Pat. No. 6,504,786 is good and valid in law; Tabula has and continues to infringe the 786 patent; U.S. Pat. No. 6,901,070 is good and valid in law; Tabula has and continues to infringe the 070 patent; U.S. Pat. No. 7,236,488 is good and valid in law; Tabula has and continues to infringe the 488 patent; Tabula and its respective directors, officers, employees, agents, subsidiaries, par-

ents, attorneys, and all persons acting in concert, on behalf of, in joint venture, or in partnership with Tabula be preliminary and permanently enjoined under 35 U.S.C. 283 against any further acts of infringement; H. For a judgment that this cause is exceptional in the sense of 35 U.S.C. 285

and that Narada is entitled to an award of its reasonable attorneys fees in the prosecution of this action; I. For an award of damages adequate to compensate Narada for the past infringe-

ment of the patents-in-suit, together with interest and costs as fixed by the Court; J. That the Court grants all other relief as is reasonable to remedy Defendants

wrongful acts by any mean, either at law or in equity.

Date: April 17, 2013

By: /s/ D. Jeffrey Rambin S. Calvin Capshaw Texas State Bar No. 03783900 E-Mail: ccapshaw@capshawlaw.com Elizabeth L. DeRieux Texas State Bar No. 05770585 E-mail: ederieux@capshawlaw.com D. Jeffrey Rambin Texas State Bar No. 00791478 Email: jrambin@capshawlaw.com CAPSHAW DERIEUX, LLP 114 E. Commerce Ave. Gladewater, Texas 75647 Telephone: (903) 236-9800 Facsimile: (903) 236-8787

OF COUNSEL: Konrad Sherinian Attorney at Law ksherinian@sherinianlaw.net The Law Offices of Konrad Sherinian, LLC 1755 Park Street, Suite # 200 Naperville, Illinois 60563 Telephone: (630) 318-2606 Facsimile: (630) 318-2605

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