CHIP PACKAGING TECHNOLOGIES, LLC v. STMicroelectronics, Inc. — Entry #57: Miscellaneous Objection to [50] Order STMicroelectronics, Inc.'s Rule 72(a) Objections to the August 17, 2026 Order regarding Discovery Dispute Over Product…
Case: CHIP PACKAGING TECHNOLOGIES, LLC v. STMicroelectronics, Inc. txwd · 7:25-cv-00505
filed October 30, 2025
What this document is
Docket entry #57 · filed August 31, 2026
Miscellaneous Objection to [50] Order STMicroelectronics, Inc.'s Rule 72(a) Objections to the August 17, 2026 Order regarding Discovery Dispute Over Product Identification by STMicroelectronics, Inc.. (Attachments: (1) Exhibit A)(Becker, Jeffery)
Who is involved
- CHIP PACKAGING TECHNOLOGIES, LLC,
- STMicroelectronics, Inc.
Why we have it
We follow this case because it names a company we track, although that company is not a party:
- Marathon Digital: its former name “MARA Holdings, Inc.” appears in a filing in this case.
…..........1 Malikie Innovations Ltd. v. MARA Holdings, Inc., No. 7:25-cv-00222-DC-DTG, Dkt. No. 94…
A free copy from the RECAP archive of federal court filings (mirrored at the Internet Archive), retrieved November 01, 2026. Federal court filings are public records.
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Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 1 of 28
EXHIBIT A
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 2 of 28
May 14, 2026
[Via Email]
Jeffery S. Becker
Baker Botts L.L.P.
2001 Ross Avenue, Suite 900
Dallas, Texas 75201-2980
RE: Chip Packaging Technologies, LLC v. STMicroelectronics, Inc., No. 7:25-cv-00505-
DC-DTG (W.D. Tex.)
Dear Mr. Becker:
We write in response to your letter of May 8, 2026, raising questions about a subset of the accused
products identified in Chip Packaging’s March 27, 2026 Supplemental Preliminary Infringement
Contentions. Your letter requests that Chip Packaging confirm it will amend the supplemental
contentions to remove part numbers that ST contends are not currently associated with any ST
product, and, in the alternative, that Chip Packaging provide the basis for its identification of those
parts.
Before turning to the parts themselves, we address the framing of your letter. Your speculation
that Chip Packaging “fabricated its list of accused products using a generative AI tool,” and your
demand that we either confirm or deny that speculation, are improper. The investigative methods
of counsel are work product, and we decline to characterize them. The footnote citation to public
benchmarks of AI “hallucination rates” adds nothing. An arithmetic comparison between a number
derived from ST’s own (still unsubstantiated) list and a published benchmark does not establish
anything about the methodology Chip Packaging actually used. We accordingly reject the
insinuation that Chip Packaging has conducted any aspect of this litigation in bad faith.
Nonetheless, in an effort to resolve this issue without unnecessary motion practice, Chip Packaging
provides the following information about the list of accused products.
The supplemental list of accused products was developed from publicly available information,
including ST’s own product-family pages and parametric tables on st.com, ST datasheets that
describe families of variants within a single document, the application notes and product briefs ST
publishes for each technology generation, third-party distributor and aggregator catalogs
(DigiKey, Mouser, Octopart, Findchips, TME, Arrow, Newark), industry press, and marketing
materials. Where ST documentation described a family of devices by reference to a systematic
naming convention, Chip Packaging made a good-faith effort to compile all variants within that
family and within the temporal scope of the patent in question. This work was performed despite
the fact that ST refused (and continues to refuse) to identify its own products, denied (and
continues to deny) in its pleadings that it even operates the website located at www.st.com (see,
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Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 3 of 28
Jeffery S. Becker
May 14, 2026
Page 2
e.g., Dkt. No. 30 at ¶¶ 34-38), and has yet to produce the technical documents ST itself maintains,
which would have permitted direct verification.
We acknowledge that compilation of an accused-product list from public materials alone, without
ST’s cooperation, may have resulted in a list that could be over-inclusive at the margins.
Chip Packaging has reviewed the parts listed in your letter against the public materials from which
the supplemental list was compiled. Based on that review, Chip Packaging is prepared to amend
the supplemental contentions to remove those parts from the list, subject to the reservations of
rights below.
To permit Chip Packaging to make an additional amendment, we ask that ST confirm in writing
that, for each of the parts identified in your May 8 letter, the part has never been manufactured,
sold, marketed, distributed, sampled, or otherwise made available by ST or any predecessor-in-
interest, parent, subsidiary, affiliate, or contract manufacturer, under any product number, custom
designation, OEM/JV channel, or sales-region-specific branding. ST is in the unique position of
being able to confirm or refute the existence of its own products from its own records.
Chip Packaging’s willingness to remove parts from the supplemental list is without prejudice to
its right to re-add any such part, or any other part, upon receipt of discovery that reveals the
existence of a previously undisclosed product or confirms the existence of any of the accused
variants. Final Infringement Contentions are not due until November 5, 2026, and Chip Packaging
expects further amendment as ST’s still-outstanding core technical document production and sales
records are received.
To the extent your May 8 letter renews the representative-product-charting arguments first raised
in ST’s April 3 letter, those arguments remain contrary to controlling authority. The Federal Circuit
has recognized that where “publicly available information might not have been available” for some
accused products, the patentee “could not have been more diligent,” and that product-by-product
analysis “might place an undue strain on the judicial resources of the district court.” Keranos, LLC
v. Silicon Storage Tech., Inc., 797 F.3d 1025, 1038 (Fed. Cir. 2015). This District accordingly
approves representative-product charting at the preliminary contention stage. See, e.g., IGT v.
Zynga Inc., No. W-21-CV-00331-ADA, 2022 WL 606719, at *2 (W.D. Tex. Mar. 1, 2022)
(holding that where uncharted products are “reasonably similar” to those specifically charted, a
defendant “cannot refuse to comply with discovery just because [it] believes it does not infringe”).
ST’s contrary citation to Intellectual Tech LLC v. Zebra Technologies Corp., No. 6:19-CV-00628-
ADA, ECF No. 31 at 1 (W.D. Tex. Apr. 29, 2020) itself requires only that a plaintiff provide “an
analysis explaining why” its chart is representative, which Chip Packaging’s supplemental
contentions do by identifying each accused product family by package type, technology
generation, and structural features. Chip Packaging stands on its prior responses dated March 6
and March 27, 2026 for the substantive merits of these arguments.
Chip Packaging is available to meet and confer regarding these issues on May 15 between 1:00
p.m. and 2:00 p.m. or between 3:00 p.m. and 5:00 p.m. Central. Please let us know which time
works for ST.
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Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 4 of 28
Jeffery S. Becker
May 14, 2026
Page 3
Sincerely,
______________________________________
Robert Magee
Blue Peak Law Group LLP
robert@bluepeak.law
3139 W. Holcombe Blvd. PMB 8160, Houston, TX 77025-1533
www.bluepeak.law | 281.972.3036 | contact@bluepeak.law
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 5 of 28
May 27, 2026
[Via Email]
Jeffery S. Becker
Baker Botts L.L.P.
2001 Ross Avenue, Suite 900
Dallas, TX 75201
RE: Chip Packaging Technologies, LLC v. STMicroelectronics, Inc., No. 7:25-cv-00505-
DC-DTG (W.D. Tex.) — Deficiencies in ST’s May 18, 2026 Technical Production
Dear Jeff,
We write regarding Defendant STMicroelectronics, Inc.’s (“ST”) May 18, 2026 core technical
document production. As explained in detail below, the production is deficient and does not satisfy
ST’s discovery obligations under the Amended Scheduling Order (Dkt. 38). We request that ST
promptly supplement its production no later than June 3, 2026.
Pursuant to the original Scheduling Order, CPT timely served its Preliminary Infringement
Contentions on February 12 and further served Supplemental Preliminary Infringement Contentions
on March 27. CPT’s contentions chart each element of every asserted claim against the Accused
Products, supported by annotated reverse-engineering photographs, X-ray images, and cross-
sectional views, among other materials. ST’s core technical production was originally due on April 16.
On April 3, ST requested a one-month extension to May 18, representing that “more time is needed
for ST to prepare its preliminary invalidity contentions and ‘sufficient to show’ production.” Dkt. 37
at 1. CPT agreed, the parties jointly moved, and the Court granted the extension. Dkt. 38.
As you know, the Asserted Patents in this case are directed to the physical structures and construction
of semiconductor packages, particularly features inside the package. Despite this, the vast majority of
ST’s technical production appears limited to public, freely available, customer-facing literature drawn
from st.com, including marketing materials, training decks, application notes, reference manuals, and
technical notes.1 As an initial matter, much of what ST produced is unrelated to packaging at all—it is
generic ST material on firmware, peripherals, software tools, training decks, and application examples.
See, e.g., ST_CPT_00070161 (an installation guide for third-party software); ST_CPT_00066527
(programming manual covering instruction set and core peripherals). Where ST’s documents do
address packaging, they describe only exterior features (e.g., pinouts and exterior package outline
1 See, e.g., ST_CPT_00010886 (STL220N6F7 datasheet, DS10089 Rev 6), available at
https://www.st.com/resource/en/datasheet/stl220n6f7.pdf, and ST_CPT_00005079 (Application Note AN2548,
“Introduction to DMA controller for STM32 MCUs”), available at
https://www.st.com/resource/en/application_note/an2548-introduction-to-dma-controller-for-stm32-mcus-
stmicroelectronics.pdf.
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Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 6 of 28
Jeffery S. Becker
May 27, 2026
Page 2
drawings) and do not show the internal package structures at all or otherwise describe their
construction.
ST’s production is deficient because it does not contain any design documents that show how the
accused infringing features of the packages are constructed. By way of example and not limitation,
the production contains no lead-frame design files and mechanical drawings, die-pad layout drawings,
internal X-ray and SEM cross-section reference images, package CAD files, wire-bond and clip-bond
diagrams, assembly process specifications and travelers, bills of material specifying alloy and mold-
compound choices, mold-compound supplier specifications, gel composition specifications,
diaphragm design drawings, or lid assembly drawings.
The Federal Circuit has explained that early discovery and contention requirements are designed,
among other things, “to allow the plaintiff to pin down the defendant’s theories of defense.” O2 Micro
Int’l Ltd. v. Monolithic Power Sys., Inc., 467 F.3d 1355, 1365-66 (Fed. Cir. 2006). In I-Flow Corp. v. Apex
Med. Techs., Inc., 250 F.R.D. 508, 510 (S.D. Cal. 2008), the court held that defendant’s technical
production was inadequate because it provided “no detail of the internal structure,” “no technical
specifications describing the components or materials used to manufacture the accused device,” and
did not “identify the dimensions of the structural components.” Id. ST’s production presents the same
deficiencies.
By Wednesday, June 3, 2026, please produce, for each accused product in CPT’s March 27
supplemental contentions, the core technical documents sufficient to show the internal structures and
physical construction of each accused package. Such documents should include, as applicable,
lead-frame design files and mechanical drawings, die-pad layout drawings, internal X-ray and SEM
cross-section reference images, package CAD files, wire-bond and clip-bond diagrams, assembly
process specifications and travelers, bills of material specifying alloy and mold-compound choices,
mold-compound supplier specifications, gel composition specifications, diaphragm design drawings,
and lid assembly drawings, among others. We note that ST appears to have access to confidential
engineering documents held by its affiliates. See, e.g., ST_CPT_00050561 and ST_CPT_00055616
(memory architecture inventories for the SPC58 microcontroller family, each stamped “ST
Restricted”). The technical production should include affiliate documents under ST’s possession,
custody, or control.
Further, to the extent that ST does not intend to supplement its production for any particular accused
product because it contends that it does not have possession, custody, or control over responsive
documents, please identify, for each product, the specific entity that has possession, custody, or
control of each category of responsive documents. CPT first raised the foreign affiliate document
question on February 4, 2026. ST declined to engage, responding on February 11 that it “disagrees
that now is the appropriate time to discuss hypothetical discovery disputes regarding document
productions that have yet to occur.” ST repeated the position in the Joint Rule 26(f) Report,
characterizing CPT’s concerns as “speculative” and “hypothetical” and proposing that any dispute
over “ST’s possession, custody, or control of any documents sought by Plaintiff” be addressed
through a “meet and confer in good-faith . . . before involving the Court.” Dkt. 31 at 5–6.
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Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 7 of 28
Jeffery S. Becker
May 27, 2026
Page 3
Accordingly, by June 3, 2026, please supplement the technical production with the documents
identified above and answer the question above. Please also provide your availability to meet and
confer during the week of June 3.
Sincerely,
/s/ Natalie Lieber
______________________________________
Natalie Lieber
Blue Peak Law Group LLP
lieber@bluepeak.law
3139 W. Holcombe Blvd. PMB 8160, Houston, TX 77025-1533
www.bluepeak.law | 281.972.3036 | contact@bluepeak.law
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 8 of 28
June 16, 2026
[Via Email]
Jeffery S. Becker
Baker Botts L.L.P.
2001 Ross Avenue, Suite 900
Dallas, TX 75201
RE: Chip Packaging Technologies, LLC v. STMicroelectronics, Inc., No. 7:25-cv-00505-DC-DTG
(W.D. Tex.)—ST’s Core Technical Production Deficiencies and Ongoing Refusal to State a Position
on Control of Core Technical Documents
Dear Jeff:
This responds to your June 4, 2026, letter. ST’s core technical production was due May 18, 2026, under the
Court’s Order Governing Proceedings in Patent Cases (the “OGP”) and the Amended Scheduling Order (the
“Scheduling Order,” Dkt. 38). As explained below, ST’s production remains materially deficient because it
includes no internal construction documents for the package interiors—the core technical documents that the
Scheduling Order requires. And to date, ST has refused to take a position on what documents it is withholding
or why, including whether any core technical documents are held by foreign affiliates.1 To facilitate the parties’
Rule 26(f) obligations (Dkt. 31 at 6), please answer the questions set forth below in Section II by June 22, 2026,
and provide your availability for a meet and confer with lead and local counsel on June 23 or 24, 2026; otherwise,
we will be at an impasse.
I. ST Failed to Produce the Internal Construction Documents the Scheduling Order Requires
ST’s May 18 production comprises more than 140,000 pages of public, customer-facing material. CPT’s review
has identified no document showing the internal construction of any accused product, including the five
products CPT charted element by element: STL220N6F7, SPC582B60E1, STM32G071CB, SR5E1E7, and
LPS28DFW (’299 App’x A, ’646 App’x B, ’189 App’x C, ’351 App’x D, ’658 App’x E). CPT could not identify
a single document in ST’s technical production addressing lead frames at all—the only documents in which the
word “lead frame” even appears are alleged prior-art references cited in ST’s invalidity contentions. Your June
4 letter does not contend otherwise.
That production does not satisfy the Court’s Scheduling Order, which required ST to produce “technical
documents, including software where applicable, sufficient to show the operation of the accused product(s).”
Dkt. 38. Your suggestion that CPT is importing “California rules of discovery” is misplaced. The asserted
patents claim the internal construction of semiconductor packages, and the “operation” of the accused products
cannot meaningfully be shown without it. Public, exterior-facing material does not suffice, and adequacy is
measured by substance, not page count. If you contend that public, exterior-facing materials can satisfy that
obligation in a package-construction case, identify the authority that supports the view. We are aware of none,
and your June 4 letter cites none.
The Western District decisions you cite do not support your position. All three are software cases in which the
key internal technical material—source code—was produced, agreed to be produced, or ordered produced;
1 CPT has now raised the issue five times over the past four months. See infra Section II.
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Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 9 of 28
Jeffery S. Becker
June 16, 2026
Page 2
none involved patents on package construction, and none suggests that public material alone can satisfy a
party’s production obligations. Kajeet denied relief only because the defendant represented that, after searching,
it “possessed no additional responsive documents.” Kajeet, Inc. v. Trend Micro, Inc., No. 6:21-cv-00389-ADA
(W.D. Tex. Nov. 30, 2021), ECF No. 34. ST has made no similar representation; to the contrary, your letter
states that “ST expects that it will produce additional technical materials on the timeline set by the Court.”
Please clarify whether those materials include the internal construction documents identified in the table in
Section II below—i.e., documents sufficient to show the design and assembly of each accused package—and,
if so, explain the reason why they were omitted from ST’s May 18 production.
If the absence of a final protective order is the basis for withholding any documents, please state whether ST
will agree to produce them now under “Outside Attorneys’ Eyes Only” treatment pending entry of a final order
(i.e., the interim mechanism provided in standing orders used for patent cases in this District, which the parties
can adopt by agreement pending entry of a protective order here), so that production can proceed now.
II. For the Parties to Meet and Confer Productively, ST Should State What It Is Withholding and
Why
The internal construction documents exist, they were due May 18, and they have not been produced. Your June
4 letter recites four potential justifications—the supposed adequacy of ST’s production, the accused-product
list, CPT’s contentions, and the absence of a final protective order—without committing to any of them. As an
initial matter, none of the four would excuse nonproduction. The product-list complaints are moot: CPT agreed
at the parties’ May 15 conference to remove the unreleased part numbers ST identified, the amendments served
today do so, and CPT never sought documents for those parts. As to the contentions, ST has never explained
how any claimed defect prevented it from producing a single document, and a merits disagreement is no basis
to withhold discovery. TwinStrand Biosciences, Inc. v. Guardant Health, Inc., No. 21-1126-GBW-SRF, 2022 WL
20402683, at *1 (D. Del. Oct. 18, 2022).
In any event, CPT cannot confer about objections that have not been stated, and the burden is ST’s, as the
producing party, to show that its production satisfies the OGP. See Edward D. Ioli Tr. v. Avigilon Corp., No. 2:10-
cv-605-JRG, 2012 WL 5830711, at *3–4 (E.D. Tex. Nov. 16, 2012). A productive conference requires ST’s
position on what it is withholding, on what basis, and whether the missing documents are within its control.
Under the Federal Rules, documents within ST’s “control” include those it has the legal right or practical ability
to obtain from a related entity. See Mir v. L-3 Commc’ns Integrated Sys., L.P., 319 F.R.D. 220, 229 (N.D. Tex. 2016);
Shell Global Solutions (US) Inc. v. RMS Eng’g, Inc., No. 4:09-cv-3778, 2011 WL 3418396, at *2 (S.D. Tex. Aug. 3,
2011). CPT has been asking since February 4 whether ST’s affiliates hold the technical documents for the
accused products. ST called the question premature in February and called it “speculative” and “hypothetical”
in the Rule 26(f) Report, while committing to “meet and confer in good faith . . . before involving the Court”
over any dispute concerning “ST’s possession, custody, or control of any documents sought by Plaintiff.” Dkt.
31 at 5–6. CPT asked again on May 27 and again at the parties’ June 4 conference; ST declined to state a
position. The production deadline has passed, and the question is no longer hypothetical. If ST does not control
these documents, CPT must seek them from the entities that do, through mechanisms that take substantial
time—and every week of silence compresses the schedule at CPT’s expense. That prejudice is the direct result
of ST’s refusal to state a position it committed, months ago, to discuss in good faith.
Accordingly, by June 22, please complete the table below for each accused package and document category. ST
“controls” a document if it is within ST’s possession, custody, or control — including any document ST has
the legal right or practical ability to obtain from a lead-frame or substrate supplier or assembly subcontractor.
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Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 10 of 28
Jeffery S. Becker
June 16, 2026
Page 3
Accused package Documents sufficient to show: In ST’s control? If If ST has them but
(patent) not, who has them? is withholding, the
basis
PowerFLAT/PQFN Design — the lead-frame design (e.g., the die
(’299) pad and the lead-frame portions connected
to the die's bond pads)
PowerFLAT/PQFN Assembly — how the package is assembled
(’299) (e.g., die mounting, lead-frame/clip attach,
and encapsulation)
eTQFP (’646, ’351) Design — the lead-frame design (e.g., the
power and ground bars between the signal
leads and the die; the lead-frame flag and its
mold-lock structures)
eTQFP (’646, ’351) Assembly — how the package is assembled
(e.g., wire bonding of the die to the bars and
leads; mold-compound interlock with the
flag)
eLQFP (’646, ’351) Design — the lead-frame design (e.g., the
power and ground bars between the signal
leads and the die; the lead-frame flag and its
mold-lock structures)
eLQFP (’646, ’351) Assembly — how the package is assembled
(e.g., wire bonding of the die to the bars and
leads; mold-compound interlock with the
flag)
LQFP (’351, ’189) Design — the lead-frame design (e.g., the
lead-frame flag and mold-lock structures; the
larger-area power-rail pad)
LQFP (’351, ’189) Assembly — how the package is assembled
(e.g., wire bonding of the die to the leads,
power-rail pad, and external connectors;
mold-compound interlock with the flag)
UFQFPN (’189) Design — the lead-frame design (e.g., the
larger-area power-rail pad and die connection
pads)
UFQFPN (’189) Assembly — how the package is assembled
(e.g., wire bonding of the power-rail pad to
the die pads and an external connector)
CCLGA sensors / Design — the sensor design (e.g., the
LPS-series (’658) pressure-sensing die, the flexible gel over its
sensing region, the diaphragm, and the lid
with its aperture)
CCLGA sensors / Assembly — how the package is assembled
LPS-series (’658) (e.g., assembly of the lid, gel, diaphragm, and
port)
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Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 11 of 28
Jeffery S. Becker
June 16, 2026
Page 4
The specific documents requested are illustrative examples only and do not limit ST’s production. These
categories are provided to focus the meet and confer that Rule 26(f) Report contemplates; they do not limit
ST’s obligation to produce other documents showing how the accused packages are built.
We look forward to your response. CPT reserves all rights, including the right to seek relief from the Court on
the deficiencies addressed above.
Sincerely,
/s/ Natalie Lieber
Natalie Lieber
Blue Peak Law Group LLP
(646) 238-0951
lieber@bluepeak.law
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Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 12 of 28
June 16, 2026
[Via Email]
Jeffery S. Becker
Baker Botts L.L.P.
2001 Ross Avenue, Suite 900
Dallas, TX 75201
RE: Chip Packaging Technologies, LLC v. STMicroelectronics, Inc., No. 7:25-cv-00505-DC-DTG
(W.D. Tex.)—Service of CPT’s Second Supplemental Preliminary Infringement Contentions;
Response to ST’s June 1, 2026 Letter
Dear Jeff:
This responds to your June 1, 2026 letter. Served with this letter are CPT’s Second Supplemental Preliminary
Infringement Contentions. As the parties discussed on May 15, the amendments expressly state CPT’s
representativeness analysis, and they resolve the product-list issues your letter raises—certain products are
removed without prejudice, certain package designations are corrected, and twelve entries are conformed to
the part numbers of the lead-frame-package products the March 27 list identified, as noted in the contentions
themselves. The claim charts are unchanged, and no new infringement theories have been added.
ST has known CPT’s infringement theories since February 12, when CPT served its Preliminary Infringement
Contentions charting an exemplary product for each asserted patent, element by element, based on CPT’s
physical teardowns. Those contentions accused both the exemplary products and the STM device series sharing
the charted package structures. At ST’s request for “a complete list of specifically identified ST products (by
product name),” CPT served such a list on March 27, identifying each accused product by part number, product
family, and package type drawn from ST’s own published datasheets. Because ST publishes no comprehensive
list of its products, CPT built the requested list using ST’s own part-numbering conventions, capturing every
device in the accused package families. A list built that way can sweep in part numbers ST never released; CPT
agreed to remove any such entries ST identified, and has done so. Having demanded an exhaustive list from a
party limited to public information, ST cannot fairly treat the margins of that list as evidence of an inadequate
investigation, much less as a discovery burden, when ST need only check the part numbers against its own
records.
The amendments served today state CPT’s representativeness analysis expressly, package family by package
family. To the extent your letter demands more of CPT’s preliminary contentions, that demand is premature.
At this stage, the uncharted products need only be “reasonably similar” to the charted exemplary products. IGT
v. Zynga Inc., No. 6:21-cv-00331-ADA, 2022 WL 606719, at *2 (W.D. Tex. Mar. 1, 2022). Final contentions are
not due until November 5, 2026, after fact discovery opens.
Setting aside the removed products, none of the differences ST recites bears on representativeness. The asserted
claims are directed to the internal construction of the package—the lead frame, ground and power bars, mold
locks, sensor gel, and lid—not to pin counts, package outlines, or the die inside. That a package has 48 pins
rather than 176 says nothing about whether it shares the claimed internal construction, and your letter identifies
no internal difference in any accused product, only external ones. A representativeness challenge requires
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Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 13 of 28
Jeffery S. Becker
June 16, 2026
Page 2
evidence of differences in that internal construction, such as “a declaration or technical document,” not attorney
argument. This Court rejected exactly such an unsupported challenge in IGT, ordering discovery on every
accused product. 2022 WL 606719, at *2. If ST has internal documents supporting its position, please produce
them now. Such documents are overdue as detailed in CPT’s letter today regarding ST’s technical production:
ST has yet to produce a single internal construction document for any accused product.
Nor do the amendments prejudice ST. The asserted claims and claim charts are unchanged, and the parties
have already exchanged claim terms and proposed constructions. An amendment that only narrows and clarifies
the case affects no deadline, particularly where every supplement CPT has served answered an ST request. This
Court has declined to find unfair prejudice where a plaintiff supplements its preliminary contentions in response
to a defendant’s complaints. WSOU Invs. LLC v. OnePlus Tech. (Shenzhen) Co., No. 6:20-cv-00952-ADA, 2022
WL 174517, at *3 (W.D. Tex. Jan. 18, 2022). To the extent ST contends that a specific claim term is genuinely
necessitated by the amendments, CPT is prepared to confer in good faith.
Please let us know if you’d like to further discuss any of these issues. CPT reserves all rights.
Sincerely,
/s/ Natalie Lieber
Natalie Lieber
Blue Peak Law Group LLP
(646) 238-0951
lieber@bluepeak.law
3139 W. Holcombe Blvd. PMB 8160, Houston, TX 77025-1533
www.bluepeak.law | 281.972.3036 | contact@bluepeak.law
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 14 of 28
UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
MIDLAND/ODESSA DIVISION
CHIP PACKAGING TECHNOLOGIES,
LLC,
Civil Action No. 7:25-cv-00505-DC-DTG
Plaintiff,
JURY TRIAL DEMANDED
v.
STMICROELECTRONICS, INC.,
Defendant.
PLAINTIFF’S SECOND SUPPLEMENTAL PRELIMINARY INFRINGEMENT
CONTENTIONS
Pursuant to the Court’s Standing Order Governing Patent Proceedings, Defendant’s request
by letter on March 19, 2026, and the parties’ May 15, 2026 meet-and-confer, Plaintiff Chip
Packaging Technologies, LLC (“Chip Packaging” or “Plaintiff”) hereby provides the following
second supplemental preliminary infringement contentions to Defendant STMicroelectronics, Inc.
(“STM” or “Defendant”).
Attached hereto as Appendices A–E are claim charts identifying, to the best of Plaintiff’s
current knowledge, where the elements of each Asserted Claim are found in Defendant’s products.
The charts are identical to the charts served with the March 27, 2026 contentions. The removal of
any product from the tables below is without prejudice, and Plaintiff reserves the right to amend
these Preliminary Infringement Contentions based on material identified after the contentions are
served, including STM’s document production and other discovery. Each representativeness
statement below is based on Plaintiff’s reverse engineering of the charted exemplary products and
1
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 15 of 28
on STM’s published package and datasheet documentation. STM has not produced its internal
packaging documents.
I. U.S. PATENT NO. 9,263,299
Defendant infringes Claims 1, 3, and 4 of U.S. Patent No. 9,263,299 (the “’299 Patent”).
Plaintiff’s investigation to date indicates that STM PowerFLAT and PQFN devices include the
devices identified below. On information and belief, Defendant makes, uses, sells, offers to sell,
and/or imports into the United States (and induces customers and consumers to make, use, sell,
offer to sell, or import into the United States) further STM products — including PowerFLAT and
PQFN devices — whose packages share the construction described in the representativeness
statement below, in addition to those identified in the table.
Product Family Part Number Package
STripFET F7 (60V) STL7N6F7 PowerFLAT 2x2
STripFET F7 (60V) STL20N6F7 PowerFLAT 3.3x3.3
STripFET F7 (60V) STL50N6F7 PowerFLAT 5x6
STripFET F7 (60V) STL90N6F7 PowerFLAT 5x6
STripFET F7 (60V) STL180N6F7 PowerFLAT 5x6
STripFET F7 (60V) STL220N6F7 PowerFLAT 5x6
STripFET F7 (60V) STL225N6F7AG PowerFLAT 5x6
STripFET F7 (60V) STL260N4F7 PowerFLAT 5x6
STripFET F7 (60V Dual) STL36DN6F7 PowerFLAT 5x6 DI
STripFET F7 (60V Dual) STL50DN6F7 PowerFLAT 5x6 DI
STripFET F7 (40V) STL64N4F7AG PowerFLAT 5x6
STripFET F7 (40V) STL110N4F7AG PowerFLAT 5x6
STripFET F7 (40V) STL210N4F7 PowerFLAT 5x6
STripFET F7 (40V) STL260N4LF7 PowerFLAT 5x6
STripFET F7 (40V Dual) STL64DN4F7AG PowerFLAT 5x6 DI
STripFET F7 (40V Dual) STL76DN4LF7AG PowerFLAT 5x6 DI
STripFET F7 (80V) STL105N8F7AG PowerFLAT 5x6
STripFET F7 (80V) STL120N8F7 PowerFLAT 5x6
STripFET F7 (80V) STL130N8F7 PowerFLAT 5x6
STripFET F7 (80V) STL135N8F7AG PowerFLAT 5x6
STripFET F7 (100V) STL3N10F7 PowerFLAT 2x2
2
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 16 of 28
STripFET F7 (100V) STL4N10F7 PowerFLAT 3.3x3.3
STripFET F7 (100V) STL7N10F7 PowerFLAT 3.3x3.3
STripFET F7 (100V) STL8N10F7 PowerFLAT 3.3x3.3
STripFET F7 (100V) STL12N10F7 PowerFLAT 5x6
STripFET F7 (100V) STL20N10F7 PowerFLAT 5x6
STripFET F7 (100V) STL30N10F7 PowerFLAT 5x6
STripFET F7 (100V) STL40N10F7 PowerFLAT 5x6
STripFET F7 (100V) STL45N10F7AG PowerFLAT 5x6
STripFET F7 (100V) STL60N10F7 PowerFLAT 5x6
STripFET F7 (100V) STL80N10F7 PowerFLAT 5x6
STripFET F7 (100V) STL100N10F7 PowerFLAT 5x6
STripFET F7 (100V) STL110N10F7 PowerFLAT 5x6
STripFET F7 (DSC) STLD110N10F7 PowerFLAT 5x6 DSC
STripFET F7 (DSC) STLD257N4F7AG PowerFLAT 5x6 DSC
STripFET F8 (40V) STL100N4LF8 PowerFLAT 3.3x3.3
STripFET F8 (40V) STL130N4LF8 PowerFLAT 3.3x3.3
STripFET F8 (40V) STL140N4LF8 PowerFLAT 5x6
STripFET F8 (40V) STL160N4F8 PowerFLAT 5x6
STripFET F8 (40V) STL300N4F8 PowerFLAT 5x6
STripFET F8 (40V) STL320N4LF8 PowerFLAT 5x6
STripFET F8 (40V) STL320N4F8 PowerFLAT 5x6
STripFET F8 (40V) STL325N4F8AG PowerFLAT 5x6
STripFET F8 (40V) STL325N4LF8AG PowerFLAT 5x6
STripFET F8 (40V) STL305N4LF8AG PowerFLAT 5x6
STripFET F8 (40V) STL059N4S8AG PowerFLAT 5x6 WF
STripFET F8 (80V) STL110N8F8 PowerFLAT 5x6
STripFET F8 (100V) STL120N10F8 PowerFLAT 5x6
STripFET F8 (100V) STL125N10F8AG PowerFLAT 5x6
STripFET F6 (60V) STL8DN6LF6AG PowerFLAT 5x6 DI
STripFET F6 (40V) STL42P4LLF6 PowerFLAT 5x6
STripFET F6 (40V) STL42P6LLF6 PowerFLAT 5x6
STripFET F6 (40V) STL12P6F6 PowerFLAT 5x6
STripFET F6 (40V) STL13DP10F6 PowerFLAT 5x6
STripFET F6 (40V DSC) STLD125N4F6AG PowerFLAT 5x6 DSC
STripFET F6 (40V DSC) STLD200N4F6AG PowerFLAT 5x6 DSC
MDmesh M6 (600V) STL17N60M6 PowerFLAT 8x8 HV
MDmesh M6 (600V) STL22N60M6 PowerFLAT 8x8 HV
MDmesh M6 (600V) STL33N60M6 PowerFLAT 8x8 HV
MDmesh M6 (600V) STL36N60M6 PowerFLAT 8x8 HV
3
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 17 of 28
MDmesh M6 (600V) STO68N60M6AV PowerFLAT 8x8 HV
MDmesh DM6 (600V) STL22N60DM6 PowerFLAT 8x8 HV
MDmesh DM6 (600V) STL33N60DM6 PowerFLAT 8x8 HV
MDmesh DM6 (600V) STL45N60DM6 PowerFLAT 8x8 HV
MDmesh DM6 (600V) STL52N60DM6 PowerFLAT 8x8 HV
MDmesh K5 (800V) STL2N80K5 PowerFLAT 5x6 VHV
MDmesh K5 (800V) STL3N80K5 PowerFLAT 5x6 VHV
MDmesh K5 (800V) STL4N80K5 PowerFLAT 5x6 VHV
MDmesh K5 (800V) STL4LN80K5 PowerFLAT 5x6 VHV
MDmesh K5 (800V) STL5N80K5 PowerFLAT 5x6 VHV
MDmesh K5 (800V) STL7N80K5 PowerFLAT 5x6 VHV
MDmesh K5 (800V) STL8N80K5 PowerFLAT 5x6 VHV
SiC Schottky (650V) STPSC4H065DLF PowerFLAT 8x8 HV
SiC Schottky (650V) STPSC10065DLF PowerFLAT 8x8 HV
SiC MOSFET (650V) SCTL90N65G2V PowerFLAT 8x8 HV
Schottky Rectifier (100V) STPS30H100DJF PowerFLAT 5x6
Schottky Rectifier (45V) STPS1045DEE PowerFLAT 3.3x3.3
Schottky Rectifier (30V) STPS8L30DEE PowerFLAT 3.3x3.3
Representativeness. The chart attached as Appendix A analyzes the STL220N6F7. On
information and belief, each product identified above is likewise assembled with its die’s bond
pads connected to a lead frame by reflowed solder, on a temporary carrier.
A preliminary infringement contentions chart setting forth where in the accused product(s)
each element of the asserted claim(s) are found is attached as Appendix A. The priority date of the
’299 Patent is July 2, 2014. A copy of the file history has been separately provided.
II. U.S. PATENT NO. 9,299,646
Defendant infringes Claims 1, 5-7, and 11 of U.S. Patent No. 9,299,646 (the “’646 Patent”).
Plaintiff’s investigation to date indicates that STM eTQFP and QFP devices include the devices
identified below. On information and belief, Defendant makes, uses, sells, offers to sell, and/or
imports into the United States (and induces customers and consumers to make, use, sell, offer to
sell, or import into the United States) further STM products — including eTQFP and eLQFP
4
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 18 of 28
devices — whose packages share the construction described in the representativeness statement
below, in addition to those identified in the table.
Product Family Part Number Package
SPC58 2B-Line SPC582B50E1 eTQFP-64
SPC58 2B-Line SPC582B50E3 eTQFP-100
SPC58 2B-Line SPC582B54E1 eTQFP-64
SPC58 2B-Line SPC582B54E3 eTQFP-100
SPC58 2B-Line SPC582B60E1 eTQFP-64
SPC58 2B-Line SPC582B60E3 eTQFP-100
SPC58 4B-Line SPC584B64E1NH00X eTQFP-64
SPC58 4B-Line SPC584B64E3ND00X eTQFP-100
SPC58 4B-Line SPC584B60E1 eTQFP-64
SPC58 4B-Line SPC584B60E3 eTQFP-100
SPC58 4B-Line SPC584B70E1 eTQFP-64
SPC58 4B-Line SPC584B70E1NHC0X eTQFP-64
SPC58 4B-Line SPC584B70E3 eTQFP-100
SPC58 4B-Line SPC584B70E5 eTQFP-144
SPC58 C-Line SPC584C60E1 eTQFP-64
SPC58 C-Line SPC584C60E3 eTQFP-100
SPC58 C-Line SPC584C70E1 eTQFP-64
SPC58 C-Line SPC584C70E3 eTQFP-100
SPC58 C-Line SPC584C70E5 eTQFP-144
SPC58 C-Line SPC584C80E1 eTQFP-64
SPC58 C-Line SPC584C80E3 eTQFP-100
SPC58 C-Line SPC584C80E5 eTQFP-144
SPC58 C-Line SPC584C80E7 eTQFP-176
SPC58 C-Line (Dual) SPC58EC80E1 eTQFP-64
SPC58 C-Line (Dual) SPC58EC80E3 eTQFP-100
SPC58 C-Line (Dual) SPC58EC80E5 eTQFP-144
SPC58 C-Line (Dual) SPC58EC80E7 eTQFP-176
SPC58 G-Line SPC584G80E5 eTQFP-144
SPC58 G-Line SPC584G80E7 eTQFP-176
SPC58 G-Line (Dual) SPC58EG80E5 eTQFP-144
SPC58 G-Line (Dual) SPC58EG80E7 eTQFP-176
SPC58 G-Line (Triple) SPC58NG80E5 eTQFP-144
SPC58 G-Line (Triple) SPC58NG80E7 eTQFP-176
SPC58 H-Line (Triple) SPC58NH92E5† eTQFP-144
SPC58 H-Line (Triple) SPC58NH92E7† eLQFP-176
5
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 19 of 28
SPC58 N-Line SPC58NN84E7 eTQFP-176
SPC58 N-Line SPC58NH84E5 eTQFP-144
SPC58 N-Line SPC58NH84E7 eTQFP-176
Stellar SR5 E1 SR5E1E3 eTQFP-100
Stellar SR5 E1 SR5E1E5 eTQFP-100
Stellar SR5 E1 SR5E1E7 eLQFP-176
† The March 27, 2026 list identified this product by its lead-frame package type (see
Package column) but inadvertently bore the part-number suffix of the corresponding ball-grid-
array variant, which Plaintiff does not accuse. The part number is corrected to identify the lead-
frame-package product. No new product is accused: the corrected entry identifies the same lead-
frame-package construction identified since March 27, which falls within the representativeness
statement below.
Representativeness. The chart attached as Appendix B analyzes the SPC582B60E1. On
information and belief, the lead frame of each product identified above likewise includes a power
bar and a ground bar in the area between the signal leads and the die.
A preliminary infringement contentions chart setting forth where in the accused product(s)
each element of the asserted claim(s) are found is attached as Appendix B. The priority date of the
’646 Patent is August 23, 2015. A copy of the file history has been separately provided.
III. U.S. PATENT NO. 8,643,189
Defendant infringes Claims 1, 13, 14, and 19 of U.S. Patent No. 8,643,189 (the “’189
Patent”). Plaintiff’s investigation to date indicates that STM UFQFPN and LQFP devices include
the devices identified below. On information and belief, Defendant makes, uses, sells, offers to
sell, and/or imports into the United States (and induces customers and consumers to make, use,
sell, offer to sell, or import into the United States) further STM products — including UFQFPN
6
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 20 of 28
and LQFP devices — whose packages share the construction described in the representativeness
statement below, in addition to those identified in the table.
Product Family Part Number / Series Package(s)
STM32L0 Series STM32L051C6 UFQFPN-48
STM32L0 Series STM32L051K8 UFQFPN-32
STM32L0 Series STM32L052C8 UFQFPN-48
STM32L0 Series STM32L053C8* UFQFPN-48
STM32L0 Series STM32L071CB* UFQFPN-48
STM32L0 Series STM32L071V8* LQFP-100
STM32L0 Series STM32L072CB* UFQFPN-48
STM32L0 Series STM32L073CZ* UFQFPN-48
STM32L0 Series STM32L073RZ* LQFP-64
STM32L0 Series STM32L073VZ* LQFP-100
STM32F7 Series STM32F722RC LQFP-64
STM32F7 Series STM32F722ZC LQFP-144
STM32F7 Series STM32F746ZG* LQFP-144
STM32F7 Series STM32F756ZG* LQFP-144
STM32F7 Series STM32F765ZI LQFP-144
STM32F7 Series STM32F767ZI LQFP-144
STM32F7 Series STM32F769II† LQFP-176
STM32L4 Series STM32L431CB* UFQFPN-48
STM32L4 Series STM32L432KC UFQFPN-32
STM32L4 Series STM32L433CC* UFQFPN-48
STM32L4 Series STM32L451CE* UFQFPN-48
STM32L4 Series STM32L476RG LQFP-64
STM32L4 Series STM32L476VG* LQFP-100
STM32L4 Series STM32L476ZG* LQFP-144
STM32L4 Series STM32L486RG LQFP-64
STM32L4 Series STM32L496ZG LQFP-144
STM32L4 Series STM32L4A6ZG LQFP-144
STM32H7 Series STM32H743VI* LQFP-100
STM32H7 Series STM32H743ZI LQFP-144
STM32H7 Series STM32H745ZI LQFP-144
STM32H7 Series STM32H747II† LQFP-176
STM32H7 Series STM32H750VB* LQFP-100
STM32H7 Series STM32H753ZI LQFP-144
STM32H7 Series STM32H755ZI LQFP-144
STM32H7 Series STM32H7B3VI* LQFP-100
7
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 21 of 28
STM32H7 Series STM32H735ZG LQFP-144
STM32G0 Series STM32G030F6 UFQFPN-20
STM32G0 Series STM32G030K8 UFQFPN-32
STM32G0 Series STM32G031K8 UFQFPN-32
STM32G0 Series STM32G070CB LQFP-48
STM32G0 Series STM32G070RB LQFP-64
STM32G0 Series STM32G071CB UFQFPN-48
STM32G0 Series STM32G071RB* LQFP-64
STM32G0 Series STM32G081CB UFQFPN-48
STM32G0 Series STM32G0B1CE* UFQFPN-48
STM32G0 Series STM32G0B1RE* LQFP-64
STM32G4 Series STM32G431CB* UFQFPN-48
STM32G4 Series STM32G431KB UFQFPN-32
STM32G4 Series STM32G431RB* LQFP-64
STM32G4 Series STM32G474CB LQFP-48
STM32G4 Series STM32G474RE LQFP-64
STM32G4 Series STM32G474VE* LQFP-100
STM32G4 Series STM32G491RE* LQFP-64
STM32L5 Series STM32L552CC UFQFPN-48
STM32L5 Series STM32L552CE UFQFPN-48
STM32L5 Series STM32L552RE LQFP-64
STM32L5 Series STM32L552ZE LQFP-144
STM32L5 Series STM32L562CE UFQFPN-48
STM32L5 Series STM32L562RE LQFP-64
STM32WB Series STM32WB55CC UFQFPN-48
STM32WB Series STM32WB55RG UFQFPN-64
STM32WB Series STM32WB50CG UFQFPN-48
STM32WB Series STM32WB15CC* UFQFPN-48
STM32WL Series STM32WL55CC† UFQFPN-48
STM32WL Series STM32WLE5CC† UFQFPN-48
STM32U5 Series STM32U575CI LQFP-100
STM32U5 Series STM32U575ZI LQFP-144
STM32U5 Series STM32U585CI LQFP-100
STM32H5 Series STM32H503RB LQFP-64
STM32H5 Series STM32H563RI LQFP-64
STM32H5 Series STM32H563VI LQFP-100
STM32H5 Series STM32H563ZI LQFP-144
STM32H5 Series STM32H573VI LQFP-100
STM32H5 Series STM32H573ZI LQFP-144
8
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 22 of 28
STM32C0 Series STM32C011F4 UFQFPN-20
STM32C0 Series STM32C011F6 UFQFPN-20
STM32C0 Series STM32C031C6 UFQFPN-48
STM32C0 Series STM32C031K6 UFQFPN-32
* This part number is sold both in a lead-frame package (LQFP or UFQFPN) and in a ball-
grid-array or wafer-level package under the same root part number. Plaintiff accuses only the lead-
frame variant.
† The March 27, 2026 list identified this product by its lead-frame package type (see
Package column) but inadvertently bore the part-number suffix of the corresponding ball-grid-
array variant, which Plaintiff does not accuse. The part number is corrected to identify the lead-
frame-package product. No new product is accused: the corrected entry identifies the same lead-
frame-package construction identified since March 27, which falls within the representativeness
statement below.
Representativeness. The chart attached as Appendix C analyzes the STM32G071CB. On
information and belief, each product identified above likewise has, on the die’s connection-pad
surface opposite the mounting surface, a power-rail pad of larger surface area than the die
connection pads, connected by wire bonds to two or more of those pads.
A preliminary infringement contentions chart setting forth where in the accused product(s)
each element of the asserted claim(s) are found is attached as Appendix C. The priority date of
the ’189 Patent is July 17, 2012. A copy of the file history has been separately provided.
IV. U.S. PATENT NO. 9,685,351
Defendant infringes Claims 1-3 of U.S. Patent No. 9,685,351 (the “’351 Patent”).
Plaintiff’s investigation to date indicates that STM 32-bit Microcontrollers (MCU),
Microprocessors (MPU) and similar large die devices in QFP format include the devices identified
9
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 23 of 28
below. On information and belief, Defendant makes, uses, sells, offers to sell, and/or imports into
the United States (and induces customers and consumers to make, use, sell, offer to sell, or import
into the United States) further STM products — including 32-bit microcontrollers (MCU),
microprocessors (MPU), and similar large-die devices in QFP format — whose packages share the
construction described in the representativeness statement below, in addition to those identified in
the table.
Product Family Part Number / Series Package(s)
STM32L4 Series STM32L476RG LQFP-64
STM32L4 Series STM32L476VG* LQFP-100
STM32L4 Series STM32L476ZG* LQFP-144
STM32L4 Series STM32L486RG LQFP-64
STM32L4 Series STM32L496ZG LQFP-144
STM32L4 Series STM32L4A6ZG LQFP-144
STM32F7 Series STM32F722ZC LQFP-144
STM32F7 Series STM32F746ZG* LQFP-144
STM32F7 Series STM32F756ZG* LQFP-144
STM32F7 Series STM32F765ZI LQFP-144
STM32F7 Series STM32F767ZI LQFP-144
STM32F7 Series STM32F769II† LQFP-176
STM32F7 Series STM32F769BI† LQFP-208
STM32H7 Series STM32H743VI* LQFP-100
STM32H7 Series STM32H743ZI LQFP-144
STM32H7 Series STM32H745ZI LQFP-144
STM32H7 Series STM32H747II† LQFP-176
STM32H7 Series STM32H750VB* LQFP-100
STM32H7 Series STM32H753ZI LQFP-144
STM32H7 Series STM32H755ZI LQFP-144
STM32H7 Series STM32H757II† LQFP-176
STM32H7 Series STM32H735ZG LQFP-144
STM32H7 Series STM32H7B3VI* LQFP-100
SPC58 2B-Line SPC582B60E1 eTQFP-64
SPC58 2B-Line SPC582B60E3 eTQFP-100
SPC58 4B-Line SPC584B70E3 eTQFP-100
SPC58 4B-Line SPC584B70E5 eTQFP-144
SPC58 C-Line SPC584C80E5 eTQFP-144
10
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 24 of 28
SPC58 C-Line SPC584C80E7 eTQFP-176
SPC58 C-Line (Dual) SPC58EC80E5 eTQFP-144
SPC58 C-Line (Dual) SPC58EC80E7 eTQFP-176
SPC58 G-Line SPC584G80E5 eTQFP-144
SPC58 G-Line SPC584G80E7 eTQFP-176
SPC58 G-Line (Dual) SPC58EG80E5 eTQFP-144
SPC58 G-Line (Dual) SPC58EG80E7 eTQFP-176
SPC58 G-Line (Triple) SPC58NG80E5 eTQFP-144
SPC58 G-Line (Triple) SPC58NG80E7 eTQFP-176
SPC58 H-Line SPC58NH92E5† eTQFP-144
SPC58 H-Line SPC58NH92E7† eLQFP-176
SPC58 N-Line SPC58NN84E7 eTQFP-176
Stellar SR5 E1 SR5E1E3 eTQFP-100
Stellar SR5 E1 SR5E1E5 eTQFP-100
Stellar SR5 E1 SR5E1E7 eLQFP-176
STM32G4 Series STM32G474VE* LQFP-100
STM32G4 Series STM32G491RE* LQFP-64
STM32G0 Series STM32G070RB LQFP-64
STM32G0 Series STM32G071RB* LQFP-64
STM32G0 Series STM32G0B1RE* LQFP-64
STM32U5 Series STM32U575CI LQFP-100
STM32U5 Series STM32U575ZI LQFP-144
STM32U5 Series STM32U585CI LQFP-100
STM32H5 Series STM32H563VI LQFP-100
STM32H5 Series STM32H563ZI LQFP-144
STM32H5 Series STM32H573VI LQFP-100
STM32H5 Series STM32H573ZI LQFP-144
* This part number is sold both in a lead-frame package (LQFP or UFQFPN) and in a ball-
grid-array or wafer-level package under the same root part number. Plaintiff accuses only the lead-
frame variant.
† The March 27, 2026 list identified this product by its lead-frame package type (see
Package column) but inadvertently bore the part-number suffix of the corresponding ball-grid-
array variant, which Plaintiff does not accuse. The part number is corrected to identify the lead-
frame-package product. No new product is accused: the corrected entry identifies the same lead-
11
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 25 of 28
frame-package construction identified since March 27, which falls within the representativeness
statement below.
Representativeness. The chart attached as Appendix D analyzes the SR5E1E7. On
information and belief, the lead frame of each product identified above likewise has, on its top
surface, positive mold lock structures that laterally protrude above that surface.
A preliminary infringement contentions chart setting forth where in the accused product(s)
each element of the asserted claim(s) are found is attached as Appendix D. The priority date of
the ’351 Patent is July 18, 2014. A copy of the file history has been separately provided.
V. U.S. PATENT NO. 10,151,658
Defendant infringes Claim 1 of U.S. Patent No. 10,151,658 (the “’658 Patent”). Plaintiff’s
investigation to date indicates that STM pressure sensor devices include the devices identified
below. On information and belief, Defendant makes, uses, sells, offers to sell, and/or imports into
the United States (and induces customers and consumers to make, use, sell, offer to sell, or import
into the United States) further STM products — including pressure sensor devices — whose
packages share the construction described in the representativeness statement below, in addition
to those identified in the table.
Product Family Part Number Package
LPS27 Series LPS27HHW CCLGA-10L
LPS27 Series LPS27HHTW CCLGA-10L
LPS28 Series LPS28DFW CCLGA-6L
LPS33 Series LPS33HW CCLGA (ceramic)
LPS33 Series LPS33K CCLGA (ceramic, gel)
ILPS Series ILPS28QSW CCLGA-6L
Representativeness. The chart attached as Appendix E analyzes the LPS28DFW. On
information and belief, each product identified above likewise includes a pressure-sensing die with
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Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 26 of 28
a flexible gel over its sensing region, a flexible diaphragm covering the gel, and a lid located
between the gel and the exterior, with an aperture.
A preliminary infringement contentions chart setting forth where in the accused product(s)
each element of the asserted claim(s) are found is attached as Appendix E. The priority date of the
’658 Patent is November 20, 2016. A copy of the file history has been separately provided.
Dated: June 16, 2026 By: /s/ Robert Magee
Garland Stephens (Texas Bar No. 24053910)
garland@bluepeak.law
Robert Magee (pro hac vice)
robert@bluepeak.law
Justin Constant (pro hac vice)
justin@bluepeak.law
Richard Koehl (Texas Bar No. 24115754)
richard@bluepeak.law
Kate Falkenstien (pro hac vice)
kate@bluepeak.law
Natalie Lieber (pro hac vice)
lieber@bluepeak.law
Ameet Modi (pro hac vice)
modi@bluepeak.law
BLUE PEAK LAW GROUP LLP
3139 West Holcombe Blvd.
PMB 8160
Houston, TX 77025
Tel: (281) 972-3036
Of Counsel:
Mark D. Siegmund (Texas Bar No. 24117055)
msiegmund@cjsjlaw.com
CHERRY JOHNSON SIEGMUND JAMES, PC
7901 Fish Pond Road, 2nd Floor
Waco, TX 76710
Tel: (254) 732-2242
Fax: (866) 627-3509
William D. Ellerman (Texas Bar No. 24007151)
wellerman@cjsjlaw.com
CHERRY JOHNSON SIEGMUND JAMES, PC
One Glenn Lakes Tower
13
Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 27 of 28
8140 Walnut Hill Lane, Suite 105
Dallas, TX 75231
Tel: (254) 732-2242
Fax: (866) 627-3509
Attorneys for Plaintiff Chip Packaging
Technologies, LLC
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Case 7:25-cv-00505-DC-DTG Document 57-1 Filed 08/31/26 Page 28 of 28
CERTIFICATE OF SERVICE
I hereby certify that on June 16, 2026, I caused the foregoing document, Plaintiff’s Second
Supplemental Preliminary Infringement Contentions, and associated documents, to be served on
counsel of record by e-mail.
Dated: June 16, 2026 By: /s/ Robert Magee