- Declaratory judgment for patent non-infringement, patent invalidity, and/or patent unenforceability;
- Unfair competition
- Intentional interference with prospective economic advantage
- Negligent interference with prospective economic advantage
- Trade libel
SanDisk alleges that starting in September 2007 and continuing through 2008, LSI contacted them on three occasions and claimed that several of SanDisk's digital media players infringed its patents. SanDisk claims to have informed LSI that it did not believe that it was required to license the LSI patents. SanDisk further alleges that in May 2009, LSI sent threatening letters, containing false statements, to four of SanDisk's major customers claiming that certain SanDisk products infringed LSI patents. Each letter was captioned "RE: Unlicensed SanDisk Products".
In addition to a judgments of patent non-infringement, patent invalidity and/or patent unenforceability, SanDisk is seeking an award of all damages, an order enjoining LSI from initiating any action of patent infringment, an order enjoining LSI from sending false and misleading communication to their customers, attorneys fees and costs, etc.