Steve, look at the contentions in this suit regarding lines per day.
FACTUAL ALLEGATIONS
THE THEFT AND MISAPPROPRIATION OF CADENCE TRADE
SECRETS
31. Avant! was founded in 1991 as ArcSys, Inc., ("ArcSys") by four former employees of Cadence
Design Systems, Inc. ("Cadence"), a designer and distributor of Integrated Circuit ("IC") software.
ArcSys was formed with the express purpose of competing with Cadence. Undisclosed, however,
was the fact that the primary products produced by ArcSys and accounting for nearly all of its
revenues were based on computer source code and technology stolen from Cadence.
32. Cadence develops, markets and supports computer software tools in the field of Integrated
Circuit Design Automation ("ICDA"). ICDA refers generally to the field of automated software
tools for the design and creation of sophisticated integrated circuits. Cadence competes in the sector
of the software industry that develops "place and route" and compaction programs. These programs
automatically determine the optimal placement of each of the thousands, and sometimes millions, of
microscopic components to be placed on a given chip ("placement"), the optimal means of routing
the electrical connections between each component ("routing"), and the optimal means for reducing
the size of the die needed to contain the components ("compaction"). Cadence's key
place-and-route and compaction programs are called QPlace_, GRoute, FRoute_, and Vsize.
Cadence markets this technology in various products under the names Cell Ensemble, Cell3
Ensemble, Gate Ensemble, and Silicon Ensemble. These programs use a proprietary database to
maintain the large body of information that must be tracked and managed by these programs.
Cadence's database was originally marketed as part of a product known as Symbad and later
marketed as part of Design Framework II.
33. Beginning in February 1991, defendant Wuu used misappropriated computer source code from
Cadence's "Symbad" database computer programs to develop ICDA software programs that were
marketed, sold and shipped by ArcSys, Inc., Avant!'s predecessor. Additionally, Wuu possessed
confidential Cadence documents discussing a pending update of the Symbad program.
34.According to a log found in Steven Wuu's office during a September 5, 1995 search of Avant! at the behest of the Santa Clara County district attorney's office, Wuu claims to have "created" more
than 47,000 lines of database code for ArcSys in the 19 days between February 22, 1991, and March 13, 1993. Generating approximately 100 lines of code in a day is the typical number in the software industry.
My question has been, and I believe it to be important is, if generating approximately 100 lines of code in a day is a typical number in the software industry, how was Wuu able to generate in 19
days, (and that includes Saturday's and Sunday's 47,000 lines of code,
or, 2473 per day on average. The average of course could be much higher if he did not work weekends. Then it would be closer to 3100 lines per day. Either one is way over the average as reported here of 100.
Another way to look at this is by assuming once again that Wuu worked
24 hours per day and averaged the 3100 lines per day. If he was able to maintain this pace for the whole period, he would have averaged 129
lines of code per hour!! This is presumably very high tech stuff we are talking about, and I have a hard time picturing 2 lines being generated per minute, each minute of a 24 hour day.
Has anyone written any code here that could offer some input regarding this? Any comments? |
