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and November 30, 1992. As used in this opinion, "petitioner"
will refer to Compaq Computer Corporation together with its
subsidiaries. "Compaq U.S." will refer to the Compaq Computer
Corporation Houston operation that includes the company
headquarters and a manufacturing plant.
Background
Compaq U.S. was founded in 1982, when a group of former
employees of Texas Instruments designed a portable personal
computer (PC) on a place mat in a restaurant. Since its
incorporation, Compaq U.S. has been engaged in the business of
designing, manufacturing, and selling PC's, and, by 1994, Compaq
U.S. had become the world's largest manufacturer of PC's. The
success of Compaq U.S. was primarily attributable to its ability
to bring high-quality products to market quickly.
At all relevant times, Compaq U.S. manufactured central
processing units (CPU's) for its PC's at Compaq U.S. in Houston,
at Compaq Asia (Pte) Ltd. (Compaq Asia) in Singapore, and at
Compaq Computer Manufacturing Ltd. in Scotland. The materials
required to manufacture CPU's include PCA's, the electronic
circuitry inside the CPU that allows the PC to operate. Each PCA
consists of a printed circuit board, the communication platform
to which components are attached, and any number of combinations
of chips, resistors, and capacitors. These circuits and boards
interconnect to deliver a desired electronic function.
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