Case 3:14-cv-02235-DMS-BLM Document 304-1 Filed 03/22/18 PageID.11613 Page 1 of 15
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`Allison H. Goddard (211098)
` ali@pattersonlawgroup.com
`PATTERSON LAW GROUP
`402 West Broadway, 29th Floor
`San Diego, CA 92101
`(619) 398-4760
`(619) 756-6991 (facsimile)
`
`Attorneys for Defendant,
`Wi-LAN Inc.
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`
`
`
`UNITED STATES DISTRICT COURT
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`SOUTHERN DISTRICT OF CALIFORNIA
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`
`
`APPLE INC.,
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`vs.
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`WI-LAN INC.,
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`Plaintiff,
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`Defendant.
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`_________________________________
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`WI-LAN INC.,
`
`vs.
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`APPLE INC.,
`
`Plaintiff,
`
`Defendant.
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`No. 3:14-cv-2235-DMS-BLM (Lead
`Case); Consolidated with 3:14-cv-01507-
`DMS-BLM
`DEMAND FOR JURY TRIAL
`
`MEMORANDUM OF POINTS AND
`AUTHORITIES IN SUPPORT OF
`DEFENDANT WI-LAN INC.’S
`MOTION TO STRIKE EXPERT
`OPINIONS REGARDING STRICKEN
`PRIOR ART REFERENCES AND
`UNDISCLOSED INVALIDITY
`THEORIES
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`Department: 13A
`Judge: Hon. Dana M. Sabraw
`Magistrate: Hon. Barbara L. Major
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`MOTION TO STRIKE EXPERT OPINIONS
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`TABLE OF CONTENTS
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`I.
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`INTRODUCTION ............................................................................................... 1
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`II. STATEMENT OF RELEVANT FACTS ........................................................... 1
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`III. ARGUMENT ................................................................................................... 4
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` Legal Standards for Striking Expert Testimony .............................................. 4
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` Fuja Report (’757 Patent) ................................................................................ 5
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`1. Ericsson with Ericsson IP Traffic ................................................................ 5
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`2. Ericsson with Klayman ................................................................................ 6
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` Hochwald Report (’040 Patent) ....................................................................... 7
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`1. Doshi with Calvignac ................................................................................... 7
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`2. GSM with Ermel and Hartmann .................................................................. 8
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`3. Written Description ...................................................................................... 8
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` Lanning Report (Bandwidth Patents) .............................................................. 9
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`1. Chuah ’254 with Sau .................................................................................... 9
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` “Background Prior Art” ................................................................................... 9
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`IV. CONCLUSION ..............................................................................................10
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`Case 3:14-cv-02235-DMS-BLM Document 304-1 Filed 03/22/18 PageID.11615 Page 3 of 15
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`CASES
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`TABLE OF AUTHORITIES
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`Page(s)
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`Avago Techs. Gen. IP Pte Ltd. v. Elan Microelecs. Corp.,
`No. C04-05385, 2007 WL 2103896 (N.D. Cal. July 20, 2007),
`aff’d, 2007 WL 2433386 (N.D. Cal. Aug. 22, 2007)............................................ 4
`
`Bayer Healthcare Pharm., Inc. v. River's Edge Pharm., LLC,
`No. 1:11-cv-1634, 2015 WL 11142427 (N.D. Ga. May 21, 2015) .............passim
`
`Chemfree Corp. v. J. Walter, Inc.,
`No. CIV. 1:04-cv-3711, 2008 WL 4845129 (N.D. Ga. Aug. 27,
`2008) ..................................................................................................................... 5
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`Elbit Sys. Land & C4I Ltd. v. Hughes Network Sys., LLC,
`No. 2:15-cv-00037, 2017 WL 2651618 (E.D. Tex. June 20, 2017) ....... 4, 6, 8, 10
`
`MediaTek Inc. v. Freescale Semiconductor, Inc.,
`No. 11-CV-5341, 2014 WL 690161 (N.D. Cal. Feb. 21, 2014) ........................... 4
`
`O2 Micro Int’l, Ltd. v. Monolithic Power Sys., Inc.,
`467 F. 3d 1355 (Fed. Cir. 2006) ........................................................................... 4
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`STATUTES
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`35 U.S.C. § 102 .......................................................................................................... 6
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`35 U.S.C. § 112 .................................................................................................passim
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`MOTION TO STRIKE EXPERT OPINIONS
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`I.
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`INTRODUCTION
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`On March 2, 2018, this Court ordered Apple’s amended invalidity
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`contentions stricken because Apple’s late addition of additional prior art
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`references, obviousness combinations, claim charts, and Section 112 defenses
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`would unduly prejudice Wi-LAN. (ECF No. 297 at 3.) Despite the Court’s ruling,
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`Apple continues to advance its stricken invalidity theories through the opinions in
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`three of its expert reports. Wi-LAN immediately requested that Apple remove the
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`portions of its expert reports that were subject to the Court’s order so that Wi-
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`LAN’s experts could clearly respond to Apple’s invalidity arguments that
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`remained in the case. Ten days later (and three days before expert rebuttal reports
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`were due), Apple agreed only to withdraw portions of one report addressing only
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`one of the six patents-in-suit. After continued requests from Wi-LAN (and
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`meeting and conferring), Apple eventually agreed to withdraw some additional
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`expert testimony, but these withdrawals are insufficient. Apple’s three expert
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`reports still contain invalidity opinions not supported by Apple’s June 29, 2017
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`Invalidity Contentions and which were stricken by the Court’s order. Accordingly,
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`Wi-LAN is forced to move the Court to strike the unsupported portions of the
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`experts’ opinions.
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`II.
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`STATEMENT OF RELEVANT FACTS
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`On June 19, 2014, Apple filed this declaratory judgment action against Wi-
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`LAN. The patents in suit are U.S. Patent No. 8,537,757 (the “’757 patent”), U.S.
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`Patent No. 8,311,040 (the “’040 patent”), U.S. Patent No. 8,457,145 (the “’145
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`patent”), U.S. Patent No. 8,462,723 (the “’723 patent”), U.S. Patent No. 8,462,761
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`(the “’761 patent”), and U.S. Patent No. 8,615,020 (the “’020 patent”). On June
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`29, 2017, Apple served its Invalidity Contentions on Wi-LAN.
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`On January 2, 2018, ten days prior to the close of fact discovery and without
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`asking the Court for leave to amend, Apple served Amended Invalidity
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`Contentions on Wi-LAN, adding 29 newly alleged prior art references, plus new
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`combinations and new Section 112 invalidity theories that were not disclosed in
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`Apple’s original invalidity contentions. On January 11, 2018, Wi-LAN moved to
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`strike these amended contentions. Apple admitted that its Amended Invalidity
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`Contentions contained new invalidity theories. (See ECF No. 266 at 1–2; ECF No.
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`293.)
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`On February 19, 2018, the parties exchanged expert reports. Apple’s expert
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`reports included the report of Dr. Bertrand Hochwald (alleging invalidity of the
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`’040 Patent), the report of Dr. Thomas Fuja (alleging invalidity of the ’757 Patent),
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`and the report of Mr. Mark Lanning (alleging invalidity of the four other patents-
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`in-suit, called the “Bandwidth Patents”). All three expert reports relied on prior art
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`references, combinations, and/or Section 112 invalidity theories that were newly
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`disclosed in Apple’s improper Amended Invalidity Contentions.
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`In addition, the Lanning report relies on the “MAC Proposal” and
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`“Fiberless” prior art references in its invalidity theories. These two references
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`were not included in either Apple’s original or amended contentions, and the Court
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`denied Apple’s motion for leave to amend its invalidity contentions to include
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`these references. (ECF No. 302.)
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`On March 2, 2018, the Court granted Wi-LAN’s motion to strike Apple’s
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`amended invalidity contentions, striking Apple’s amended contentions in their
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`entirety as unduly prejudicial to Wi-LAN. (ECF No. 297 at 3.) The Court’s Order
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`is clear that “Apple’s amendments include[d] at least two new obviousness
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`combinations (Chuah and Sau, Ericsson and Ericsson IP Traffic), twenty two new
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`background references, two new claim charts (UMTS and Carvalho) and
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`amendments to Apple’s Section 112 defenses.” (Id.)
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`Less than an hour after receiving the Court’s Order, Wi-LAN requested that
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`Apple provide a list of paragraphs that Apple would be withdrawing from its
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`expert reports. (See Ex. D at 619.) With rebuttal expert reports due nearly two
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`weeks later, obtaining this clarity was important for Wi-LAN’s experts to properly
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`rebut Apple’s voluminous validity challenges. Wi-LAN again e-mailed Apple on
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`March 7, 2018 requesting a list of withdrawn paragraphs, and Apple again did not
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`respond. (See Ex. E at 620.) Wi-LAN also met and conferred with Apple on
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`March 8, 2018, but Apple was not prepared to provide a list of withdrawn
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`paragraphs on the call.
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`Indeed, Apple did not provide Wi-LAN with any such list of withdrawn
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`paragraphs until March 12, 2018—ten days after Wi-LAN’s initial request and a
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`mere three days before expert rebuttal reports were due. (See Ex. D at 618–19.)
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`Despite this Court’s ruling, Apple only agreed to withdraw paragraphs 81 (in part),
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`83 (in part), 300–483, and 523–528 of Dr. Hochwald’s expert report. (Id.) These
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`paragraphs include opinions relating to the new UMTS and Carvalho references
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`and one of the new Section 112 theories from Apple’s amended invalidity
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`contentions that were stricken by the Court. (See Ex. D at 618.) However, Apple
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`refused to withdraw any other opinions from its three invalidity experts.
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`On March 14, 2018, Wi-LAN again explained to Apple in an email why
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`these withdrawals were insufficient. (Ex. D at 618.) On March 19, 2018, the
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`Court denied Apple’s Motion for Leave to Amend, and Wi-LAN immediately
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`asked Apple to withdraw paragraphs relating to the references Apple had sought to
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`add to its invalidity contentions in that motion. (Ex. D at 617.) On March 21,
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`2018, a week after Wi-LAN’s March 14 email, Apple finally agreed to withdraw
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`additional paragraphs from its Hochwald, Fuja, and Lanning expert reports. (Ex. D
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`at 617.) Yet even after these withdrawals, many paragraphs remain that cite prior
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`art combinations and arguments Apple first introduced in its now-stricken
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`Amended Invalidity Contentions. In several emails, Apple stated that it intended
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`to move the Court for “clarification” of the Court’s prior order on some of these
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`issues. (Ex. D at 617–18.) However, because disputed issues remain and because
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`Apple’s proposed motion (still not filed with this Court) for clarification does not
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`appear to resolve all of the remaining disputed issues, Wi-LAN has no choice but
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`to move the Court to strike Apple’s expert opinions.
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`III. ARGUMENT
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` Legal Standards for Striking Expert Testimony
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`The Patent Local Rules are “designed specifically to require parties to
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`crystallize their theories of the case early in the litigation so as to prevent the
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`‘shifting sands’ approach.” O2 Micro Int’l, Ltd. v. Monolithic Power Sys., Inc.,
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`467 F. 3d 1355, 1364 (Fed. Cir. 2006). In the Southern District of California,
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`“each item of prior art,” “any combinations of prior art,” and any 35 U.S.C. § 112
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`grounds of invalidity must be disclosed in a party’s invalidity contentions. P.L.R.
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`3.3.
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`Any invalidity theories not disclosed under the patent local rules “are
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`barred . . . from presentation at trial (whether through expert opinion testimony or
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`otherwise).” MediaTek Inc. v. Freescale Semiconductor, Inc., No. 11-CV-5341,
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`2014 WL 690161, at *5 (N.D. Cal. Feb. 21, 2014) (striking expert report where the
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`portion of prior art identified “differs considerably” from what was disclosed in the
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`invalidity contentions); Avago Techs. Gen. IP Pte Ltd. v. Elan Microelecs. Corp.,
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`No. C04-05385, 2007 WL 2103896, at *2 (N.D. Cal. July 20, 2007) (“Defendant is
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`limited to the pinpoint citations disclosed in its [Final Invalidity Contentions].”),
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`aff’d, 2007 WL 2433386 at *1 (N.D. Cal. Aug. 22, 2007).
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`Striking portions of an expert report is particularly appropriate where, as
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`here, the prior art references and invalidity theories have previously been stricken
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`by the Court, or where leave to amend has been denied. See, e.g., Elbit Sys. Land
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`& C4I Ltd. v. Hughes Network Sys., LLC, No. 2:15-cv-00037, 2017 WL 2651618,
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`at *8 (E.D. Tex. June 20, 2017) (striking portions of expert report that rely on
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`references previously stricken
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`from
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`invalidity contentions), report and
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`recommendation adopted, 2017 WL 4693971 (E.D. Tex. July 31, 2017); Chemfree
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`Corp. v. J. Walter, Inc., No. CIV. 1:04-cv-3711, 2008 WL 4845129, at *7–8 (N.D.
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`Ga. Aug. 27, 2008) (striking references that “[t]he Court previously struck . . .
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`from Defendants’ invalidity contentions” and references that “the Court did not
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`permit Defendants to amend their invalidity contentions to include”).
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`Courts also strike expert opinions relating to combinations of references
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`where those combinations were not disclosed in invalidity contentions, even if the
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`references were individually disclosed. See Bayer Healthcare Pharm., Inc. v.
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`River's Edge Pharm., LLC, No. 1:11-cv-1634, 2015 WL 11142427, at *14 (N.D.
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`Ga. May 21, 2015) (striking obviousness combination from expert report where
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`“nowhere in [the defendants’] contentions are these various combinations, or
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`motivations to combine all of the various references, disclosed”), report and
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`recommendation adopted, 2015 WL 11142424 (N.D. Ga. June 16, 2015).
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`Fuja Report (’757 Patent)
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`The Fuja report sets forth invalidity opinions for the ’757 Patent. (See Ex.
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`A.) Dr. Fuja’s invalidity opinions detailed below are not supported by Apple’s
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`Invalidity Contentions and should be stricken.
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`1.
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`Ericsson with Ericsson IP Traffic
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`The Court has already found that the combination of Ericsson and Ericsson
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`IP Traffic is a “new obviousness combination[],” striking Apple’s amended
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`invalidity contentions that included it. (ECF No. 297 at 3.) The Ericsson IP
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`Traffic reference is not identified anywhere in Apple’s June 29, 2017 Invalidity
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`Contentions.1 (See Ex. F at 625–28.) Indeed, Apple admitted that “Apple added
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`further citations to its Klayman and Ericsson claim charts to show how Klayman,
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`Ericsson and Ericsson IP Traffic further disclose these claim terms and related
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`limitations.” (ECF No. 293 at 3.) However, despite the Court’s clear holding,
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`Apple refuses to withdraw this invalidity argument. (See Ex. A at 40, 43, 46–50,
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`78–79, 108–09.) Accordingly, Paragraphs 120, 129, 139–150, 236–237, and 341–
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`342 of the Fuja report, which rely on the combination of Ericsson and Ericsson IP
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`Traffic, must be stricken. See Elbit, 2017 WL 2651618 at *8.
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`2.
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`Ericsson with Klayman
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`Apple separately disclosed the Ericsson and Klayman references in its
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`Invalidity Contentions, but never suggested that the two references should be
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`combined, despite providing a long list of other obviousness combinations. (See
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`Ex. M at 948, Ex. N at 992.) Yet the Fuja report relies on their combination. (See
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`Ex. A at 40, 43, 63–64, 70–71, 73–75.)
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`Where two references are disclosed individually in invalidity contentions,
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`but their combination and motivation to combine them are not disclosed, an
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`expert’s opinion cannot rely on their combination. See Bayer, 2015 WL 11142427
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`at *14. In the Fuja report, paragraphs 120, 129, 187–190, 209–212, and 219–223
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`rely on the undisclosed combination of Ericsson with Klayman and must therefore
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`be stricken.
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`1 While Apple’s original chart cited to quotes from Ericsson IP Traffic, a separate
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`reference from Apple’s main Ericsson reference, Apple’s chart failed to identify
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`Ericsson IP Traffic as the source of these quotes and implied that those quotes
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`were part of the main Ericsson reference despite the fact that combining two
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`references is impermissible under 35 U.S.C. § 102.
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` Hochwald Report (’040 Patent)
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`The Hochwald report sets forth invalidity opinions for the ’040 Patent. (See
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`Ex. B.) In addition to the paragraphs Apple has already agreed to withdraw, Dr.
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`Hochwald’s report contains invalidity opinions that are not supported by Apple’s
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`Invalidity Contentions and should be stricken.
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`1.
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`Doshi with Calvignac
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`The Hochwald report relies on an obviousness combination of Doshi in view
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`of Calvignac. (See Ex. B at 200, 211–16, 224.) Apple disclosed the Doshi and
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`Calvignac references individually in its Invalidity Contentions, but never disclosed
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`the combination of the two references, despite providing a long list of other
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`obviousness combinations.2 (See Ex. H at 715; Ex. I at 767; see ECF No. 293 at
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`3.) Apple first disclosed the combination of Doshi and Calvignac in its Amended
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`Invalidity Contentions, which were stricken by the Court. (See Ex. Q at 1074.)
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`Indeed, Apple admitted that “[i]n its amended invalidity contentions, Apple
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`provided … the combination of Doshi and Calvignac.” (ECF No. 293 at 3.)
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`Where two references are disclosed individually in invalidity contentions,
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`but their combination and motivation to combine are not disclosed, an expert’s
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`2 Apple may argue that the generic disclosure in its charts is sufficient to show the
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`combination of any two references. See Ex. H at 715 (stating merely that “Apple
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`reserves the right to rely upon the knowledge of one skilled in the art, or any other
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`disclosed prior art reference, alone or in combination, whether produced by Apple
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`or Wi-LAN, to show the element and thereby invalidate those claims”). This
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`boilerplate language does not identify the actual combinations of references Apple
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`now tries to assert, and it does not show what the motivation to combine would be,
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`so it is not a proper disclosure. See Bayer, 2015 WL 11142427, at *14.
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`MOTION TO STRIKE EXPERT OPINIONS
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`opinion cannot rely on their combination. See Bayer, 2015 WL 11142427 at *14.
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`In the Hochwald report, paragraphs 121, 154, 157–163, 166–167, 171–172, and
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`206 rely on the undisclosed combination of Doshi and Calvignac and must
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`therefore be stricken.
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`2. GSM with Ermel and Hartmann
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`The Hochwald report relies on an obviousness combination of GSM in view
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`of Ermel and Hartmann. (See Ex. B at 227, 230–31, 240.) While Apple has agreed
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`to withdraw paragraph 215 of the Hochwald report, Apple has not addressed the
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`other three paragraphs that rely on this combination. The Ermel and Hartmann
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`references are not referenced anywhere in Apple’s Invalidity Contentions. (See
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`Ex. F at 625–28, Ex. J at 775.) Apple’s amended contentions adding these
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`references were stricken by the Court. (See Ex. R at 1143.) Because paragraphs
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`214, 223, and 240 of the Hochwald report rely on references not found in the
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`Invalidity Contentions, they must be stricken from the Hochwald report. See Elbit,
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`2017 WL 2651618 at *8.
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`3. Written Description
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`The Hochwald report argues that the “establish a length for the PDU based
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`on the bandwidth allocated to the specified connection in a current frame” term in
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`claim 1 of the ’040 Patent lacks written description. (See Ex. B at 354, 356.) This
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`argument is missing from Apple’s Invalidity Contentions. (See Ex. F at 680–81.)
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`However, Apple added this argument in its now-stricken Amended Invalidity
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`Contentions. (See Ex. S at 1229–30.)
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`The Court clearly struck the “amendments to Apple’s Section 112 defenses”
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`that added these terms. (ECF No. 297 at 3; Ex. S at 1229–30.) Despite the fact
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`Apple nonetheless refuses to withdraw these arguments. For these reasons, the
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`MOTION TO STRIKE EXPERT OPINIONS
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`portions of paragraphs 529 and 532 of the Hochwald report that are regarding
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`claim 1 should be stricken.
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` Lanning Report (Bandwidth Patents)
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`The Lanning report sets forth invalidity opinions for the ’145, ’723, ’761,
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`and ’020 Patents (the “Bandwidth Patents”). (See Ex. C.) Mr. Lanning’s invalidity
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`opinions detailed below are not supported by Apple’s Invalidity Contentions and
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`must be stricken.
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`1.
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`Chuah ’254 with Sau
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`Exhibits 3–6 of the Lanning report rely on the obviousness combination of
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`the Chuah ’254 reference in view of the Sau reference. (See Ex. C at 455–59, 467–
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`69, 486, 512, 514–15, 522, 538, 556, 575, 585, 594–95, 599, 611, 613–14.) The
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`Court has already found that the combination of Chuah ’254 and Sau is a “new
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`obviousness combination[],” striking the amended invalidity contentions that first
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`disclosed it. (ECF No. 297 at 3.) Indeed, Apple admitted that “[i]n its amended
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`invalidity contentions, Apple provided further citations to Chuah and Chuah
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`combined with Sau.” (ECF No. 293 at 1.) Apple separately identified Chuah ’254
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`and Sau in its Invalidity Contentions, but did not disclose the combination of
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`Chuah ’254 in view of Sau, despite providing a long list of other obviousness
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`combinations. (See Ex. F at 626–27 (disclosing both references), Ex. G at 685, Ex.
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`K at 866, Ex. L at 895, Ex. O at 1025 (omitting Sau from the list of references to
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`be combined with Chuah ’254).)
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`Where two references are disclosed individually in invalidity contentions,
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`but their combination and motivation to combine are not disclosed, an expert’s
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`opinion cannot rely on their combination. See Bayer, 2015 WL 11142427 at *14.
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`Paragraphs 195–205, 233-239, and exhibits 3–6 of the Lanning report rely on the
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`undisclosed combination of Chuah ’254 with Sau and therefore must be stricken.
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`“Background Prior Art”
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`MOTION TO STRIKE EXPERT OPINIONS
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`Paragraphs 95–113 of the Lanning report discuss various other alleged prior
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`art references not disclosed in Apple’s Invalidity Contentions, including U.S.
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`Patent No. 5,923,650 to Chen, U.S. Patent No. 6,493,331 to Walton, and U.S.
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`Patent No. 6,621,804 to Holtzman. (Compare Ex. C at 425–30 with Ex. F at 625–
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`28.) These references are part of the “twenty-two new background references” the
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`Court already ordered stricken. (ECF No. 297 at 3.)
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`Further, paragraphs 84–90 of the Hochwald report rely on the UMTS
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`reference, which was not identified in Apple’s Invalidity Contentions. (Compare
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`Ex. B at 184–86 with Ex. F at 625–28.) The Court explicitly struck Apple’s
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`UMTS claim charts. (ECF No. 297 at 3.)
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`Where references were stricken from invalidity contentions, they should also
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`be stricken from expert reports. See Elbit, 2017 WL 2651618 at *8. Paragraphs
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`95–113 of the Lanning report and paragraphs 84–90 of the Hochwald report rely
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`on undisclosed references and therefore must be stricken.
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`IV. CONCLUSION
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`For the foregoing reasons, Wi-LAN respectfully requests that the Court
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`grant this motion and strike paragraphs 120, 129, 139–150, 187–190, 209–212,
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`219–223, 236–237, and 341–342 of the Fuja report; paragraphs 84–90, 121, 154,
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`157–163, 166–167, 171–172, 206, 214, 223, 240, 529, and 532 of the Hochwald
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`report; paragraphs 95–113, 195–205, and 233–239 of the Lanning report; and the
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`portions of Exhibits 3–6 of the Lanning report related to Sau.3
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`3 Because Apple’s invalidity challenges addressed in this motion were understood
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`by Wi-LAN to have been struck by the Court in its March 2, 2018 Order, Wi-
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`LAN’s expert, Ken Stanwood, did not address these challenges in his March 15,
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`MOTION TO STRIKE EXPERT OPINIONS
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`Case No. 3:14-cv-02235-DMS-BLM
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`Dated: March 22, 2018
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`Respectfully submitted,
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`/s/ Allison Goddard
`By:
` Allison H. Goddard (211098)
` ali@pattersonlawgroup.com
` PATTERSON LAW GROUP
` 402 West Broadway, 29th Floor
` San Diego, CA 92101
` (619) 398-4760
` (619) 756-6991 (facsimile)
`
`
`
` Robert Cote
` rcote@mckoolsmith.com
` Brett Cooper
` bcooper@mckoolsmith.com
` Kevin Schubert
` kschubert@mckoolsmith.com
` Christopher McNett (298893)
` cmcnett@mckoolsmith.com
` McKOOL SMITH, P.C.
` One Bryant Park, 47th Floor
` New York, NY 10036
` (212) 402-9400
` (212) 402-9444 (facsimile)
`
` Seth Hasenour
` shasenour@mckoolsmith.com
` MCKOOL SMITH, P.C.
` 300 W. 6th Street, Suite 1700
` Austin, TX 78701
` (512) 692-8700
` (512) 692-8744 (facsimile)
`
` Attorneys for Defendant,
` Wi-LAN Inc.
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`2018 validity report. If Apple is allowed to assert these challenges, it would
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`further prejudice Wi-LAN. Should the Court nonetheless permit any of these
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`paragraphs to remain, Wi-LAN’s expert should be granted a chance to rebut.
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`MOTION TO STRIKE EXPERT OPINIONS
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`Case No. 3:14-cv-02235-DMS-BLM
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`PROOF OF SERVICE
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`I hereby certify that on March 22, 2018, I caused a copy of this pleading to
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`be delivered via CM/ECF on the counsel of record.
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`Dated: March 22, 2018
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`By:
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`/s/ Allison Goddard
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`Allison H. Goddard (211098)
` ali@pattersonlawgroup.com
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`PATTERSON LAW GROUP
`402 West Broadway, 29th Floor
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` San Diego, CA 92101
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`(619) 398-4760
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`(619) 756-6991 (facsimile)
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`Attorneys for Defendant,
` Wi-LAN Inc.
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`MOTION TO STRIKE EXPERT OPINIONS
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`-12-
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`Case No. 3:14-cv-02235-DMS-BLM
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