`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 22-311-WCB
`
`JURY TRIAL DEMANDED
`
`))))))))))
`
`IMPOSSIBLE FOODS INC.,
`
`Plaintiff,
`
`v.
`
`MOTIF FOODWORKS, INC. and
`GINKGO BIOWORKS, INC.,
`
`Defendants.
`
`PLAINTIFF IMPOSSIBLE FOODS INC.’S MOTION FOR ENTRY OF JUDGMENT
`REGARDING CLAIMS 1, 3, 10, AND 12 OF U.S. PATENT NO. 10,863,761 AND FOR
`LEAVE TO AMEND PLAINTIFF’S IDENTIFICATION OF ASSERTED CLAIMS
`
`Pursuant to the Amended Scheduling Order (D.I. 161), Plaintiff Impossible Foods Inc.
`
`(“Impossible”) hereby moves for entry of judgment of invalidity regarding claims 1, 3, 10, and 12
`
`of U.S. Patent No. 10,863,761 and for leave to serve an Amended Identification of Asserted
`
`Claims. The grounds for this motion are set forth in Impossible’s Opening Brief and supporting
`
`papers filed herewith.
`
`
`
`Case 1:22-cv-00311-WCB Document 196 Filed 09/08/23 Page 2 of 2 PageID #: 15558
`
`Respectfully submitted,
`POTTER ANDERSON & CORROON LLP
`
`By: /s/ Bindu A. Palapura
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Andrew M. Moshos (#6685)
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`amoshos@potteranderson.com
`
`Attorneys for Plaintiff Impossible Foods Inc.
`
`OF COUNSEL:
`
`Wendy L. Devine
`Kristina M. Hanson
`Jessica Ramsey
`Susannah M. L. Gagnon
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`One Market Plaza
`Spear Tower, Suite 3300
`San Francisco, CA 94105
`Tel: (415) 947-2000
`
`Matthew R. Reed
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`650 Page Mill Road
`Palo Alto, CA 94304
`Tel: (650) 493-9300
`
`Lori P. Westin
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`12235 El Camino Real
`San Diego, CA 92130
`Tel: (858) 350-2300
`
`Dated: September 8, 2023
`11044703 / 20200.00002
`
`2
`
`
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