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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF KANSAS
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`LOGANTREE LP
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`Plaintiff,
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`v.
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`GARMIN INTERNATIONAL, INC.
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`Defendant.
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`Case No. 6:17-cv-01217
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`PLAINTIFF LOGANTREE LP’S MOTION IN LIMINE
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`For the reasons set forth in the accompanying Memorandum of Law, LoganTree LP moves
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`for an order in limine on the following:
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`Argument, evidence, testimony, or suggestion that there is any difference in the
`1.
`operation of the step goal and step counting features between any of the Accused Products.
`
`Argument, evidence, testimony, or suggestion that Garmin’s products do not
`2.
`infringe because they do not record “a time stamp reflecting the time at which a user achieved
`his or her user-defined step goal.”
`
`
`Argument, evidence, or testimony of any comparison between the accused products
`3.
`to prior art.
`
`Argument, evidence, testimony, or suggestion that the asserted claims of the ’576
`4.
`patent are limited to workers compensation claims, back angles on lifting heavy objects, or the
`BackTalk device, or that Garmin does not infringe because Garmin’s Accused Products are
`different from the BackTalk device.
`
`Argument, evidence, testimony, or suggestion that LoganTree took contradictory
`5.
`positions between its statements to the patent office and its infringement contentions in this
`litigation.
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`Argument, evidence, testimony, or reference to any alleged improprieties in
`6.
`LoganTree’s, or any of its affiliates’, dealings with the IRS or SEC.
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`1
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`Case 6:17-cv-01217-EFM Document 246 Filed 10/10/22 Page 2 of 3
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`Respectfully submitted by:
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`FOULSTON SIEFKIN LLP
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`
`
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`/s/Clayton J. Kaiser
`Clayton J. Kaiser, Kansas Bar #24066
`1551 N. Waterfront Pkwy, Suite 100
`Wichita, Kansas 67206
`O: 316-291-9539
`F: 866-280-2532
`ckaiser@foulston.com
`
`and
`
`MCCATHERN, PLLC
`
`
`
`/s/ Arnold Shokouhi
`Arnold Shokouhi, TX (pro hac vice)
`James E. Sherry, TX (pro hac vice)
`3710 Rawlins Street, Suite 1600
`Dallas, Texas 75219
`O: 214-443-4478
`F: 214-741-4717
`arnolds@mccathernlaw.com
`jsherry@mccathernlaw.com
`
`and
`
`Ahmad, Zavitsanos & Mensing PC
`/s/ Jason McManis
`
`
`Jason McManis, TX (pro hac vice)
`Weining Bai, TX (pro hac vice)
`Sujeeth Rajavolu (pro hac vice)
`1221 McKinney Street, Suite 2500
`Houston, Texas 77010
`T: 713-655-1101
`F: 713-655-0062
`jmcmanis@azalaw.com
`wbai@azalaw.com
`srajavolu@azalaw.com
`
`Counsel for Plaintiff LoganTree LP
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`2
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`Case 6:17-cv-01217-EFM Document 246 Filed 10/10/22 Page 3 of 3
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`
`/s/Clayton J. Kaiser
`Clayton J. Kaiser, #24066
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`CERTIFICATE OF SERVICE
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`I hereby certify that on October 10, 2022, I electronically filed a copy of the foregoing
`document with the Clerk of the Court using the CM/ECF system, which will send notification of
`such filing to counsel of record for all parties in the case.
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`3
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