`|PR2013-00010
`Case No. IPR2013-00010
`Patent No. 7,516,484
`Patent No. 7,516,484
`Exhibit 2004
`Exhibit 2004
`
`
`DRM
`
`DOWNS RACHLIN MARTIN PLLC
`
`LAWRENCE H. MEIER
`1meier@drm.com
`
`June 16, 2011
`
`VIA FAX AND FEDEX
`
`Timothy M. Kowalski, Esq.
`Lead Intellectual Property Counsel
`Motorola Mobility, Inc.
`600 North U.S. Highway 45
`Libertyville, IL 60048-1286
`
`Re:
`
`Arnouse Digital Devices Patent Portfolio
`
`Dear Mr. Kowalski:
`
`This is a follow up to my letter to you dated May 16, 2011.
`
`On February 7, 2011, Michael Arnouse, President of Arnouse Digital Devices Corp. (“ADD”)
`sent a letter to Mr. Sanj ay Jha, Motorola Mobility CEO, concerning the possible licensing of
`ADD patents relating to the new ATRIX products, in particular U.S. Patents Nos. 7,533,408 and
`7,516,484, and published U.S. Patent Application No. 2009/0200367.
`
`A week later, on February 15, 2011, you responded to Mr. Arnouse with an indication that it “is
`Motorola Mobility’s long-standing policy to respect the intellectual property rights of others and
`to properly investigate licensing opportunities. We have initiated an investigation into this
`matter.” You also requested an explanation regarding how ADD’s patents are relevant to
`Motorola Mobility, and asked for a claim chart.
`
`On February 17, 2011, Michael Arnouse sent you a letter and accompanying claim chart,
`explaining the relevance of an ADD patent and two ADD patent applications. Four months
`later, and 30 days after my follow up letter to you of May 16, 2011, we still have not received a
`reply. The analysis required to respond substantively to the information accompanying the
`February 17th letter only requires a few weeks to complete, not four months. Consequently, the
`
`COURTHOUSE PLAZA I 199 MAIN ST. I PO BOX190 I BURLINGTON, VT I 05402-0190 I T: +1.802.863.2375 I F:+1.802.862.7512IWWW.DRM.COM
`BRATTLEBORO, VT I BURLINGTON, VT I LEBANON, NH I MONTPELIER. VT I PLATTSBURGH, NY I ST. JOHNSBURY, VT
`
`
`
`Timothy M. Kowalski, Esq.
`June 16, 2011
`
`Page 2
`
`only reasonable conclusion we can draw is that Motorola is not interested at this time in entering
`into licensing discussions.
`
`It is clear to ADD that Motorola Mobility has needs under at least U.S. Patent No 7,516,484, and
`will have further needs under patents maturing from certain pending applications of ADD.
`Accordingly, on June 16, 2011, we filed a complaint for patent infringement with the U.S.
`District Court for the District of Vermont, a copy of which is enclosed. Because ADD remains
`interested in licensing its patents to Motorola Mobility, ADD will refrain from serving the
`complaint for a thirty-day period, i.e., until July 16, 2011, to give the parties a further
`opportunity to discuss licensing opportunities.
`
`As mentioned in my letter to you of May 16, 2011, ADD is willing to explore an exclusive
`patent license agreement with Motorola Mobility that includes sublicense rights and the right to
`sue unlicensed parties for infiingement. ADD is also willing to discuss non-exclusive licensing
`opportunities.
`
`This may be a matter that can only be resolved through the courts. In the event, however, that
`Motorola Mobility is interested in exploring a licensing solution, we look forward to receiving a
`substantive reply to the February 17th letter from Mr. Amouse well in advance of July 16th.
`
`Very truly yours,
`
`DOWNS RACHLIN MARTIN PLLC
`
`Lawr
`
`Meier
`
`Enclosure
`
`Cc:
`
`Mr. Michael Amouse
`
`4503934.l
`
`DOWNS RACHLIN MARTIN PLLC
`
`
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