`One Liberty Place
`1650 Market Street. Suite 4900
`Philadelphia, Pennsylvania 191033300
`www.diapiper.com
`
`Paul A. Taufer
`paui.taufer@d|apiper.com
`T 215.656.3385
`F 215.606.3385
`
`YOUR FILE no. 0314-1
`OUR FILE NO. DMC-1-R
`
`|)|_A P|PE|.'Q
`
`May 19. 2011
`VIA E-MML AND U.S. MM. PATENTs@oeox.coM
`
`Norman E. Lehrer, Esq.
`Norman E. Lehrer RC.
`
`1205 North Kings Highway
`Cheny Hill, NJ 08034-1982
`
`Re:
`
`Destination Maternity Corporation — M'Ci1ic LLC
`
`Dear MI’. Lehrer:
`
`Thank you for your May 1?. 2011 letter in which you assert that M'Chic does not infringe because
`
`its jeans do not recede downward. Destination Maternity disagrees. M’Chic's jeans recede downward in
`the same manner as shown in Destination Maternity’s patent figures:
`
`Figure 1 of the Destination Maternity Patents
`
`M’Chic Capri Pant
`
`Target v. DMC
`IPRZO13-00530, 531, 532, 533
`DMC0116526
`
`Target Corporation Exhibit 1086
`
`Target v. DMC
`IPR2013-00530, 531, 532, 533
`
`Target Corporation Exhibit 1086
`
`
`
`DLA PIPER
`
`Norman E. Lehrer, Esq.
`May 19, 2011
`Page Two
`
`Figure 1 of the Destination Maternity Patents
`
`lllI'CI1ich Skinny Leg Jean
`
`importantly, the portion of clothing that recedes downward may be either shallow or more
`pronounced. E U.S. Patent No. 7,814,575 col. 3 Ins. 1-2; US. Patent No. 7.900.276 col. 3 Ins. 7-8. As
`
`such. even a small dip is covered by the Destination Maternity patents.
`
`In light of the above information, we request that you provide on or before Max 27, 2011 a
`
`detailed explanation that is sufficient to remove the M'Chic products from the ambit of the claims of the
`
`Destination Maternity patents. Destination Maternity seeks assurance that its intellectual property rights
`are not being infringed.
`
`Very truly yours,
`
`/
`
`‘J’
`
`I.J
`
`
`
`\_,/
`
`DLA
`N
`
`E
`
`._
`
`_\
`,1/'
`
`.
`
`faul A. Taufer
`Partner
`
`EAST\44351420.1
`
`Target Corporation Exhibit 1086
`
`DMC011652?
`
`Target Corporation Exhibit 1086
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