`
`
`Dallas
`Silicon Valley
`
`
`
`Jennifer Towle
`800 S. Austin, Suite 200
`Georgetown, TX 78626
`512-582-2828
`www farneydaniels.com
`
`
`Minneapolis
`Wilmington
`
`
`March 28, 2014
`
`VIA E-MAIL
`
`Brian M. Berliner
`O’Melveny & Myers LLP
`400 South Hope Street
`Los Angeles, CA 90071-2899
`
`Re: Memory Integrity LLC v. Samsung Electronics Co., Ltd. et al., Case No. 1:13-cv-01808-
`GMS
`
`
`Dear Mr. Berliner:
`
`I write in response to your letter dated March 14, 2014. In your letter, you claim: (1) that
`Memory Integrity does not have a sufficient basis under Federal Rule of Civil Procedure 11 for
`claiming that Samsung infringes U.S. Patent No. 7,296,121 (the “’121 Patent”),
`
`
`
`Response to Samsung’s Allegation of a Rule 11 Violation:
`
`
`
`
`
`In your letter you assert that none of the accused Samsung products listed in the
`Complaint contain a “point-to-point” architecture. You further assert that all CPU
`communications in these products pass through the Snoop Control Unit using a bus structure
`rather than a point-to-point architecture. On this basis, you allege that Memory Integrity failed
`to conduct an adequate pre-filing investigation.1
`
`We respectfully disagree with your assertion that the Samsung products identified in the
`Complaint do not contain a point-to-point architecture and that Memory Integrity failed to
`conduct an adequate pre-filing investigation. As shown in Figure 1.1 of your letter (reproduced
`below), the Cortex-A9 contains separate links between each core (e.g., CPU0, CPU1, CPU2, and
`CPU3) and the Snoop Control Unit (SCU). Thus, the cores do not use a shared-bus architecture
`
`1 Your letter also states that the Galaxy Tab 7.0 product does not have a multicore processor. However, Samsung’s
`own webpage for the Samsung Galaxy Tab 7.0 Plus indicates that at least that version of the product has a multi-
`core processor: http://www.samsung.com/global/microsite/galaxytab/7.0/spec.html?type=find.
`
`1
`
`APPLE 1016
`
`
`
`March 28. 2014
`
`Page 2
`
`but rather utilize separate links to the SCU. Indeed, this is consistent with what the ’ 121 Patent
`shows in Figure 1B, which the Patent’s specification describes as a point-to-point architecture
`that can use the techniques of the patented invention. See ’ 121 Patent. Fig. 1B and 6:24-35.
`Further, the patent notes that the use of a switch as shown in Figure 1B is advantageous because
`it “allows implementation with fewer point-to-point links.” See id. at 6:28-30.
`
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`See Figlu‘e 1.1 of the Cortex-A9 lieference Manual (annotations added in red).
`
`
`
`Accordingly, your assertions that SamSImg does not infringe the ’ 121 Patent and that Memory
`Integrity failed to conduct an adequate pre-filing investigation are without merit.
`
`
`
`
`2
`
`
`
`March 28, 2014
`
`Page 3
`
`
`
`Should you wish to discuss these matters fluther, please let me know.
`
`Sincerely,
`
`/s/ Jennifer Towle
`Jemlifer Towle
`
`3
`
`
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