IPR2015-00163, No. 2001 Exhibit - Initial Identification of Asserted Claims And Accused Products served on Petitioners in Memory Integrity LLC v Amazoncom Inc et al (P.T.A.B. Feb. 13, 2015)

IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`MEMORY INTEGRITY, LLC,
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`Civil Action No. 1:13-cv-01796-GMS
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF MEMORY INTEGRITY, LLC’S
`INITIAL IDENTIFICATION OF ASSERTED CLAIMS AND ACCUSED PRODUCTS
`
`Plaintiff Memory Integrity, LLC (“MI” “Memory Integrity” or “Plaintiff”) provides the
`
`following preliminary identification of the asserted claims and accused products to Defendant
`
`Apple Inc. (“Apple”) in accordance with paragraph 5(b) of this Court’s October 1, 2014
`
`Scheduling Order.
`
`The preliminary identifications contained herein are based upon information reasonably
`
`and currently available to Plaintiff. However, Plaintiff anticipates that discovery and other
`
`pretrial preparation will uncover additional relevant information, which may lead to, for
`
`example, the identification of additional accused products. Plaintiff reserves the right to clarify,
`
`amend, modify, and supplement the information contained in these identifications as information
`
`becomes available through discovery or investigation during this action, and as permitted by the
`
`Federal Rules of Civil Procedure and this Court’s Scheduling Order.
`
`I.
`
`ASSERTED CLAIMS AND ACCUSED PRODUCTS
`
`Plaintiff identifies the following accused products which are alleged to infringe at least
`
`claims 1-3, 8, 11-12, and 14-25 of U.S. Patent No. 7,296,121 (the “’121 Patent” or the “Patent-
`
`in-Suit”):
`
`
`
`1
`
`1
`
`

`
`All Apple products containing a multi-core, ARM-based processor1 with a snoop control
`
`unit (or similar snoop-filtering unit).
`
`The foregoing includes but is not limited to:
`
` Apple’s iPad 2, iPad 3, iPad 4, iPad Mini, iPad Mini 2, iPad Air products;
`
` Apple’s iPhone 4S, iPhone 5, iPhone 5C, iPhone 5S, iPhone 6, iPhone 6 Plus
`
`products;
`
` Apple’s iPod Touch (5th Generation) products;
`
` All versions, variations, models, and upgrades of the foregoing; and any products
`
`that are reasonably similar to any of the above-identified products.
`
`II.
`
`FILE HISTORY
`
`The file history of the Patent-in-Suit is being produced with Bates numbers
`
`MI_ALL_000001-000188.
`
`
`1
`“ARM-based processor” refers to any processor compatible, in whole or in part, with an
`ARM instruction set, regardless of whether the processor itself was designed by ARM.
`2
`
`
`
`2
`
`

`
`Dated: October 13, 2014
`
`Respectfully submitted,
`
`
`
`/s/ Jonathan D. Baker
`Jonathan D. Baker (pro hac vice)
`FARNEY DANIELS PC
`411 San Borel Ave., Suite 350
`San Mateo, CA 94402
`Telephone: (424) 268-5200
`Facsimile: (424) 268-5219
`jbaker@farneydaniels.com
`
`Stamatios Stamoulis (#4606)
`stamoulis@swdelaw.com
`Richard C. Weinblatt (#5080)
`weinblatt@swdelaw.com
`STAMOULIS & WEINBLATT LLC
`Two Fox Point Centre
`6 Denny Road, Suite 307
`Wilmington, DE 19809
`(302) 999-1540
`
`Attorneys for Plaintiff Memory Integrity, LLC
`
`
`
`3
`
`
`
`
`
`3
`
`

`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on October 13, 2014, I caused a copy of this document to be served
`
`by transmitting it via e-mail or electronic transmission to counsel of record for Defendant.
`
`/s/ Jonathan Baker
`Jonathan Baker
`
`
`
`
`
`4
`
`4
`
`

`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`MEMORY INTEGRITY, LLC,
`
`Plaintiff,
`
`v.
`
`HTC CORPORATION AND
`HTC AMERICA, INC.,
`
`Defendants.
`
`Civil Action No. 1:13-cv-01802-GMS
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF MEMORY INTEGRITY, LLC’S
`INITIAL IDENTIFICATION OF ASSERTED CLAIMS AND ACCUSED PRODUCTS
`
`Plaintiff Memory Integrity, LLC (“MI” “Memory Integrity” or “Plaintiff”) provides the
`
`following preliminary identification of the asserted claims and accused products to Defendants
`
`HTC Corporation and HTC America, Inc. (collectively, “HTC”) in accordance with paragraph
`
`5(b) of this Court’s October 1, 2014 Scheduling Order.
`
`The preliminary identifications contained herein are based upon information reasonably
`
`and currently available to Plaintiff. However, Plaintiff anticipates that discovery and other
`
`pretrial preparation will uncover additional relevant information, which may lead to, for
`
`example, the identification of additional accused products. Plaintiff reserves the right to clarify,
`
`amend, modify, and supplement the information contained in these identifications as information
`
`becomes available through discovery or investigation during this action, and as permitted by the
`
`Federal Rules of Civil Procedure and this Court’s Scheduling Order.
`
`
`
`1
`
`5
`
`

`
`I.
`
`ASSERTED CLAIMS AND ACCUSED PRODUCTS
`
`Plaintiff identifies the following accused products which are alleged to infringe at least
`
`claims 1-3, 8, 11-12, and 14-25 of U.S. Patent No. 7,296,121 (the “’121 Patent” or the “Patent-
`
`in-Suit”):
`
`All HTC products containing a multi-core, ARM-based processor1 with a snoop control
`
`unit (or similar snoop-filtering unit).
`
`The foregoing includes but is not limited to:
`
` HTC’s Jetstream products;
`
` HTC’s Amaze 4G, Desire 510, Desire 610, Desire 612, Desire 816, Droid DNA,
`
`Droid Incredible, Evo, First, myTouch 4G, myTouch 4G Slide, One, One E8,
`
`One (M7), One (M8), One Max, One Mini, One remix, One S, One SV, One VX,
`
`One X, One X+, Rezound, Vivid, Windows Phone 8x, and 8XT products;
`
` All versions, variations, models, and upgrades of the foregoing; and any products
`
`that are reasonably similar to any of the above-identified products.
`
`II.
`
`FILE HISTORY
`
`The file history of the Patent-in-Suit is being produced with Bates numbers
`
`MI_ALL_000001-000188.
`
`
`1
`“ARM-based processor” refers to any processor compatible, in whole or in part, with an
`ARM instruction set, regardless of whether the processor itself was designed by ARM.
`2
`
`
`
`6
`
`

`
`Dated: October 13, 2014
`
`Respectfully submitted,
`
`
`
`/s/ Jonathan D. Baker
`Jonathan D. Baker (pro hac vice)
`FARNEY DANIELS PC
`411 Borel Ave., Suite 350
`San Mateo, CA 94402
`Telephone: (424) 268-5200
`Facsimile: (424) 268-5219
`jbaker@farneydaniels.com
`
`Stamatios Stamoulis (#4606)
`stamoulis@swdelaw.com
`Richard C. Weinblatt (#5080)
`weinblatt@swdelaw.com
`STAMOULIS & WEINBLATT LLC
`Two Fox Point Centre
`6 Denny Road, Suite 307
`Wilmington, DE 19809
`(302) 999-1540
`
`Attorneys for Plaintiff Memory Integrity, LLC
`
`
`
`3
`
`
`
`
`
`7
`
`

`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`MEMORY INTEGRITY, LLC,
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS CO. LTD.;
`SAMSUNG ELECTRONICS AMERICA, LLC;
`AND SAMSUNG TELECOMMUNICATIONS
`AMERICA, LLC,
`
`Defendants.
`
`Civil Action No. 1:13-cv-01808-GMS
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF MEMORY INTEGRITY, LLC’S
`INITIAL IDENTIFICATION OF ASSERTED CLAIMS AND ACCUSED PRODUCTS
`
`Plaintiff Memory Integrity, LLC (“MI” “Memory Integrity” or “Plaintiff”) provides the
`
`following preliminary identification of the asserted claims and accused products to Defendants
`
`Samsung Electronics Co., Ltd.; Samsung Electronics America, LLC; and Samsung
`
`Telecommunications America, LLC (collectively, “Samsung”) in accordance with paragraph
`
`5(b) of this Court’s October 1, 2014 Scheduling Order.
`
`The preliminary identifications contained herein are based upon information reasonably
`
`and currently available to Plaintiff. However, Plaintiff anticipates that discovery and other
`
`pretrial preparation will uncover additional relevant information, which may lead to, for
`
`example, the identification of additional accused products. Plaintiff reserves the right to clarify,
`
`amend, modify, and supplement the information contained in these identifications as information
`
`becomes available through discovery or investigation during this action, and as permitted by the
`
`Federal Rules of Civil Procedure and this Court’s Scheduling Order.
`
`
`
`1
`
`9
`
`

`
`I.
`
`ASSERTED CLAIMS AND ACCUSED PRODUCTS
`
`Plaintiff identifies the following accused products which are alleged to infringe at least
`
`claims 1-3, 8, 11-12, and 14-25 of U.S. Patent No. 7,296,121 (the “’121 Patent” or the “Patent-
`
`in-Suit”):
`
`All Samsung products containing a multi-core, ARM-based processor1 with a snoop
`
`control unit (or similar snoop-filtering unit).
`
`The foregoing includes but is not limited to:
`
` Samsung’s Galaxy Tab 7.0 Plus, Galaxy Tab S 10.5, Galaxy Tab S 8.4, Galaxy
`
`Tab 4 NOOK, Galaxy Tab 3, Samsung Galaxy Tab 3 Lite, Galaxy Tab 3 8.0,
`
`Galaxy Tab 3 7.0 Kids, Galaxy Tab 4 7.0, Galaxy Tab 4 8.0, Galaxy Tab 4 10.1,
`
`Galaxy Note 10.1, Galaxy Note 2, Galaxy Note 3, Galaxy Note Pro 12.2, Galaxy
`
`Tab Pro 8.4, Galaxy Tab Pro 10.1, Galaxy Tab Pro 12.2, Galaxy Note Pro
`
`products;
`
` Samsung’s Galaxy S2, Samsung Galaxy Ace 3, Samsung ATIV S Neo, Samsung
`
`Galaxy Mega 2, Samsung Galaxy Express, Samsung Galaxy Express 2, Samsung
`
`Galaxy Round, Samsung Galaxy S3, Samsung Galaxy S3 Neo, Samsung Galaxy
`
`S4, Samsung Galaxy S4 Mini, Samsung Galaxy S5, products
`
` Samsung’s Chromebook (XE303C12), Samsung Galaxy Gear 2, and Samsung
`
`Galaxy Gear 2 Neo products;
`
` Samsung’s televisions that have a multicore ARM-based processor, such as the
`
`F8000 series;
`
`
`1
`“ARM-based processor” refers to any processor compatible, in whole or in part, with an
`ARM instruction set, regardless of whether the processor itself was designed by ARM.
`2
`
`
`
`10
`
`

`
` Products containing the Samsung Exynos 4 and 5 series processors including the
`
`Exynos 4210, 4212, 4412, 5250, 5410, 5420, 5422, 5260, 5430, 5433, and 5800;
`
` All versions, variations, models, and upgrades of the foregoing; and any products
`
`that are reasonably similar to any of the above-identified products.
`
`II.
`
`FILE HISTORY
`
`The file history of the Patent-in-Suit is being produced with Bates numbers
`
`MI_ALL_000001-000188.
`
`Dated: October 13, 2014
`
`Respectfully submitted,
`
`
`
`/s/ Jonathan D. Baker
`Jonathan D. Baker (pro hac vice)
`FARNEY DANIELS PC
`411 Borel Ave., Suite 350
`San Mateo, CA 94402
`Telephone: (424) 268-5200
`Facsimile: (424) 268-5219
`jbaker@farneydaniels.com
`
`Stamatios Stamoulis (#4606)
`stamoulis@swdelaw.com
`Richard C. Weinblatt (#5080)
`weinblatt@swdelaw.com
`STAMOULIS & WEINBLATT LLC
`Two Fox Point Centre
`6 Denny Road, Suite 307
`Wilmington, DE 19809
`(302) 999-1540
`
`Attorneys for Plaintiff Memory Integrity, LLC
`
`
`
`3
`
`
`
`
`
`11
`
`

`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`MEMORY INTEGRITY, LLC,
`
`Plaintiff,
`
`v.
`
`AMAZON.COM, INC.,
`
`Defendant.
`
`Civil Action No. 1:13-cv-01795-GMS
`
`JURY TRIAL DEMANDED
`
`
`
`PLAINTIFF MEMORY INTEGRITY, LLC’S
`INITIAL IDENTIFICATION OF ASSERTED CLAIMS AND ACCUSED PRODUCTS
`
`Plaintiff Memory Integrity, LLC (“MI” “Memory Integrity” or “Plaintiff”) provides the
`
`following preliminary identification of the asserted claims and accused products to Defendant
`
`Amazon.com, Inc. (“Amazon”) in accordance with paragraph 5(b) of this Court’s October 1,
`
`2014 Scheduling Order.
`
`The preliminary identifications contained herein are based upon information reasonably
`
`and currently available to Plaintiff. However, Plaintiff anticipates that discovery and other
`
`pretrial preparation will uncover additional relevant information, which may lead to, for
`
`example, the identification of additional accused products. Plaintiff reserves the right to clarify,
`
`amend, modify, and supplement the information contained in these identifications as information
`
`becomes available through discovery or investigation during this action, and as permitted by the
`
`Federal Rules of Civil Procedure and this Court’s Scheduling Order.
`
`I.
`
`ASSERTED CLAIMS AND ACCUSED PRODUCTS
`
`Plaintiff identifies the following accused products which are alleged to infringe at least
`
`claims 1-3, 8, 11-12, and 14-25 of U.S. Patent No. 7,296,121 (the “’121 Patent” or the “Patent-
`
`in-Suit”):
`
`
`
`1
`
`13
`
`

`
`All Amazon products containing a multi-core, ARM-based processor1 with a snoop
`
`control unit (or similar snoop-filtering unit).
`
`The foregoing includes but is not limited to:
`
` Amazon’s Kindle Fire, Kindle Fire HD, Kindle Fire HDX, Fire HD, and Fire
`
`HDX products;
`
` Amazon’s Fire Phone products;
`
` Amazon’s Fire TV products;
`
` All versions, variations, models, and upgrades of the foregoing; and any products
`
`that are reasonably similar to any of the above-identified products.
`
`II.
`
`FILE HISTORY
`
`The file history of the Patent-in-Suit is being produced with Bates numbers
`
`MI_ALL_000001-000188.
`
`Dated: October 13, 2014
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`/s/ Jonathan D. Baker
`
`Jonathan D. Baker (pro hac vice)
`FARNEY DANIELS PC
`411 San Borel Ave., Suite 350
`San Mateo, CA 94402
`Telephone: (424) 268-5200
`Facsimile: (424) 268-5219
`jbaker@farneydaniels.com
`
`
`1
`“ARM-based processor” refers to any processor compatible, in whole or in part, with an
`ARM instruction set, regardless of whether the processor itself was designed by ARM.
`2
`
`
`
`14
`
`

`
`Stamatios Stamoulis (#4606)
`Richard C. Weinblatt (#5080)
`Two Fox Point Centre
`6 Denny Road, Suite 307
`Wilmington, DE 19809
`(302) 999-1540
`stamoulis@swdelaw.com
`weinblatt@swdelaw.com
`
`Attorneys for Plaintiff Memory Integrity, LLC
`
`
`
`3
`
`
`
`
`
`15
`
`

`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on October 13, 2014, I caused a copy of this document to be served
`
`by transmitting it via e-mail or electronic transmission to counsel of record for Defendant.
`
`
`
`
`
`/s/ Jonathan Baker
`Jonathan Baker
`
`
`
`4
`
`16

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