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`SMART EXHIBIT 1015
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`l\)
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`D.)
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`KC00\IO\U1
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`UNITED STATES DISTRICT COURT
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`FOR THE SOUTHERN DISTRICT OF TEXAS
`HOUSTON DIVISION
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`
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`JAMES B. GOODMAN,
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`Civil Action No. 4:14-CV—01380 GHM
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`Plaintiff,
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`vs.
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`SMART MODULAR TECHNOLOGIES INC.
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`Before US. District Court Judge
`GRAY H. MILLER
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`Defendant.
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`JURY TRIAL DEMANDED
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`_..J
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`DISCLOSURE OF ASSERTED CLAIMS AND
`PRELIMINARY INFRINGEMENT CONTENTIONS
`IN ACCORDANCE ‘WITH P.R. 3-2 AND
`DOCUMENT PRODUCTION UNDER P. R. 3-2
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`The following is Plaintiffs Disclosure of Asserted Claims and Preliminary Contentions
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`in accordance with P.R. 3-2:
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`(3)
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`Only Claim 1 of the patent—in-suit is being asserted at this time; however, Plaintiff
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`reserves the right to asserted additional claims.
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`(b)
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`Claim 1 of the patent—in-suit is infringed by at least the products identified by the
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`Defendant as DDR2, DDR3, and DDR4.
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`(0)
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`A chart showing the relationship between Claim l of the patent—in—suit and the
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`infringing products identified above in item (b) is on disk A accompanying this
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`document.
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`(Cl)
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`Based on the technical information available, the identified products infringe
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`under the doctrine of equivalents with respect to having at least two memory
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`devices by exhibiting at least two banks of memory.
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`(6)
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`No priority to an earlier application or priority date is being asserted.
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`James B. Goodman v. Smart Modular Technologies Inc.
`Case No. 14-CV-1380
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`Page 1
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`SMART EXHIBIT 1015 - PA E-1
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`SMART EXHIBIT 1015 - PAGE - 1
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`bx)
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`Lo)
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`(i)
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`Item P.R. 3-2 (f) does not apply.
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`The following is the Document Production under P.R. 3-2:
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`(1)
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`(2)
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`(3)
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`There are no documents pursuant to PR. 3-2 (a)(l).
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`There are no documents pursuant to PR. 3-2 (a)(2).
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`The file history of the patent—in-suit is provided on the disk A accompanying this
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`document.
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`(4)
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`Copies of license agreements for the patent-in—suit are provided on the disk A
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`accompanying this document
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`Respectfully submitted,
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`/s/ David Fink
`David Fink
`Fink & Johnson
`7519 Apache Plume
`Houston, TX 77071
`Admission No. 299869
`Tel. 713 729-4991
`Fax: 713 729-4951
`Email:
`te_xascowboy6@gmail.com
`Attorney in Charge for the Plaintiff
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`l6
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`Enclosure: Disk A
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`James B. Goodman v. Smart Modular Technologies Inc.
`Case No. 14-CV-I380
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`Page 2
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`SMART EXHIBIT 1015 - PA E-2
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`SMART EXHIBIT 1015 - PAGE - 2
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`
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and correct copy of the foregoing Notice has been sent by
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`prepaid First Class U.S. Mail on October 22, 2014 to the attorney for the Defendant at the
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`following address:
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`Anup M. Shah
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`Kin & Spalding
`100
`orth Tr on Street, Suite 3900
`Charlotte, N 28202
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`/s/ David Fink
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`_
`David Fink
`Attorney in Charge for the Plaintiff
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`James B. Goodman v. Smart Modular Technologies Inc.
`Case No. 14-CV«]380
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`Page 3
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`SMART EXHIBIT 1015 - PA E-3
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`SMART EXHIBIT 1015 - PAGE - 3