`FOR THE NORTHERN DISTRICT OF ILLINOIS
`
`
`
`LYNK LABS, INC.’S INITIAL INFRINGEMENT CONTENTIONS PURSUANT
`TO LOCAL PATENT RULE 2.2
`
`Plaintiff Lynk Labs, Inc. (“Lynk Labs”) hereby provides, pursuant to LPR 2.2, the
`
`following Initial Infringement Contentions. Lynk Labs contends that each of identified claims is
`
`infringed by Juno Lighting, LLC and Juno Manufacturing, Inc. (collectively “Juno”). The
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`following contentions are based on knowledge and information in Lynk Labs’ possession,
`
`custody and control after a reasonable investigation of publicly available sources and the limited
`
`number of documents that Juno produced pursuant to Local Patent Rule 2.1. The accused Juno
`
`products implement some of the infringing functionality in whole or in part using circuitry and
`
`components that are neither publicly available nor described in Lynk’s production to date.
`
`Therefore, Lynk Labs reserves the right to revise, amend and supplement these contentions as
`
`discovery progresses and new information becomes available.
`
`A. Identification of Infringed Claims and Applicable Statutory Section of 35
`U.S.C. § 271
`
`
`
`
`
`
`
`
`
`)
`
`)
`
`)
`Civil Action No.: 15-cv-04833
`)
`
`)
`) Hon. Virginia M. Kendall
`)
`
`JURY TRIAL DEMANDED
`)
`)
`)
`)
`)
`
`
`
`
`
`
`
`
`LYNK LABS, INC.
`
`
`
`v.
`
`JUNO LIGHTING, LLC, and
`JUNO MANUFACTURING, INC.
`
`
`
`
`
`
`
`
`
`
`
`
`Plaintiff,
`
`Defendants.
`
`IPR PAGE 1
`
`Acuity v. Lynk
`Acuity Ex.
`
`1021
`
`
`
`Claims 1-5 of U.S. Patent No. 8,531,118 (“the ’118 patent”) are infringed under 35
`
`U.S.C. § 271(a), (b), (c), and (f). Claims 1-5 of U.S. Patent No. 8,841,855 (“the ’855 patent”)
`
`are infringed under 35 U.S.C. § 271(a).
`
`B. Identification of Accused Instrumentalities By Claim1
`
`As set forth in the accompanying claim chart, the following Juno products are accused of
`
`infringing the ’118 patent (“’118 Accused Products”):
`
`Claim 1:
`
`• Trac 12 and 12/25 lighting systems driven by AC electronic transformers
`
`incorporating one or more of the following LED fixtures: Color LED Linear Module;
`
`LED Mini Flood; Low Power LED Module Series; WarmDim LED Linear Lighting
`
`Modules; QJ LED Mini Cylinder Display/Picture Horizontal; QJ LED Mini Cylinder
`
`Display/Picture Vertical; Quick Jack LED Spot Light – Reno Series; Quick Jack LED
`
`Spot Light – Vegas Series; Cylindra 13W LED Spotlight Series; LED Mini-Cylindra
`
`Spotlight Gen 2; TL261L Conix II; Dolce Series Pendants; Medium Dome Series
`
`Pendants; Tear Drop Glass Series Pendants; Charlotte Series Pendants; Fargo Glass
`
`Series Pendants; Long Cone Glass Series Pendants; Medium Cylinder Series
`
`Pendants; Onyx Series Pendants; Tube Glass Series Pendants; Cylinder Glass Shade
`
`Pendants; Quick Jack 6W LED Cylinder MiniPendant Series; Cylinder LED
`
`MiniPendant Series; Flute LED MiniPendant Series; LED Pendant Cordset Series;
`
`and Quick Jack LED Pendant Cordset Series.
`
`
`1 Juno’s production to date does not sufficiently describe the Juno products accused of
`infringement, and accordingly does not comply with LPR 2.1. Lynk reserves the right to
`supplement and identify additional infringing features and products once Juno complies with its
`discovery obligations and the Local Rules (e.g., LPR 2.3).
`
`
`
`
`2
`
`
`
`IPR PAGE 2
`
`
`
`• Flex 12 lighting systems driven by AC electronic transformers incorporating one or
`
`more of the following LED fixtures: Cylindra LED; MR11 LED Spotlight; Quick
`
`Jack LED Spot Light Reno Series; Quick Jack LED Spot Light Vegas Series; TF261L
`
`Conix II LED; Dolce Series Pendant; Medium Dome Series Pendant; Tear Drop
`
`Glass Series Pendant; Charlotte Series Pendant; Fargo Glass Series Pendant; Long
`
`Cone Glass Series Pendant; Medium Cylinder Series Pendant; Onyx Series Pendant;
`
`Tube Glass Series Pendant; Cylinder Glass Shade Pendant; Quick Jack 6W LED
`
`Cylinder MiniPendant Series; Cylinder LED Mini-Pendant Series; Flute LED Mini-
`
`Pendant Series; Flute Glass Shade Short Cone Metal; LED Pendant Cordset Series;
`
`Quick Jack LED Pendant Corsdset; LED Mini Pendant Cylinder Series; and LED
`
`Mini Pendant Flute Series.
`
`• Solo-Task lighting systems driven by AC electronic transformers incorporating one or
`
`more Solo-Task LED Luminaries.
`
`• Downlighting lighting systems driven by AC electronic transformers incorporating
`
`one or more Mini LED Downlights or Gimbals.
`
`• Any Trac-Master 120V One Circuit, Trac-Master 120V Two Circuit, Trac-Master
`
`120V Tube, Trac-Master 120V Recessed, or Trac-Lites One Circuit lighting system
`
`incorporating one or more of the following LED fixtures driven by an AC electronic
`
`transformer: o
`
`Dolce Series Pendant; Medium Dome Series Pendant; Tear Drop
`
`Glass Series Pendant; Charlotte Series Pendant; Fargo Glass Series Pendant; Long
`
`Cone Glass Series Pendant; Medium Cylinder Series Pendant; Onyx Series Pendant;
`
`Tube Glass Series Pendant; and Cylinder Glass Shade Pendant; Quick Jack LED
`
`Cylinder MiniPendant Series; and Quick Jack LED Flute MiniPendant Series.
`
`
`
`
`3
`
`
`
`IPR PAGE 3
`
`
`
`Claim 2:
`
`• Trac 12 and 12/25 lighting systems driven by AC electronic transformers
`
`incorporating one or more of the following LED fixtures: Color LED Linear Module;
`
`LED Mini Flood; Low Power LED Module Series; WarmDim LED Linear Lighting
`
`Modules; QJ LED Mini Cylinder Display/Picture Horizontal; QJ LED Mini Cylinder
`
`Display/Picture Vertical; Quick Jack LED Spot Light – Reno Series; Quick Jack LED
`
`Spot Light – Vegas Series; Cylindra 13W LED Spotlight Series; LED Mini-Cylindra
`
`Spotlight Gen 2; TL261L Conix II; Dolce Series Pendants; Medium Dome Series
`
`Pendants; Tear Drop Glass Series Pendants; Charlotte Series Pendants; Fargo Glass
`
`Series Pendants; Long Cone Glass Series Pendants; Medium Cylinder Series
`
`Pendants; Onyx Series Pendants; Tube Glass Series Pendants; Cylinder Glass Shade
`
`Pendants; Quick Jack 6W LED Cylinder MiniPendant Series; Cylinder LED
`
`MiniPendant Series; Flute LED MiniPendant Series; LED Pendant Cordset Series;
`
`and Quick Jack LED Pendant Cordset Series.
`
`• Flex 12 lighting systems driven by AC electronic transformers incorporating one or
`
`more of the following LED fixtures: Cylindra LED; MR11 LED Spotlight; Quick
`
`Jack LED Spot Light Reno Series; Quick Jack LED Spot Light Vegas Series; TF261L
`
`Conix II LED; Dolce Series Pendant; Medium Dome Series Pendant; Tear Drop
`
`Glass Series Pendant; Charlotte Series Pendant; Fargo Glass Series Pendant; Long
`
`Cone Glass Series Pendant; Medium Cylinder Series Pendant; Onyx Series Pendant;
`
`Tube Glass Series Pendant; Cylinder Glass Shade Pendant; Quick Jack 6W LED
`
`Cylinder MiniPendant Series; Cylinder LED Mini-Pendant Series; Flute LED Mini-
`
`Pendant Series; Flute Glass Shade Short Cone Metal; LED Pendant Cordset Series;
`
`
`
`
`4
`
`
`
`IPR PAGE 4
`
`
`
`Quick Jack LED Pendant Corsdset; LED Mini Pendant Cylinder Series; and LED
`
`Mini Pendant Flute Series.
`
`• Solo-Task lighting systems driven by AC electronic transformers incorporating one or
`
`more Solo-Task LED Luminaries.
`
`• Downlighting lighting systems driven by AC electronic transformers incorporating
`
`one or more Mini LED Downlights or Gimbals.
`
`• Any Trac-Master 120V One Circuit, Trac-Master 120V Two Circuit, Trac-Master
`
`120V Tube, Trac-Master 120V Recessed, or Trac-Lites One Circuit lighting system
`
`incorporating one or more of the following LED fixtures driven by an AC electronic
`
`transformer: o
`
`Dolce Series Pendant; Medium Dome Series Pendant; Tear Drop
`
`Glass Series Pendant; Charlotte Series Pendant; Fargo Glass Series Pendant; Long
`
`Cone Glass Series Pendant; Medium Cylinder Series Pendant; Onyx Series Pendant;
`
`Tube Glass Series Pendant; and Cylinder Glass Shade Pendant; Quick Jack LED
`
`Cylinder MiniPendant Series; and Quick Jack LED Flute MiniPendant Series.
`
`Claim 3:
`
`• Trac 12 and 12/25 lighting systems driven by AC electronic transformers
`
`incorporating one or more of the following LED fixtures: Color LED Linear Module;
`
`LED Mini Flood; Low Power LED Module Series; WarmDim LED Linear Lighting
`
`Modules; QJ LED Mini Cylinder Display/Picture Horizontal; QJ LED Mini Cylinder
`
`Display/Picture Vertical; Quick Jack LED Spot Light – Reno Series; Quick Jack LED
`
`Spot Light – Vegas Series; Cylindra 13W LED Spotlight Series; LED Mini-Cylindra
`
`Spotlight Gen 2; TL261L Conix II; Dolce Series Pendants; Medium Dome Series
`
`Pendants; Tear Drop Glass Series Pendants; Charlotte Series Pendants; Fargo Glass
`
`
`
`
`5
`
`
`
`IPR PAGE 5
`
`
`
`Series Pendants; Long Cone Glass Series Pendants; Medium Cylinder Series
`
`Pendants; Onyx Series Pendants; Tube Glass Series Pendants; Cylinder Glass Shade
`
`Pendants; Quick Jack 6W LED Cylinder MiniPendant Series; Cylinder LED
`
`MiniPendant Series; Flute LED MiniPendant Series; LED Pendant Cordset Series;
`
`and Quick Jack LED Pendant Cordset Series.
`
`• Flex 12 lighting systems driven by AC electronic transformers incorporating one or
`
`more of the following LED fixtures: Cylindra LED; MR11 LED Spotlight; Quick
`
`Jack LED Spot Light Reno Series; Quick Jack LED Spot Light Vegas Series; TF261L
`
`Conix II LED; Dolce Series Pendant; Medium Dome Series Pendant; Tear Drop
`
`Glass Series Pendant; Charlotte Series Pendant; Fargo Glass Series Pendant; Long
`
`Cone Glass Series Pendant; Medium Cylinder Series Pendant; Onyx Series Pendant;
`
`Tube Glass Series Pendant; Cylinder Glass Shade Pendant; Quick Jack 6W LED
`
`Cylinder MiniPendant Series; Cylinder LED Mini-Pendant Series; Flute LED Mini-
`
`Pendant Series; Flute Glass Shade Short Cone Metal; LED Pendant Cordset Series;
`
`Quick Jack LED Pendant Corsdset; LED Mini Pendant Cylinder Series; and LED
`
`Mini Pendant Flute Series.
`
`• Solo-Task lighting systems driven by AC electronic transformers incorporating one or
`
`more Solo-Task LED Luminaries.
`
`• Downlighting lighting systems driven by AC electronic transformers incorporating
`
`one or more Mini LED Downlights or Gimbals.
`
`• Any Trac-Master 120V One Circuit, Trac-Master 120V Two Circuit, Trac-Master
`
`120V Tube, Trac-Master 120V Recessed, or Trac-Lites One Circuit lighting system
`
`incorporating one or more of the following LED fixtures driven by an AC electronic
`
`
`
`
`6
`
`
`
`IPR PAGE 6
`
`
`
`transformer: Dolce Series Pendant; Medium Dome Series Pendant; Tear Drop Glass
`
`Series Pendant; Charlotte Series Pendant; Fargo Glass Series Pendant; Long Cone
`
`Glass Series Pendant; Medium Cylinder Series Pendant; Onyx Series Pendant; Tube
`
`Glass Series Pendant; and Cylinder Glass Shade Pendant; Quick Jack LED Cylinder
`
`MiniPendant Series; and Quick Jack LED Flute MiniPendant Series.
`
`Claim 4:
`
`• As identified above, upon information and belief, certain of the ’118 Accused
`
`Products infringe dependent claim 3. In the alternative, to the extent that there are
`
`differences in the packaging of certain Juno products (information which should have
`
`been included in Juno’s LPR 2.1 production among other deficiencies), the products
`
`identified above as infringing claim 3 of the ’118 Patent would at least meet
`
`dependent claim 4. Lynk reserves the right to supplement its contentions for claim 4
`
`once Juno complies with its discovery obligations and the Local Patent Rules.
`
`Claim 5:
`
`• Upon information and belief, Juno makes, uses, sells, offers for sale, imports and
`
`exports products meeting limitation 5B. For reasons identified in connection with
`
`dependent claim 4, Juno’s production pursuant to LPR 2.1 is inadequate, and does not
`
`at this time include sufficient detail to confirm Lynk’s belief. Lynk reserves the right
`
`to supplement its contentions for claim 5 once Juno complies with its discovery
`
`obligations and the Local Patent Rules.
`
`As set forth in the accompanying claim chart, the following Juno products are accused of
`
`infringing the ’855 patent (“’855 Accused Products”):
`
`Claim 1:
`
`
`
`
`7
`
`
`
`IPR PAGE 7
`
`
`
`• Trac 12 LED Mini-Flood, Trac 12 LED Modules (TL201 and TL2142) and Art Glass
`
`Pendants (including without limitation Dolce Series Pendants, Medium Dome Series
`
`Pendants, Charlotte Series Pendants, Fargo Glass Series Pendants, Long Cone Glass
`
`Series Pendants, Medium Cylinder Series Pendants, Onyx Series Pendants, Tube Glass
`
`Series Pendants and Cylinder Glass Shade Pendants)
`
`Claim 2:
`
`• Trac 12 LED Mini-Flood
`
`Claim 3:
`
`• Trac 12 LED Mini-Flood
`
`Claim 4:
`
`• Trac 12 LED Mini-Flood and Trac 12 LED Modules (TL201 and TL214) and Art Glass
`
`Pendants (including without limitation Dolce Series Pendants, Medium Dome Series
`
`Pendants, Charlotte Series Pendants, Fargo Glass Series Pendants, Long Cone Glass
`
`Series Pendants, Medium Cylinder Series Pendants, Onyx Series Pendants, Tube Glass
`
`Series Pendants and Cylinder Glass Shade Pendants)
`
`Claim 5:
`
`• Trac 12 LED Mini-Flood and Trac 12 LED Modules (TL201 and TL214) and Art Glass
`
`Pendants (including without limitation Dolce Series Pendants, Medium Dome Series
`
`Pendants, Charlotte Series Pendants, Fargo Glass Series Pendants, Long Cone Glass
`
`
`2 Lynk Labs has identified accused product families by Juno catalog number prefixes in certain
`cases where multiple different products appear to be named similarly. The listing of Juno
`catalog numbers herein does not limit Lynk Labs’ infringement allegations in any way, and are
`intended solely to assist Juno in identifying those products that infringe the patents in suit.
`
`
`
`
`8
`
`
`
`IPR PAGE 8
`
`
`
`Series Pendants, Medium Cylinder Series Pendants, Onyx Series Pendants, Tube Glass
`
`Series Pendants and Cylinder Glass Shade Pendants)
`
`C. Claim Chart Comparing Each Element of the Asserted Claims to the
`Accused Instrumentalities
`
`Charts identifying where each element of each asserted claim is found within each
`
`accused product is attached hereto as Appendix A and Appendix B.
`
`D. Identification of Whether Each Element of Each Asserted Claim is Present in
`the Accused Instrumentalities Literally or Under the Doctrine of Equivalents
`
`At this time, Lynk Labs asserts that all of the asserted claim elements are literally present
`
`in the Juno accused products. Lynk Labs reserves the right to assert a doctrine of equivalents
`
`theory in response to, for example, claim construction positions advanced by Juno.
`
`E. Description of Indirect Infringement Claims
`
`In addition to directly infringing all claims of the ’118 patent, Juno also infringes all
`
`claims of the ’118 patent under 35 U.S.C. § 271(b) by actively inducing others to directly
`
`infringe the ’118 patent. Juno is liable under 35 U.S.C. § 271(b) because it induces retailers,
`
`electrical distributors, contractors and end consumers to sell, offer for sale and use the ’118
`
`Accused Products as described in the accompanying claim charts.
`
`For example, Juno induces its third party retailers to use, sell and/or offer for sale all
`
`components of the ’118 Accused Products. On information and belief, third party retailers of
`
`Juno products include, for example, Home Depot and Lowe’s. Third party retailers directly
`
`infringe the ’118 patent by using all the components of the ’118 Accused Products as instructed
`
`by Juno (see, e.g., J00000719-734 (Juno literature describing and offering for sale product
`
`displays and sales aids)) in their stores. Third party retailers also directly infringe the ‘118 patent
`
`by selling and offering for sale all components of the ’118 Accused Products using Juno’s
`
`marketing materials, specifications and instructions (see, e.g., J00000832, -921, -1019, -1021
`
`
`
`
`9
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`
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`IPR PAGE 9
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`
`
`(describing compatibility between AC electronic transformer and other components of infringing
`
`systems)).
`
`As an additional example, Juno induces electrical distributors, contractors and other third
`
`parties to use, sell and/or offer for sale the ’118 Accused Products as complete lighting systems
`
`as described in the accompanying claim chart. Juno provides marketing materials, specifications
`
`and instructions that explain how various components of the ’118 Accused Products should be
`
`combined to form an infringing lighting system (see, e.g., J00000832, -921, -1019, -1021
`
`(describing compatibility between AC electronic transformer and other components of infringing
`
`systems)), and Juno instructs electrical distributors, contractors and other third parties to use this
`
`information to sell complete lighting systems. Electrical distributors and contractors also
`
`infringe the ’118 patent by using infringing lighting systems by, for example, installing and
`
`testing such systems.
`
`As an additional example, Juno induces end users of the ’118 Accused Products, such as
`
`consumers, to use those products as described in the accompanying claim chart. Juno provides
`
`marketing materials, specifications and instructions that explain how various components of the
`
`’118 Accused Products should be combined to form an infringing lighting system, and Juno
`
`intends that its end users will install lighting systems as described in the accompanying claim
`
`chart. Moreover, Juno also advises end users that components of the ’118 Accused Products can
`
`be purchased from entities other than Juno, including, for example, third-party AC electronic
`
`drivers (see, e.g., ’118 Chart Page 19 (Juno lighting fixture, as sold by Juno, incorporating Hatch
`
`transformer)), LED bulbs (see, e.g., J00000412 (describing lampholders “compatibl[e] with most
`
`MR16 LED lamps (by others)”), and dimmers (see, e.g., J00000823-25 (third-party dimmer
`
`specification). Juno also contracts with and encourages third party suppliers, such as Hatch,
`
`
`
`
`10
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`
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`IPR PAGE 10
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`
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`Norlux, and Citizen, to produce and sell components of the ’118 Accused Products and advise
`
`end users as to how those components may be combined as described in the accompanying claim
`
`chart.
`
`Upon information and belief, Juno formed a specific intent to infringe the ’118 Patent on
`
`or near the issuance of the ‘118 Patent. Juno formed a specific intent to infringe the ‘118 Patent
`
`at least when it, for example, agreed to indemnify its third party OEM’s such as Hatch against
`
`infringement claims brought by Lynk Labs and, in all events, no later than the February 28,
`
`2014, patent portfolio offering to Juno described below. See § G, infra.
`
`Juno also infringes the ’118 patent under 35 U.S.C. § 271(c) by offering to sell and/or
`
`selling material components of the ’118 Accused Products (the components identified in the
`
`accompanying claim chart), each of which is especially made by Juno for use in the infringing
`
`manner described in the accompanying claim chart. For example, Juno sells material
`
`components of the ’118 Accused Products to electrical distributors, contractors and retailers with
`
`the understanding and intention that such components will combined by end users as described in
`
`the accompanying claim chart. Furthermore, the components of the ’118 Accused Products
`
`offered for sale and/or sold by Juno are not staples, articles, or commodities of commerce
`
`suitable for substantial noninfringing use.
`
`Lynk Labs has provided a description of Juno’s indirect infringement based on
`
`information available to it at this early stage of the case. Lynk Labs reserves the right to amend
`
`these contentions as additional information regarding Juno’s indirect infringement and third
`
`parties’ direct infringement becomes available to it throughout the course of discovery in this
`
`case.
`
`
`
`
`F. Priority Date To Which Each Asserted Claim Is Entitled
`
`11
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`
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`IPR PAGE 11
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`
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`Lynk Labs asserts that each claim of the ’118 patent is entitled to a priority date of
`
`February 25, 2004. Lynk Labs asserts that each claim of the ’855 patent is entitled to a priority
`
`date of October 7, 2007.
`
`G. Basis for Allegation of Willful Infringement
`
`Juno has willfully infringed and continues to willfully infringe the ’118 patent because it
`
`either knew or should have known that there was an objectively high risk of infringement by
`
`making, using, offering to sell, and/or selling the Juno accused products enumerated herein in the
`
`United States. In approximately April 2008, Lynk Labs gave notice to Juno of its pending patent
`
`applications by email. An April 21, 2008 email from David Early, then Juno’s LED Program
`
`Manager, to Lynk Labs and other Juno employees confirms Juno’s knowledge of Lynk Labs’
`
`patent applications, stating that “Lynk has patent applications on the technology.” See ECF No.
`
`1 at Ex. D. Indeed, later that same year, Juno demanded an exclusive license to Lynk Labs’ AC-
`
`driven LED technology, further confirming Juno’s understanding that at least some of its LED
`
`lighting products required a license to Lynk Labs’ patents.
`
`Juno was again notified of Lynk Labs’ patent portfolio when Lynk Labs announced that
`
`its U.S. Patent No. 7,489,086, which is in the same patent family as the ’118 patent, had issued in
`
`LEDs Magazine. On February 10, 2009, Lynk Labs emailed the announcement in LED
`
`Magazine to Juno, and Juno’s then Vice President of Product Management responded via email,
`
`congratulating Lynk Labs and noting he would “be reading it over to see all of the details.” See
`
`ECF No. 1 at Ex. K.
`
`Lynk Labs gave further notice to Juno of its patents and patent applications in an email
`
`dated May 21, 2009, noting that “Lynk Labs has approved and pending, published and non-
`
`published IP and has shared some of this technology and know-how with Juno Lighting group
`
`
`
`
`12
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`
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`IPR PAGE 12
`
`
`
`under [the parties’ Mutual Nondisclosure Agreement],” and requesting a meeting with Juno “to
`
`review Lynk Labs patent position.” See ECF No. 1 at Ex. G. Juno refused Lynk Labs’ request
`
`for a meeting to discuss Lynk Labs’ patents.
`
`Juno received notice of the ’118 patent yet again in December 2013, when Lynk Labs
`
`announced the issuance of the ’118 patent in Solid State Technology magazine. Lynk Labs’
`
`announcement informed readers that the ’118 patent encompasses “vertical market segments of
`
`AC LED technology from the core AC LED circuits and powering methods to the lighting
`
`system level.” On information and belief, Juno employees read Lynk Labs’ announcement in
`
`Solid State Technology magazine.
`
`Finally, Juno received notice of the ’118 patent on February 28, 2014, when John
`
`Mabbott, then and current President and CEO of Juno, received an email regarding Lynk Labs’
`
`patent portfolio that was for sale. The email included details of Lynk Labs’ patent portfolio,
`
`including a listing of the ’118 patent and the pending application for the ‘855 patent. Moreover,
`
`the memorandum offered analysis of representative claims of the ’118 Patent, and specifically
`
`identified LED lighting products and systems, many of which were and are made and sold by
`
`Juno, as infringing the ’118 Patent. Mr. Mabbott later responded via telephone that Juno was not
`
`interested in acquiring Lynk Labs’ patent portfolio.
`
`H. Lynk Labs’ Products That Practice the Claimed Inventions
`
`Lynk Labs hereby
`
`identifies
`
`the following apparatus, products, devices and
`
`instrumentalities as practicing the claimed inventions:
`
`’118 patent – BriteDriver with SnapBrite or Tesla product lines
`
`’855 patent – Certain SnapBrite products
`
`
`
`
`13
`
`
`
`IPR PAGE 13
`
`
`
`Lynk Labs marked its products with “Patent Pending” before the ’118 and ’855 patents
`
`issued. Lynk Labs also provided notice of its patents, including the ’118 and ’855 patents,
`
`through
`
`its
`
`website,
`
`including,
`
`for
`
`example,
`
`at
`
`the
`
`web
`
`address
`
`http://www.lynklabs.com/media/Patent%20Number%20List%202015v2.pdf.
`
`
`
`Dated: September 24, 2015
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/ James A. Shimota
`James A. Shimota
`
`James A. Shimota (IL Bar No. 6270603)
`Aaron C. Taggart (IL Bar No. 6302068)
`Braden J. Tilghman (IL Bar No. 6314143)
`HAYNES AND BOONE, LLP
`180 North LaSalle Street, Suite 2215
`Chicago, Illinois 60601
`Telephone: 312-216-1620
`Facsimile: 312-216-1621
`jim.shimota@haynesboone.com
`aaron.taggart@haynesboone.com
`braden.tilghman@haynesboone.com
`
`Counsel for Plaintiff Lynk Labs, Inc.
`
`14
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`
`
`IPR PAGE 14
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned hereby certifies that a true and correct copy of the above and foregoing
`
`document has been served on September 24, 2015, by electronic mail to:
`
`
`Benjamin J. Bradford
`Lisa M. Schoedel
`JENNER & BLOCK LLP
`353 N. Clark St.
`Chicago, Illinois 60654
`bbradford@jenner.com
`lschoedel@jenner.com
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`Counsel for Defendants
`Juno Lighting, LLC and Juno Manufacturing, Inc.
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`/s/ James Rally
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`IPR PAGE 15
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