IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`IRONBURG INVENTIONS LTD. a
`United Kingdom Limited Company,
`
`Plaintiff,
`
`vs.
`
`COLLECTIVE MINDS GAMING
`CO. LTD.,
`
`Defendant.
`
`Civil Action No. 1:16-cv-04110-TWT
`
`PLAINTIFF IRONBURG INVENTIONS LTD PRELIMINARY
`INFRINGEMENT CONTENTIONS AGAINST DEFENDANT
`COLLECTIVE MINDS GAMING CO., LTD.
`
`IPR2018-00354
`COLLECTIVE EX1017 Page 1
`
`
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`IRONBURG INVENTIONS LTD. a
`United Kingdom Limited Company,
`
`Plaintiff,
`
`vs.
`
`COLLECTIVE MINDS GAMING
`CO. LTD.,
`
`Defendant.
`
`Civil Action No. 1:16-cv-04110-TWT
`
`PLAINTIFF IRONBURG INVENTIONS LTD PRELIMINARY
`INFRINGEMENT CONTENTIONS AGAINST DEFENDANT
`COLLECTIVE MINDS GAMING CO., LTD.
`
`IPR2018-00354
`COLLECTIVE EX1017 Page 1
`
`
`
`Pursuant to Scheduling Order (D.I. 28) and L.P.R. 4.1 and 4.4(a) Plaintiff
`
`Ironburg Inventions Ltd. (“Ironburg” or “Plaintiff”), by and through its counsel,
`
`hereby submits the following Preliminary and Exemplary Infringement
`
`Contentions against Defendant Collective Minds Gaming Co. LTD (“Collective
`
`Minds” or “Defendant”).
`
`Plaintiff reserves the right to supplement these Infringement Contentions,
`
`including the list of accused products, based upon further discovery. Further,
`
`Plaintiff may amend or supplement any of these disclosures and contentions in
`
`view of any claim construction ruling(s) by the Court or any position taken by
`
`Collective Minds in this action. Plaintiff therefore expressly reserves the right to
`
`amend or to supplement its identification of asserted claims and accused devices,
`
`as well as its claim charts, based on further investigation and discovery.
`
`(1) Each claim of each patent in suit that is allegedly infringed by each
`
`party.
`
`The following table sets forth the claims alleged to be infringed by
`
`Collective Minds. Each patent is alleged to be infringed under 35 U.S.C. § 271(a)
`
`and (b):
`
`Patent
`
`Asserted Claims
`
`U.S. Patent No. 8,641,525
`
`1-11, 13-20
`
`U.S. Patent No. 9,089,770
`
`1-20
`
`
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`-1-
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`IPR2018-00354
`COLLECTIVE EX1017 Page 2
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`
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`U.S. Patent No. 9,289,688
`
`1, 9-10, 18-19, 21-24, 26, 28-30
`
`U.S. Patent No. 9,352,229
`
`1-2, 9-10, 15-18, 21-24
`
`U.S. Patent No. 9,308,450
`
`1, 10-15, 20
`
`
`Plaintiff asserts that all elements of all claims listed above are literally
`
`present and also by equivalents.
`
`(2) Each accused apparatus, method, composition or other instrumentality
`(“Accused Device”) corresponding to each claim
`
`Each of the asserted claims in the table of section (1), above, is being
`
`asserted against the products, namely Collective Minds Strike Pack controller,
`
`Strike Pack, Strike Pack F.P.S. Dominator and Trigger Grips.
`
`Charts identifying specifically where each element of each asserted claim is
`
`found within each Accused Device, including for each element that such party
`
`contends is governed by 35 U.S.C. § 112(6), the identity of the structure(s), act(s),
`
`or material(s) in the Accused Device that performs the claimed function, and
`
`whether each element of each asserted claim is to be literally present, present under
`
`the doctrine of equivalents, or both, in the Accused Device, are attached hereto as
`
`follows:
`
` U.S. Patent No. 8,641,525 – Appendix A
`
` U.S. Patent No. 9,089,770 – Appendix B
`
` U.S. Patent No. 9,289,688 – Appendix C
`
`
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`-2-
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`IPR2018-00354
`COLLECTIVE EX1017 Page 3
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` U.S. Patent No. 9,352,229 – Appendix D
`
` U.S. Patent No. 9,308,450 – Appendix E
`
`(3) Priority dates of patents claiming priority to an earlier application
`
`U.S. Patent No. 9,089,770 claims priority to U.S. Patent No. 8,641,525,
`
`which has a filing date of June 17, 2011. Claims 1-20 of U.S. Patent No.
`
`9,089,770 have a priority date of June 17, 2011.
`
`U.S. Patent No. 9,289,688 claims priority to International Application No.
`
`PCT/EP2015/058096, which claims priority to Provisional Application No.
`
`61/979,124. Provisional Application No. 61/979,124 was filed on April 14, 2014.
`
`Claims 1-30 of U.S. Patent No. 9,289,688 have a priority date of April 14, 2014.
`
`There are no foreign applications that also claim priority to International
`
`Application No. PCT/EP2015/058096.
`
`U.S. Patent No. 9,352,229 claims priority to International Application No.
`
`PCT/EP2014/060587, which claims priority to Provisional Application No.
`
`61/882,171 and Provisional Application No. 61/826087. Provisional Application
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`No. 61/882,171 was filed on September 25, 2013. Provisional Application No.
`
`61/826,087 was filed on May 22, 2013. Claims 1-24 of U.S. Patent No. 9,352,229
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`have a priority date of May 22, 2013. The following foreign applications claim
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`priority to International Application No. PCT/EP2014/060587: CA2913093 (A1),
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`CN105492090 (A), and EP2888017 (A1).
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`
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`-3-
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`IPR2018-00354
`COLLECTIVE EX1017 Page 4
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`U.S. Patent No. 9,308,450 claims priority to U.S. Patent No. 8,480,491,
`
`which has a filing date of June 17, 2011. Claims 1-20 of U.S. Patent No.
`
`9,308,450 have a priority date of June 17, 2011.
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`(4) Production or availability of documents
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`Other than the documents produced concurrently with these Preliminary
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`Infringement Contentions, documents will be made available at counsel’s office at
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`a mutually convenient time or produced after the parties agree on a protocol for the
`
`production of documents (or the court enters an order if the parties do not agree).
`
`
`
` Dated: June 8, 2017
`
`
`
`
`
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`Respectfully submitted,
`
`By: /s/ Robert D. Becker
`Robert D. Becker, pro hac vice
`CA Bar No. 160648
`MANATT, PHELPS & PHILLIPS, LLP
`1841 Page Mill Road, Suite 200
`Palo Alto, CA 94304
`Telephone: (650) 812-1300
`Facsimile: (650) 213-0260
`
`Cynthia R. Parks, local counsel
`GA Bar No. 563929
`PARKS IP LAW LLC
`75 Ponce de Leon Avenue, NE, Suite 102
`Atlanta, GA 30308
`Telephone: (678) 365-4444
`Facsimile: (678) 365-4450
`
`Attorneys for Plaintiff
`IRONBURG INVENTIONS LTD.
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`-4-
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`IPR2018-00354
`COLLECTIVE EX1017 Page 5
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`CERTIFICATE OF SERVICE
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` The undersigned counsel hereby certifies that on June 8, 2017, a true and
`
`
`
`correct copy of the Plaintiff Ironburg Inventions LTD Preliminary Infringement
`
`Contentions Against Defendant Collective Minds Gaming Co., Ltd, including any
`
`attachments, were served upon the following attorneys of record via electronic
`
`mail.
`
`Eric A. Buresh, KS Bar No. 19895 admitted pro hac vice
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
`eric.buresh@eriseip.com
`
`Paul R. Hart, admitted pro hac vice
`CO Bar No. 45697
`Michelle Callaghan, admitted pro hac vice
`CO Bar No. 50082
`ERISE IP, P.A.
`5600 Greenwood Plaza Blvd., Suite 200
`Greenwood Village, CO 80111
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
`paul.hart@eriseip.com
`michelle.callaghan@eriseip.com
`
`Steven G. Hill GA Bar No. 354658
`Martha L. Decker GA Bar No. 420867
`Hill, Kertscher & Wharton, LLP
`3350 Riverwood Parkway, Suite 800
`Atlanta, GA 30339
`Telephone: (770) 953-0995
`sgh@hkw-law.com
`md@hkw-law.com
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`-5-
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`IPR2018-00354
`COLLECTIVE EX1017 Page 6
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`/s/ Robert D. Becker
`Robert D. Becker
`
`
`Attorney for Plaintiff
`IRONBURG INVENTIONS LTD.
`
`
`
`
`
`Dated: June 8, 2017
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`318727661.2
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`-6-
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`IPR2018-00354
`COLLECTIVE EX1017 Page 7
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