APPENDIX A
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`APPENDIX A
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`O-I Glass, Inc.
`Exhibit 1051
`Page 001
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`APPENDIX A
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`O-I Glass, Inc.
`Exhibit 1051
`Page 001
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`Asserted Claim
`CLAIM 1
`1. A method of creating recycled
`glass products, comprising the
`steps of:
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`
`Description of How the Accused Method Relates to the Asserted Claim
`Defendant makes numerous recycled glass products of various colors as
`demonstrated by the website:
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`Defendant’s public product catalog discloses Defendant’s ability to make
`recycled glass products of various colors, including amber, green, flint,
`blue, and dead leaf yellow:
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`1
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`O-I Glass, Inc.
`Exhibit 1051
`Page 002
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`
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`Many of these products are “recycled” in that they are made from cullet,
`meaning scrap, waste, or recycled post-consumer glass.
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`That use of cullet is demonstrated in numerous places, and is often listed as
`defendant’s “main ingredient”
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`2
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`O-I Glass, Inc.
`Exhibit 1051
`Page 003
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`For instance, Defendant’s website states that Defendant makes glass bottles
`from combining the raw materials sand, limestone, and soda ash with
`cullet, including an average of 38% post-consumer recycled glass cullet:
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`Defendant’s CEO Andres Lopez has stated the same, including in
`Defendant’s 2018 Sustainability Report:
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`According to Defendant’s Sustainability Report, making recycled glass
`products from cullet is “essential” to Defendant’s success:
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`3
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`O-I Glass, Inc.
`Exhibit 1051
`Page 004
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`Defendant often touts the same in its marketing materials:
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`4
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`O-I Glass, Inc.
`Exhibit 1051
`Page 005
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
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`In its application to the State of California for a “Beverage Container
`Recycling Market Development & Expansion Grants,” Defendant
`repeatedly admitted that it determines and tracks how much cullet it uses in
`its glass batches, as a fraction of its glass batches:
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`5
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`O-I Glass, Inc.
`Exhibit 1051
`Page 006
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`
`CLAIM 1
`obtaining unsorted mixed color
`glass cullet having glass of at
`least two different colors;
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`To the extent this Preamble is determined to be limiting, Plaintiffs
`further allege that it is infringed by the methods and processes indicated
`in the responses below.
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`As outlined below, Defendant obtains and uses unsorted mixed color glass
`cullet having glass of at least two different colors whenever Defendant
`creates recycled glass products with cullet containing broken pieces of
`glass of mixed colors and types.
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`Unsorted mixed color cullet is the same thing as mixed color cullet.
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`In the alternative, if the term unsorted has a separate meaning, the mixed
`color cullet that Defendant obtains and uses nonetheless meets this
`limitation because Defendant’s cullet is unsorted when it is charged into
`the furnace.
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`To the extent this limitation is not met literally because Defendant and/or
`its cullet suppliers allegedly obtain the mixed color cullet that Defendant
`uses by, e.g., “processing,” “sorting,” “blending,” “cleaning,” or “mixing”
`that cullet, this limitation is met in the alternative through the doctrine of
`equivalents because the mixed color cullet that Defendant allegedly obtains
`is insubstantially different than the cullet claimed by the ’737 patent,
`including because the cullet that Defendant allegedly obtains performs the
`same function, in the same way, to achieve the same results in the accused
`methods, as the cullet claimed by the ’737 patent does in the claimed
`methods.
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`6
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`O-I Glass, Inc.
`Exhibit 1051
`Page 007
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`
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
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`Indeed, when Plaintiffs filed for a grant from the State of California
`regarding their program, “Effective Use of Mixed Color Cullet in Glass
`Container Manufacturing,” Defendant filed “a letter of enthusiastic
`support” for the program and stated that “the expanded use of 3-mix cullet
`appears to be the only way in which two important goals are achieved:
`high overall glass recycling rates and establishing an adequate supply of
`cullet to the glass container industry”:
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`Defendant’s websites and marketing materials also make clear that the
`cullet that Defendant uses is—in line with current industry practice—
`mixed color cullet, or broken pieces of glass of mixed colors and types,
`including at least two of green glass, amber glass, and flint glass:
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`7
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`O-I Glass, Inc.
`Exhibit 1051
`Page 008
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`8
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`O-I Glass, Inc.
`Exhibit 1051
`Page 009
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`9
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`O-I Glass, Inc.
`Exhibit 1051
`Page 010
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`10
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`O-I Glass, Inc.
`Exhibit 1051
`Page 011
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`Defendant’s US Patent 9,475,724 (which cites many of Plaintiffs’ patents,
`including both the ’737 and ’521 patents) also discloses the use of mixed
`color glass cullet, said mixed color glass cullet including at least two of
`green glass, amber glass, and flint glass:
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`In Defendant’s processes, mixed color cullet having glass of at least two
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`11
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`O-I Glass, Inc.
`Exhibit 1051
`Page 012
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`
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`different colors is obtained by:
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`1. Purchasing said mixed color cullet;
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`Defendant’s cullet specification, which was provided to Plaintiffs during
`one of the many meetings between the parties, makes clear that Defendant
`uses unsorted mixed color glass cullet containing broken pieces of glass of
`mixed colors and types, including at least amber, flint, and green glass.
`E.g.:
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`During one such meeting in September 2005, Defendant’s executives
`repeatedly told Plaintiffs that they used and desired to use unsorted mixed
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`12
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`O-I Glass, Inc.
`Exhibit 1051
`Page 013
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`
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
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`color cullet containing glass of at least two different colors:
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`Additionally, one of the country’s largest suppliers of mixed color cullet,
`Strategic Materials, admits on its website that it supplies cullet to
`Defendant:
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`O-I Glass, Inc.
`Exhibit 1051
`Page 014
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`
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`2. Purchasing single-color cullet and mixing said single-
`color cullet with other purchased single-color cullet, with
`purchased mixed color cullet, and/or with cullet recycled
`or manufactured within the plant; and
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`US Patent 9,475,724 also discloses that such cullet can be comprised of
`both post-consumer and/or post-industrial mixed color cullet:
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`14
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`O-I Glass, Inc.
`Exhibit 1051
`Page 015
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`
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`3. Mixing single-color recycled or manufactured cullet with
`other single-color recycled or manufactured cullet, and/or
`with mixed color cullet.
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`US Patent 9,475,724 also discloses that such cullet can be comprised of
`both post-consumer and/or post-industrial mixed color cullet:
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`15
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`O-I Glass, Inc.
`Exhibit 1051
`Page 016
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`
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`
`CLAIM 1
`adding to said mixed color glass
`cullet at least one of a
`decolorizing agent which
`selectively decolorizes at least
`one of the colors of said unsorted
`mixed color glass cullet and a
`colorizing agent which enhances
`a remaining color of said unsorted
`mixed color glass cullet; and
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`Defendant’s website and marketing materials state that Defendant adds at
`least one of a decolorizing agent and colorizing agent to its glass batches
`containing unsorted mixed color cullet:
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`16
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`O-I Glass, Inc.
`Exhibit 1051
`Page 017
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`17
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`O-I Glass, Inc.
`Exhibit 1051
`Page 018
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`
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`
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`During meetings with Plaintiffs, Defendant stated that it added at least one
`of a decolorizing agent and colorizing agent to its glass batches containing
`unsorted mixed color cullet:
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`18
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`O-I Glass, Inc.
`Exhibit 1051
`Page 019
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
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`Defendant’s US patent 9,475,724 (which cites many of Plaintiffs’ patents,
`including both the ’737 and ’521 patents) also discloses the addition of at
`least one of a colorizing agent and decolorizing agent:
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`19
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`O-I Glass, Inc.
`Exhibit 1051
`Page 020
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`
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`Additionally, Defendant’s publicly available job description(s) for its
`furnace engineers confirms that such engineers will calculate the
`appropriate amount of colorizing and/or decolorizing agents:
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`20
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`O-I Glass, Inc.
`Exhibit 1051
`Page 021
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`
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`CLAIM 1
`melting the mixed color glass
`cullet and any agent added in said
`adding step to a molten state;
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`Defendant then melts the mixed color glass cullet and any colorizing
`and/or decolorizing agents added to the batch in its glassmaking furnaces.
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`21
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`O-I Glass, Inc.
`Exhibit 1051
`Page 022
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`22
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`O-I Glass, Inc.
`Exhibit 1051
`Page 023
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`23
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`O-I Glass, Inc.
`Exhibit 1051
`Page 024
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`
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`
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`
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`CLAIM 1
`creating a recycled glass product
`of said remaining color from the
`selectively colorized/decolorized
`molten mixed color glass cullet.
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`Defendant then creates recycled glass products of a single color from the
`glass batch containing mixed color cullet containing broken pieces of glass
`of mixed colors.
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`24
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`O-I Glass, Inc.
`Exhibit 1051
`Page 025
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`
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`25
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`O-I Glass, Inc.
`Exhibit 1051
`Page 026
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`26
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`O-I Glass, Inc.
`Exhibit 1051
`Page 027
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`27
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`O-I Glass, Inc.
`Exhibit 1051
`Page 028
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`28
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`O-I Glass, Inc.
`Exhibit 1051
`Page 029
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`
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`29
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`O-I Glass, Inc.
`Exhibit 1051
`Page 030
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`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`CLAIM 2
`2. A method as in claim 1,
`wherein said obtaining step
`comprises the step of obtaining
`mixed color cullet comprising
`flint, green and amber colored
`glass.
`CLAIM 3
`3. A method as in claim 2,
`wherein said adding step
`comprises the steps of adding a
`decolorizing agent which
`selectively decolorizes said green
`colored glass and a colorizing
`agent which colorizes said flint
`and decolorized green colored
`glass to amber color.
`
`CLAIM 4
`4. A method as in claim 2,
`wherein said adding step
`comprises the steps of adding a
`decolorizing agent which
`selectively decolorizes said amber
`glass and a colorizing agent
`which colorizes said flint and
`decolorized amber colored glass
`to green color.
`CLAIM 5
`5. A method as in claim 2,
`wherein said adding step
`comprises the step of adding a
`decolorizing agent which
`selectively decolorizes said amber
`colored glass and said green
`colored glass.
`CLAIM 6
`6. A method as in claim 1,
`wherein the decolorizing agent is
`selected from the group of
`physical decolorizing agents
`consisting of manganese, cobalt,
`nickel and selenides.
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`See response to Claim 1.
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`See response to Claim 1.
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`See response to Claim 1.
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`See response to Claim 1.
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`See response to Claim 1.
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`30
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`O-I Glass, Inc.
`Exhibit 1051
`Page 031
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`
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`CLAIM 7
`7. A method as in claim 1,
`wherein the decolorizing agent is
`selected from the group of
`chemical decolorizing agents
`consisting of zinc, cerium, and
`arsenic.
`CLAIM 8
`8. A method as in claim 1,
`wherein the colorizing agent is
`selected from the group
`consisting of iron pyrite, salt
`cake, sodium sulfite, sodium
`sulphide, CARBOCITE™,
`calumite, chromium oxide, and
`iron oxide.
`CLAIM 9
`9. A method of creating recycled
`glass products, comprising the
`steps of:
`CLAIM 9
`obtaining unsorted mixed color
`glass cullet having glass of at
`least two different colors;
`CLAIM 9
`adding an amount of the unsorted
`mixed color glass cullet to a glass
`melt of a virgin soda-lime glass
`batch for glass of a particular
`color;
`CLAIM 9
`adding to said glass melt at least
`one of a decolorizing agent which
`selectively decolorizes at least
`one of the colors of said unsorted
`mixed color glass cullet other
`than said particular color and a
`colorizing agent which enhances
`said particular color of said
`unsorted mixed color glass cullet;
`and
`CLAIM 9
`creating a recycled glass product
`of said particular color from the
`selectively colorized/decolorized
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`See response to Claim 1.
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`See response to Claim 1.
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`See response to Claim 1.
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`See response to Claim 1.
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`See response to Claim 1.
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`See response to Claim 1.
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`See response to Claim 1.
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`31
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`O-I Glass, Inc.
`Exhibit 1051
`Page 032
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`
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`glass melt.
`
`CLAIM 10
`10. A method as in claim 9,
`wherein said virgin glass batch
`comprises sand, limestone, soda
`ash, feldspar, salt cake, gypsum,
`CARBOCITE™, iron pyrite, and
`calumite.
`
`See response to Claim 1.
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`Numerous materials indicate the use of these materials in the virgin glass
`batches used in Defendant’s manufacturing processes.
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`32
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`O-I Glass, Inc.
`Exhibit 1051
`Page 033
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`
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`
`
`Defendant’s US patent 9,475,724 (which cites many of Plaintiffs’ patents,
`including both the ’737 and ’521 patents) similarly discloses the use of
`such raw materials:
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`33
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`O-I Glass, Inc.
`Exhibit 1051
`Page 034
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`
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`34
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`O-I Glass, Inc.
`Exhibit 1051
`Page 035
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`
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
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`35
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`O-I Glass, Inc.
`Exhibit 1051
`Page 036
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`
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
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`36
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`O-I Glass, Inc.
`Exhibit 1051
`Page 037
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`
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`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
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`See response to Claim 1 and 9.
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`See response to Claim 1 and 9.
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`See response to Claim 1 and 9.
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`
`CLAIM 11
`11. A method as in claim 9,
`wherein said obtaining step
`comprises the step of obtaining
`mixed color cullet comprising
`flint, green and amber colored
`glass.
`CLAIM 12
`12. A method as in claim 11,
`wherein the agent adding step
`comprises the steps of adding a
`decolorizing agent which
`selectively decolorizes said green
`colored glass and a colorizing
`agent which colorizes said flint
`and decolorized green colored
`glass to amber color.
`
`CLAIM 13
`13. A method as in claim 11,
`wherein the agent adding step
`comprises the steps of adding a
`decolorizing agent which
`selectively decolorizes said amber
`colored glass and a colorizing
`agent which colorizes said flint
`and decolorized amber colored
`glass to green color.
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`37
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`O-I Glass, Inc.
`Exhibit 1051
`Page 038
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`
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`CLAIM 14
`14. A method as in claim 11,
`wherein the agent adding step
`comprises the step of adding a
`decolorizing agent which
`selectively decolorizes said amber
`colored glass and said green
`colored glass.
`CLAIM 15
`15. A method as in claim 9,
`wherein the decolorizing agent is
`selected from the group of
`physical decolorizing agents
`consisting of manganese, cobalt,
`nickel, and selenides.
`CLAIM 16
`16. A method as in claim 9,
`wherein the decolorizing agent is
`selected from the group of
`chemical decolorizing agents
`consisting of zinc, cerium, and
`arsenic.
`CLAIM 17
`17. A method as in claim 9,
`wherein the colorizing agent is
`selected from the group
`consisting of iron pyrite, salt
`cake, sodium sulfite, sodium
`sulphide, CARBOCITE™,
`calumite, chromium oxide, and
`iron oxide.
`CLAIM 18
`18. A method of creating recycled
`glass products, comprising the
`steps of:
`CLAIM 18
`obtaining unsorted mixed color
`glass cullet having glass of at
`least two different colors;
`CLAIM 18
`adding an amount of the unsorted
`mixed color glass cullet to a raw
`virgin soda-lime glass batch
`mixture for glass of a particular
`color;
`
`See response to Claim 1 and 9.
`
`See response to Claim 1 and 9.
`
`
`See response to Claim 1 and 9.
`
`
`
`See response to Claim 1 and 9.
`
`See response to Claim 1.
`
` See response to Claim 1.
`
`
`
`
`
`
`
`See response to Claim 1.
`
`Numerous materials indicate the use of these materials in the virgin glass
`batches used in Defendant’s manufacturing processes.
`
`
`38
`
`O-I Glass, Inc.
`Exhibit 1051
`Page 039
`
`
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`39
`
`O-I Glass, Inc.
`Exhibit 1051
`Page 040
`
`
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`
`
`Defendant’s US patent 9,475,724 (which cites many of Plaintiffs’ patents,
`including both the ’737 and ’521 patents) similarly discloses the use of
`such raw materials:
`
`
`
`40
`
`O-I Glass, Inc.
`Exhibit 1051
`Page 041
`
`
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`
`
`
`
`
`
`
`
`
`41
`
`O-I Glass, Inc.
`Exhibit 1051
`Page 042
`
`
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`
`
`
`
`
`42
`
`O-I Glass, Inc.
`Exhibit 1051
`Page 043
`
`
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`
`
`
`
`
`
`
`
`
`
`43
`
`O-I Glass, Inc.
`Exhibit 1051
`Page 044
`
`
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`
`
`
`
`
`44
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`
`
`
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`O-I Glass, Inc.
`Exhibit 1051
`Page 045
`
`
`
`
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`
`CLAIM 18
`adding to said virgin batch
`mixture at least one of a
`decolorizing agent which
`selectively decolorizes at least
`one of the colors of said unsorted
`mixed color glass cullet other
`than said particular color and a
`colorizing agent which enhances
`said particular color of said
`unsorted mixed color glass cullet;
`
`CLAIM 18
`melting the virgin batch mixture
`with said mixed color glass cullet
`and any agent added in said
`adding step to a molten state; and
`CLAIM 18
`creating a recycled glass product
`of said particular color from the
`selectively colorized/decolorized
`virgin batch mixture.
`CLAIM 19
`19. A method as in claim 18,
`wherein said virgin glass batch
`comprises sand, limestone, soda
`ash, feldspar, salt cake, gypsum,
`CARBOCITE™, iron pyrite, and
`calumite.
`
`
`See response to Claim 1.
`
`
`See response to Claim 1.
`
`
`
`
`
`
`See response to Claim 1.
`
`
`
`
`
`See response to Claim 1 and Claim 18.
`
`
`
`
`
`
`
`
`
`45
`
`O-I Glass, Inc.
`Exhibit 1051
`Page 046
`
`
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`CLAIM 20
`20. A method as in claim 18,
`wherein said obtaining step
`comprises the step of obtaining
`mixed color cullet comprising
`flint, green, and amber colored
`glass.
`CLAIM 21
`21. A method as in claim 20,
`wherein the agent adding step
`comprises the steps of adding a
`decolorizing agent which
`selectively decolorizes said green
`colored glass and
`CLAIM 21
`a colorizing agent which colorizes
`said flint and decolorized green
`colored glass to amber color.
`CLAIM 22
`22. A method as in claim 20,
`wherein the agent adding step
`comprises the steps of adding a
`decolorizing agent which
`selectively decolorizes said amber
`colored glass and a colorizing
`agent which colorizes said flint
`and decolorized amber colored
`glass to green color.
`
`CLAIM 23
`23. A method as in claim 20,
`wherein the agent adding step
`comprises the step of adding a
`decolorizing agent which
`selectively decolorizes said amber
`colored glass and said green
`colored glass.
`CLAIM 24
`24. A method as in claim 18,
`wherein the decolorizing agent is
`selected from the group of
`physical decolorizing agents
`consisting of manganese, cobalt,
`nickel, and selenides.
`
`See response to Claim 1 and Claim 18.
`
`See response to Claim 1 and Claim 18.
`
`See response to Claim 1 and Claim 18.
`
`
`See response to Claim 1 and Claim 18.
`
`See response to Claim 1 and Claim 18.
`
`See response to Claim 1 and Claim 18.
`
`
`
`
`
`
`
`
`46
`
`O-I Glass, Inc.
`Exhibit 1051
`Page 047
`
`
`
`See response to Claim 1 and Claim 18.
`
`See response to Claim 1 and Claim 18.
`
`Green Mountain v. Owens-Illinois
`U.S. Patent No. 5,718,737
`Date: January 6, 2020
`
`CLAIM 25
`25. A method as in claim 18,
`wherein the decolorizing agent is
`selected from the group of
`chemical decolorizing agents
`consisting of zinc, cerium, and
`arsenic.
`CLAIM 26
`26. A method as in claim 18,
`wherein the colorizing agent is
`selected from the group
`consisting of iron pyrite, salt
`cake, sodium sulfite, sodium
`sulphide, CARBOCITE™,
`calumite, chromium oxide, and
`iron oxide.
`
`
`
`
`47
`
`O-I Glass, Inc.
`Exhibit 1051
`Page 048
`
`
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