`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`INGENIOSHARE, LLC,
`
`Plaintiff,
`
`v.
`
`EPIC GAMES, INC.,
`
`Defendant.
`
`Civil Action No. 6:21-cv-00663-ADA
`
`PLAINTIFF’S PRELIMINARY INFRINGEMENT CONTENTIONS
`
`Pursuant to the Court’s Order Governing Proceedings – Patent Cases, Plaintiff
`
`IngenioShare, LLC hereby provides its Preliminary Infringement Contentions to Defendant.
`
`These infringement contentions are based upon publicly available information. The
`
`references contained in the appended claim chart are intended to be exemplary rather than
`
`exhaustive. Furthermore, certain technical information concerning the Accused Instrumentalities
`
`is not publicly available. Such technical information may provide additional support for
`
`Plaintiff’s infringement contentions. Plaintiff reserves the right to amend its infringement
`
`contentions and asserted claims as discovery progresses based, for example, upon information
`
`obtained through discovery or in response to claim-construction rulings in this case or in any
`
`related case.
`
`As shown in the appended charts, Plaintiff asserts that Defendant infringes the following
`
`claims: claims 1, 2, 3, 6, 7, 8, 9, and 15-17 of U.S. Patent No. 10,708,727 (Claim Chart attached
`
`hereto as Exhibit A); claims 7-12, 22-24, and 33-62, 64, 65, and 67 of U.S. Patent No.
`
`Epic Games Ex. 1012
`Page 1
`
`
`
`10,492,038 (Claim Chart attached hereto as Exhibit B); Claims 1-6, 11-15, 17, 19, and 20 of U.S.
`
`Patent No. 10,142,810 (Claim Chart attached hereto as Exhibit C); and claims 53, 54, and 56 of
`
`U.S. Patent No. 8,744,407 (Claim Chart attached hereto as Exhibit D).
`
`All asserted claims are entitled to an effective filing date of June 10, 2005. All asserted
`
`claims are also entitled to a priority date from conception and/or reduction to practice of at least
`
`as early as April 27, 2005.
`
`Plaintiff produces herewith documents numbered IS 000001-IS 001676, which includes a
`
`copy of the file histories for the asserted patents and all documents evidencing conception and
`
`reduction to practice for each claimed invention currently known to Plaintiff. Should Plaintiff
`
`later discover additional documents evidencing conception or reduction to practice, it will
`
`supplement its production accordingly.
`
`This 16th day of September, 2021.
`
`/s/ Cortney S. Alexander
`Stephen R. Risley
`steverisley@kentrisley.com
`Tel: (404) 585-2101
`Cortney S. Alexander
`cortneyalexander@kentrisley.com
`Tel: (404) 855-3867
`KENT & RISLEY LLC
`5755 N Point Pkwy Ste 57
`Alpharetta, GA 30022
`
`Attorneys for Plaintiff
`
`Epic Games Ex. 1012
`Page 2
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that Plaintiff’s Preliminary Infringement Contentions
`
`and Document Production Accompanying Disclosure was served on Defendant’s counsel of
`
`record via-email this 16th day of September, 2021.
`
`/s/ Cortney S. Alexander
`Cortney S. Alexander
`
`Epic Games Ex. 1012
`Page 3
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
