IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`Corrigent Corporation
`
`v.
`
`Cisco Systems, Inc.
`
`Plaintiff,
`
`Defendant.
`
`Civil Action No. 6:22-cv-00396-ADA
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF CORRIGENT CORPORATION’S
`PRELIMINARY INFRINGEMENT CONTENTIONS
`
`Plaintiff Corrigent Corporation (“Corrigent” or “Plaintiff”) hereby serves its Preliminary
`
`Infringement Contentions on Defendant Cisco Systems, Inc. (“Cisco” or “Defendant”) pursuant to
`
`paragraph 2 of the Standing Order Governing Proceedings (OGP) 4.1–Patent Cases entered on
`
`April 14, 2022. These Preliminary Infringement Contentions include “preliminary infringement
`
`contentions chart[s] setting forth where the accused product(s) each element of the asserted
`
`claim(s) are found.” Id.
`
`Asserted Patents
`
`Claim Charts
`
`U.S. Patent No. 6,957,369 (“ʼ369 patent”)
`
`U.S. Patent No. 7,113,485 (“ʼ485 patent”)
`
`U.S. Patent No. 7,330,431 (“ʼ431 patent”)
`
`U.S. Patent No. 7,593,400 (“ʼ400 patent”)
`
`U.S. Patent No. 9,118,602 (“ʼ602 patent”)
`
`Exhibit 1
`
`Exhibit 2
`
`Exhibit 3
`
`Exhibit 4
`
`Exhibit 5
`
`These Preliminary Infringement Contentions also “identify the priority date (i.e., the earliest date
`
`of invention) for each asserted claim.” Id. Corrigent has also served, contemporaneously with its
`
`Preliminary Infringement Contentions: “a copy of the file history for each patent in suit.” Id.; see
`
`COR-CSC00000001 - COR-CSC00002323. Corrigent also performed a reasonable search for “all
`
`1
`
`Ex.1019
`CISCO SYSTEMS, INC. / Page 1 of 12
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`

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`documents evidencing conception and reduction to practice for each claimed invention” within
`
`Corrigent’s possession, custody, and control, and states that no such documents exist. Id.
`
`Corrigent bases its Preliminary Infringement Contentions on its current knowledge,
`
`understanding, and belief as to the facts and information available as of the date of this disclosure,
`
`without the benefit of substantial discovery or Markman Order. As with the rest of Corrigent’s
`
`Preliminary Infringement Contentions, Corrigent’s claim charts are preliminary and exemplary in
`
`nature, and may not necessarily capture the precise nature or entire scope of Defendant’s
`
`infringement. Corrigent reserves the right to supplement these Preliminary Infringement
`
`Contentions to allege other theories of infringement based on Corrigent’s continuing investigation
`
`during the course of discovery (including any relevant discovery responses served and documents
`
`produced, as well as those that are served and produced in the future), or in response to positions
`
`taken by Defendant as the case proceeds. Corrigent further reserves the right to modify,
`
`supplement, amend, or otherwise alter these Preliminary Infringement Contentions as discovery
`
`progresses, as permitted by the Federal Rules of Civil Procedure, the Standing Order Governing
`
`Proceedings (OGP) 4.1–Patent Cases entered on April 14, 2022, or by order of the Court. In
`
`particular, Corrigent reserves the right to modify, supplement, amend, or otherwise alter these
`
`Preliminary Infringement Contentions following the Court’s Markman Order and the opportunity
`
`for expert discovery. In addition to the documents cited in Exhibits 1–5 of these Preliminary
`
`Infringement Contentions, expert discovery is likely to show that the Accused Products practice
`
`the limitations of the Asserted Claims. Corrigent will provide its expert disclosures as required
`
`and pursuant to the deadlines set forth in the Scheduling Order.
`
`These disclosures contend that Defendant’s network routing and switching products
`
`infringe U.S. Patent Nos. 6,957,369 (“ʼ369 patent”), 7,113,485 (“ʼ485 patent”), 7,330,431 (“ʼ431
`
`2
`
`Ex.1019
`CISCO SYSTEMS, INC. / Page 2 of 12
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`

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`patent”), and 7,593,400 (“ʼ400 patent”), and 9,118,602 (“ʼ602 patent”) (collectively, “Asserted
`
`Patents”). Specifically, these disclosures contend the Defendant infringes (1) at least claims 1–26
`
`of the ʼ369 patent; (2) at least claims 1–20 of the ʼ485 patent; (3) at least claims 1–30 of the ʼ431
`
`patent; (4) at least claims 1–20 of the ʼ400 patent; and (5) at least claims 1–26 of the ʼ602 patent
`
`(collectively, “Asserted Claims”).
`
`Corrigent identifies through these Preliminary Infringement Contentions, including the
`
`claim charts of Exhibits 1–5, the following products that infringe the Asserted Claims of the
`
`Asserted Patents (collectively, “Accused Products”). The Accused Products specifically identified
`
`in the claim charts of Exhibits 1–5 are representative of the other Accused Products identified
`
`herein, and each Accused Product has the same or substantially similar structure, function,
`
`configuration, and operation.
`
`Asserted Patents
`ʼ369 patent
`
`Asserted Claims
`1–26
`
`Accused Products
`Cisco’s Nexus 7000 Series
`Switches,1 Nexus 9000 Series
`Switches,2 and Catalyst 9500
`Series Switches3
`
`1 Including, on information and belief, e.g., N7K-C7004 - Cisco Nexus 7000 4-Slot Switch, N7K-
`C7009 - Cisco Nexus 7000 9-Slot Switch, N7K-C7010 - Cisco Nexus 7000 10-Slot Switch, N7K-
`C7018 - Cisco Nexus 7000 18-Slot Switch.
`2 Including, on information and belief, e.g., Cisco Nexus 9800 Modular Switches, Cisco Nexus
`9500 Modular Switches, Cisco Nexus 9400 Centralized Modular Switches, Cisco Nexus 9000
`Fixed Switches, further including, on information and belief, e.g., N9K-C9808- Cisco Nexus 9800
`8-slot chassis, N9K-C9504: 4-Slot Chassis, N9K-C9508: 8-Slot Chassis, N9K-C9516: 16-Slot
`Chassis, N9K-C9408 - Nexus 9400 Chassis with 8 linecard slots, • N9K-C9364D-GX2A, N9K-
`C9348D-GX2A, N9K-C9332D-GX2B, N9K-C9316D-GX, N9K-C93600CD-GX, N9K-C9364C-
`GX, N9K-C9336PQ, N9K-C9364C, N9K-C9332C, N9K-C93180YC-FX3, N9K-C93180YC-
`FX3S, N9K-C93108TC-FX3P, N9K-C93180YC-FX, N9K-C93108TC-FX, N9K-C9348GC-FX,
`N9K-C9336C-FX2, N9K-C9336C-FX2-E, N9K-C93240YC-FX2, N9K-C93360YC-FX2, N9K-
`C93216TC-FX2, N9K-C93180YC-EX, N9K-C93108TC-EX, N9K-C93180LC-EX, N9K-
`C93180YC-FX-24, N9K-C93108TC-FX-24, N9K-C93180YC-EX-24, N9K-C93108TC-EX-24,
`N9K- C92348GC-X, N9K-C92160YC-X, N9K-C9272Q, N9K-C92304QC, N9K-C9236C, N9K-
`C92300YC, N9K-C9396PX, N9K-C9396TX, N9K-C93128TX, N9K-C93120TX, N9K-
`C9332PQ, N9K-C9372PX-E, N9K-C9372TX-E, N9K-C9372PX, N9K-C9372TX.
`3 Including, on information and belief, e.g., C9500X-28C8D-A, C9500X-28C8D-E, C9500-32C-
`E, C9500-32C-A, C9500-32QC-E, C9500-32QC-A, C9500-48Y4C-E, C9500-48Y4C-A, C9500-
`
`3
`
`Ex.1019
`CISCO SYSTEMS, INC. / Page 3 of 12
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`

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`Asserted Patents
`ʼ485 patent
`
`Asserted Claims
`1–20
`
`ʼ431 patent
`
`ʼ400 patent
`
`1–30
`
`1–20
`
`Accused Products
`Cisco ASR 9000 Series
`Routers,4 Cisco Catalyst 8000
`EDGE Platforms,5 Cisco
`NCS 540/560 Series Routers6
`Cisco’s “Collaboration
`Platform” Compatible
`Products7
`Cisco ASR 9000 Series
`Routers8
`
`24Y4C-E, C9500-24Y4C-A, C9500-24Q-E, C9500-24Q-A, C9500-12Q-E, C9500-12Q-A,
`C9500-40X-E, C9500-40X-A, C9500-16X-E, C9500-16X-A.
`4 Including, on information and belief, e.g., ASR 9922, ASR 9912, ASR 9910, ASR 9906, ASR
`9904, ASR 9903, ASR 9902, ASR 9901, ASR 9010, ASR 9006, ASR 9001, ASR 9000v-2.
`5 Including, on information and belief, e.g., C8200-1N-4T, C8200L-1N-4T, C8200-UCPE-1N8,
`Catalyst 8300-1N1S-6T, Catalyst 8300-1N1S-4T2X, Catalyst 8300-2N2S-6T, Catalyst 8300-
`2N2S-4T2X, Catalyst 8500L (PID: C8500L-8S4X), Catalyst 8500 (PID: C8500-12X), Catalyst
`8500-4QC (PID: C8500-12X4QC).
`6 Including, on information and belief, e.g., N540-FH-CSR-SYS , N540-FH-AGG-SYS, N540-
`24Q8L2DD-SYS, N540-24Z8Q2C-SYS, N540-ACC-SYS, N540X-ACC-SYS, N540X-
`16Z4G8Q2C-A, N540X-16Z4G8Q2C-D, N540X-12Z16G-SYS-A, N540X-12Z16G-SYS-D,
`N540-28Z4C-SYS-A, N540-28Z4C-SYS-D, N540-12Z20G-SYS-A, N540-12Z20G-SYS-D,
`N540X-16Z8Q2C-D, N540X-6Z18G-SYS-A, N540X-6Z18G-SYS-D, N540X-8Z16G-SYS-A,
`N540X-8Z16G-SYS-D, N540X-4Z14G2Q-A, N540X-4Z14G2Q-D, N540-6Z14S-SYS-D, NCS
`560-4, NCS 560-7.
`7 Including, on information and belief, e.g., Cisco BE7000.
`8 Including, on information and belief, e.g., ASR 9922, ASR 9912, ASR 9910, ASR 9906, ASR
`9904, ASR 9903, ASR 9902, ASR 9901, ASR 9010, ASR 9006, ASR 9001, ASR 9000v-2.
`
`4
`
`Ex.1019
`CISCO SYSTEMS, INC. / Page 4 of 12
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`

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`Asserted Patents
`ʼ602 patent
`
`Asserted Claims
`1–26
`
`Accused Products
`Cisco’s Nexus 7000 Series
`Switches,9 Nexus 9000 Series
`Switches,10 Cisco ASR 9000
`Series Routers,11
`
`More specifically, Corrigent contends that Defendant directly infringes under 35 U.S.C. § 271(a),
`
`either literally or by the doctrine of equivalents, and/or indirectly infringes, by both inducing direct
`
`infringement and contributing to direct infringement under 35 U.S.C. §§ 271(b) and (c) at least
`
`claims 1–26 of the ʼ369 patent; at least claims 1–20 of the ʼ485 patent; at least claims 1–30 of the
`
`ʼ431 patent; at least claims 1–20 of the ʼ400 patent; and at least claims 1–26 of the ʼ602 patent by
`
`Defendant’s making, using, selling, offering for sale, and/or importing the Accused Products.
`
`Presently, and during all relevant times, Corrigent has been and is the sole owner of all
`
`right, title, and interest in the Asserted Patents, including the right to recover for past infringement.
`
`Corrigent contends through these Preliminary Infringement Contentions that the priority
`
`date for each Asserted Claim of the ʼ369 patent is no later than May 30, 2002, the filing date of
`
`U.S. Application No. 10/156,851, to which the ʼ369 patent claims priority. See ʼ369 patent at (22)
`
`9 Including, on information and belief, e.g., N7K-C7004 - Cisco Nexus 7000 4-Slot Switch, N7K-
`C7009 - Cisco Nexus 7000 9-Slot Switch, N7K-C7010 - Cisco Nexus 7000 10-Slot Switch, N7K-
`C7018 - Cisco Nexus 7000 18-Slot Switch.
`10 Including, on information and belief, e.g., Cisco Nexus 9800 Modular Switches, Cisco Nexus
`9500 Modular Switches, Cisco Nexus 9400 Centralized Modular Switches, Cisco Nexus 9000
`Fixed Switches, further including, on information and belief, e.g., N9K-C9808- Cisco Nexus 9800
`8-slot chassis, N9K-C9504: 4-Slot Chassis, N9K-C9508: 8-Slot Chassis, N9K-C9516: 16-Slot
`Chassis, N9K-C9408 - Nexus 9400 Chassis with 8 linecard slots, • N9K-C9364D-GX2A, N9K-
`C9348D-GX2A, N9K-C9332D-GX2B, N9K-C9316D-GX, N9K-C93600CD-GX, N9K-C9364C-
`GX, N9K-C9336PQ, N9K-C9364C, N9K-C9332C, N9K-C93180YC-FX3, N9K-C93180YC-
`FX3S, N9K-C93108TC-FX3P, N9K-C93180YC-FX, N9K-C93108TC-FX, N9K-C9348GC-FX,
`N9K-C9336C-FX2, N9K-C9336C-FX2-E, N9K-C93240YC-FX2, N9K-C93360YC-FX2, N9K-
`C93216TC-FX2, N9K-C93180YC-EX, N9K-C93108TC-EX, N9K-C93180LC-EX, N9K-
`C93180YC-FX-24, N9K-C93108TC-FX-24, N9K-C93180YC-EX-24, N9K-C93108TC-EX-24,
`N9K- C92348GC-X, N9K-C92160YC-X, N9K-C9272Q, N9K-C92304QC, N9K-C9236C, N9K-
`C92300YC, N9K-C9396PX, N9K-C9396TX, N9K-C93128TX, N9K-C93120TX, N9K-
`C9332PQ, N9K-C9372PX-E, N9K-C9372TX-E, N9K-C9372PX, N9K-C9372TX.
`11 Including, on information and belief, e.g., ASR 9922, ASR 9912, ASR 9910, ASR 9906, ASR
`9904, ASR 9903, ASR 9902, ASR 9901, ASR 9010, ASR 9006, ASR 9001, ASR 9000v-2.
`
`5
`
`Ex.1019
`CISCO SYSTEMS, INC. / Page 5 of 12
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`

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`(Filed: May 30, 2002).
`
`Corrigent contends through these Preliminary Infringement Contentions that the priority
`
`date for each Asserted Claim of the ʼ485 patent is no later than September 4, 2001, the filing date
`
`of U.S. Application No. 09/947,183, to which the ʼ485 patent claims priority. See ʼ485 patent at
`
`(22) (Filed: September 4, 2001).
`
`Corrigent contends through these Preliminary Infringement Contentions that the priority
`
`date for each Asserted Claim of the ʼ431 patent is no later than September 3, 2004, the filing date
`
`of U.S. Application No. 10/933,572, to which the ʼ431 patent claims priority. See ʼ431 patent at
`
`(22) (Filed: September 3, 2004).
`
`Corrigent contends through these Preliminary Infringement Contentions that the priority
`
`date for each Asserted Claim of the ʼ400 patent is no later than May 19, 2006, the filing date of
`
`U.S. Application No. 11/419,444, to which the ʼ400 patent claims priority. See ʼ400 patent at (22)
`
`(Filed: May 19, 2006).
`
`Corrigent contends through these Preliminary Infringement Contentions that the priority
`
`date for each Asserted Claim of the ʼ602 patent is no later than May 6, 2005, the filing date of U.S.
`
`Application No. 11/123,801, to which the ʼ602 patent claims priority. See ʼ602 patent at (63)
`
`(Related U.S. Application Data).
`
`Documents and discovery may support Corrigent’s claim to an earlier priority date for each
`
`Asserted Claim. Corrigent reserves the reserves the right to identify and rely on an earlier priority
`
`date for each Asserted Claim following discovery and completion of Corrigent’s continuing
`
`investigation during the course of discovery or in response to positions taken by Defendant as the
`
`case proceeds including, for example, Defendant’s identification of and reliance on prior art to the
`
`Asserted Patents.
`
`6
`
`Ex.1019
`CISCO SYSTEMS, INC. / Page 6 of 12
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`

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`Corrigent identifies the above Accused Products in these disclosures, but further discovery
`
`may be necessary to reveal additional Accused Products. Corrigent reserves the right to modify,
`
`supplement, amend, or otherwise alter these disclosures based on forthcoming discovery. The
`
`identification of Accused Products is exemplary. Defendant may readily ascertain, based on these
`
`disclosures, other products that practice one or more claims of the Asserted Patents.
`
`Corrigent provides these disclosures without the benefit of a Markman Order. Corrigent
`
`reserves the right to modify, supplement, amend, or otherwise alter these disclosures after
`
`receiving the Court’s Markman Order.
`
`Corrigent provides these Preliminary Infringement Contentions without the benefit of fact
`
`discovery, including document production of Defendant’s technical documents related to the
`
`Accused Products. Corrigent reserves the right to modify, supplement, amend, or otherwise alter
`
`these Preliminary Infringement Contentions following discovery including production of
`
`Defendant’s technical documents related to the Accused Products.
`
`Corrigent provides these disclosures without the benefit of receiving and reviewing the
`
`source code for the Accused Products, which is likely to show that the Accused Products practice
`
`the limitations of the Asserted Claims and/or one or more additional claims of the Asserted Patents.
`
`Corrigent reserves the right to modify, supplement, amend, or otherwise alter these disclosures
`
`after receiving and reviewing the source code for the Accused Products.
`
`Further fact and expert discovery may also reveal that Defendant infringes additional
`
`claims and Corrigent reserves the right to modify, supplement, amend, or otherwise alter these
`
`disclosures on that basis.
`
`Nothing in these disclosures, including Exhibits 1–5, is, or should be construed as, an
`
`admission regarding Corrigent’s understanding of the proper scope of the Asserted Claims,
`
`7
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`Ex.1019
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`Corrigent’s preliminary construction of any asserted claim or claim term(s), or Corrigent’s position
`
`on whether any claim term(s) should be construed by the Court.
`
`With regard to the claim charts attached as Exhibits 1–5, the citation of a particular
`
`document or documents with respect to a particular claim or claim element is not an admission
`
`and should not be construed as an admission that only the cited portion of the document or only
`
`the cited document(s) are relevant to that particular claim or claim element. The citations included
`
`in Exhibits 1–5 are only exemplary in nature, and the cited documents may contain additional
`
`support for a particular claim element (including references to additional documents) and/or
`
`additional documents may contain additional support for a particular claim element. Corrigent
`
`reserves the right to rely on uncited portions of documents and other uncited documents with
`
`regard to its allegations of infringement. In addition, each dependent claim in Exhibits 1–5 should
`
`be read to include the citations provided for each independent claim from which it depends.
`
`The Accused Products literally infringe the Asserted Claims of the Asserted Patents as set
`
`forth in Exhibits 1–5, for example. Corrigent reserves the right to assert infringement under the
`
`doctrine of equivalents after receiving discovery regarding the design and operation of the Accused
`
`Products, including the source code for the Accused Products; after receiving Defendant’s non-
`
`infringement, invalidity, and claim construction positions; and after receiving the Court’s
`
`Markman Order.
`
`Defendant has been on actual notice of ʼ485 patent and Defendant’s infringement of the
`
`ʼ485 patent since at least no later than around March 20, 2017, and at least no later than April 19,
`
`2022, the date Corrigent filed its Complaint. See Dkt. 1 ¶¶ 49–55; Dkt. 15, 16. Defendant has
`
`been on actual notice of other Asserted Patents, the ʼ369, ʼ431, ʼ400, and ʼ600 patents, since at
`
`least no later than April 19, 2022, the date Corrigent filed its Complaint. Id.; Dkt. 15, 16
`
`8
`
`Ex.1019
`CISCO SYSTEMS, INC. / Page 8 of 12
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`

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`(stipulating to dismiss only Corrigent’s allegations of pre-suit willful and indirect infringement of
`
`the ʼ369, ʼ431, ʼ400, and ʼ602 patents).
`
`Since at least the date Defendant had actual notice of the Asserted Patents (e.g., least no
`
`later than around March 20, 2017, for the ʼ485 patent, and at least no later than April 19, 2022, the
`
`date Corrigent filed its Complaint, for the ʼ369, ʼ431, ʼ400, and ʼ602 patents) and as also set forth
`
`in Exhibits 1–5, for example, Defendant has induced infringement of the Asserted Patents by their
`
`customers and/or end users in violation of 35 U.S.C. § 271(b) by, among other things, selling,
`
`providing support for, providing instructions for use of, and/or otherwise encouraging its
`
`customers and/or end-users to directly infringe the Asserted Claims with the intent to encourage
`
`those customers and/or end-users to infringe the Asserted Claims. See Dkt. 1 ¶ 48.
`
`By way of example, Defendant actively induces infringement of the Asserted Claims by
`
`encouraging, instructing, and aiding one or more persons in the United States, including but not
`
`limited to customers and end users who purchase, test, operate, and use Defendant’s products,
`
`including at least the Accused Products, to make, use, sell, and/or offer to sell Defendant’s
`
`products, including at least the Accused Products, in a manner that infringes the Asserted Claims.
`
`For example, Defendant actively markets, advertises, offers for sale, and/or otherwise promotes
`
`the Accused Products on its website. See id. Defendant further actively markets, advertises, offers
`
`for sale, and/or otherwise promotes its Accused Products by publishing and distributing data
`
`sheets, manuals, and guides for the Accused Products. These documents and materials are
`
`described and set forth in Corrigent’s Complaint and Exhibits 1–5. See id.; see also Exhibits 1–5.
`
`Therein, Defendant describes and touts the use of the subject matter claimed in the Asserted
`
`Patents.
`
`Since at least the date Defendant had actual notice of the Asserted Patents (e.g., least no
`
`9
`
`Ex.1019
`CISCO SYSTEMS, INC. / Page 9 of 12
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`

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`later than around March 20, 2017, for the ʼ485 patent, and at least no later than April 19, 2022, the
`
`date Corrigent filed its Complaint, for the ʼ369, ʼ431, ʼ400, and ʼ602 patents), and as also set forth
`
`in Exhibits 1–5, for example, Defendant has contributed to infringement of those patents in
`
`violation of 35 U.S.C. § 271(c) by offering to sell, selling, and importing into the United States the
`
`Accused Products, which are a material part of the invention of the Asserted Claims, especially
`
`made or adapted for use in an infringement of the Asserted Claims, and not a staple article or
`
`commodity of commerce suitable for substantial non-infringing use.
`
`Since at least the date Defendant had actual notice of the Asserted Patents (e.g., least no
`
`later than around March 20, 2017, for the ʼ485 patent, and at least no later than April 19, 2022, the
`
`date Corrigent filed its Complaint, for the ʼ369, ʼ431, ʼ400, and ʼ602 patents), Defendant’s
`
`infringement and continued infringement, direct and indirect, of the Asserted Patents has been
`
`willful, deliberate, and intentional. Since at least the time Defendant had actual notice of the
`
`Asserted Patents, Defendant had actual knowledge or awareness of the Asserted Patents. After
`
`acquiring that knowledge or awareness, Defendant infringed at least the Asserted Claims of the
`
`Asserted Patents as also set forth in Exhibits 1–5 and described herein, for example. And in doing
`
`so, Defendant knew, or should have known, that its conduct amounted to infringement of the
`
`Asserted Patents at least because Defendant had actual notice of the Asserted Patents and its
`
`infringement as described herein.
`
`10
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`Ex.1019
`CISCO SYSTEMS, INC. / Page 10 of 12
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`Dated: August 3, 2022
`
`Respectfully submitted,
`
`By: /s/ James R. Nuttall
`
`Charles Ainsworth
`State Bar No. 00783521
`Robert Christopher Bunt
`State Bar No. 00787165
`PARKER, BUNT & AINSWORTH, P.C.
`100 E. Ferguson, Suite 418
`Tyler, TX 75702
`(903) 531-3535
`E-mail: charley@pbatyler.com
`E-mail: rcbunt@pbatyler.com
`
`James R. Nuttall (IL 6243585)
`Robert F. Kappers (IL 6313187)
`Daniel F. Gelwicks (IL 6320663)
`STEPTOE & JOHNSON LLP
`227 West Monroe Street, Suite 4700
`Chicago, IL 60606
`(312) 577-1300
`E-mail: jnuttall@steptoe.com
`E-mail: rkappers@steptoe.com
`E-mail: dgelwicks@steptoe.com
`
`Michael C. Miller (NY 2066256)
`STEPTOE & JOHNSON LLP
`1114 Avenue of the Americas
`New York, NY 10036
`E-mail: mmiller@steptoe.com
`
`Thomas C. Yebernetsky (DC 219497)
`Christopher A. Suarez (IL 6307113)
`STEPTOE & JOHNSON LLP
`1330 Connecticut Avenue, NW
`Washington, DC 20036
`(202) 429-8003
`E-mail: tyebernetsky@steptoe.com
`
`Attorneys for Plaintiff Corrigent Corporation
`
`11
`
`Ex.1019
`CISCO SYSTEMS, INC. / Page 11 of 12
`
`

`

`CERTIFICATE OF SERVICE
`
`I, James R. Nuttall, hereby certify that on August 3, 2022, I caused a copy of PLAINTIFF
`
`CORRIGENT CORPORATION’S PRELIMINARY INFRINGEMENT CONTENTIONS
`
`to be served on the following counsel of record in the manner indicated below:
`
`BY EMAIL
`
`Shaun W. Hassett
`Michael E. Jones
`POTTER MINTON, P.C.
`110 N. College Ave., Suite 500
`Tyler, Texas 75702
`Email: shaunhassett@potterminton.com
`Email: mikejones@potterminton.com
`
`Stuart M. Rosenberg
`Ryan Iwahashi
`Gibson, Dunn & Crutcher LLP
`1881 Page Mill Road
`Palo Alto, CA 94304
`Email: srosenberg@gibsondunn.com
`Email: riwahashi@gibsondunn.com
`
`Brian Rosenthal
`Katherine Dominguez
`Gibson Dunn & Crutcher LLP
`200 Park Avenue
`New York, NY 10166
`Email: brosenthal@gibsondunn.com
`Email: kdominguez@gibsondunn.com
`
`/s/ James R. Nuttall
`James R. Nuttall
`
`Ex.1019
`CISCO SYSTEMS, INC. / Page 12 of 12
`
`