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Bailey Benedict <benedict@fr.com>
`Wednesday, June 28, 2023 7:12 PM
`Seth Reich; LGE/Constellation EDTX - Service; melissa@gillamsmithlaw.com
`constellation@caldwellcc.com; andrea@wsfirm.com
`RE: Constellation v LG - Final Election of Invalidity Theories/Equitable Defenses
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Counsel,
`
`Defendants’ final elecon of equitable defenses is as follows: prosecuon laches, unclean hands, and patent misuse.
`
`Defendants’ final elecon of invalidity theories and prior art references/combinaons is described in the chart below:
`
`Asserted Patent
`
`Invalidity Theories and Prior Art
`References/Combinaons
`
`’761 Patent, claims 17, 21, 24, and
`28
`
`Single ref. §103: DeGaudenzi Arcle
`
`’700 Patent, claims 1 and 5
`
`Single ref. §103: DeGaudenzi Arcle
`
`’509 Patent, claim 21
`
`’509 Patent, claim 23
`
`’922 Patent, claim 24
`
`‘922 Patent, claim 44
`
`Single ref. §103: Bauch
`
`§103: Bauch + Zhang
`
`§103: Shen + Thomsom + Cronie
`
`§103: Shen + Thomson + Cronie
`
`Regards,
`
`Bailey K. Benedict
`Principal :: Fish & Richardson P.C.
`713 654 5331 direct :: benedict@fr.com
`
`1
`
`Constellation Exhibit 2020
`LG Electronics, Inc. v. Constellation Designs, LLC
`IPR2023-00319
`Page 1 of 1
`
`

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