`
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`8001 Development Drive
`Morrisville, NC 27560
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`Lenovo.com
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`
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`VIA FEDEX AND EMAIL
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`February 17, 2021
`
`Microsoft Corporation
`One Microsoft Way
`Redmond, Washington 98052
`
`Re:
`
`To Whom it May Concern:
`
`LiTL LLC v. Lenovo (United States) Inc. et. al., No. 1:20-cv-689 (D. Del.)
`
`Lenovo (United States) Inc. and its affiliate Lenovo Beijing Ltd. were named as defendants in the above-
`referenced lawsuit filed by LiTL LLC in the United States District Court for the District of Delaware. On December
`30, 2020, LiTL filed a First Amended Complaint, which is attached for your review. LiTL asserts infringement of
`claims of one of the asserted patents—U.S. Patent No. 8,577,957—based on Microsoft Products. For example,
`LiTL alleges infringement of at least Claim 19 of the ‘957 patent based on Microsoft Photos. See, e.g., First
`Amended Compl. ¶¶ 316-17 (“For example, the 3rd Generation ThinkPad X1 Yoga and the Yoga A940 include
`the Microsoft Photos app, which is configured to provide access to digital media albums stored [sic] OneDrive
`by clicking on a OneDrive link. . . . For example, clicking on a OneDrive album link in the Microsoft Photos app
`in the Accused Products (e.g., the 3rd Generation ThinkPad X1 Yoga, Yoga A940) accesses OneDrive user
`profile information in order to access content on a user’s OneDrive album.”) (screenshots omitted).
`
`Accordingly, this letter serves as notice of Lenovo’s request for indemnification under at least Section 8.2(a) of
`the Device Partner Terms of the Global Partner Agreement between Lenovo and Microsoft. Specifically, under
`Section 8.4 of the Device Partner Terms of the Agreement, Lenovo requests that Microsoft defend Lenovo from
`LiTL’s claims directed to the ‘957 patent “alleging that the Product alone, without modification, either (1) directly
`infringes an asserted patent claim; or (2) embodies all the essential inventive elements of an asserted patent
`claim.”
`
`Please confirm receipt of this notice and accept Microsoft’s indemnification obligation. I am responsible for the
`day-to-day management of the matter for Lenovo and would be happy to discuss next steps with you at your
`convenience. I look forward to working with you on the resolution of this matter.
`
`Sincerely,
`
`
`
`Anup M. Shah
`Senior IP Litigation Counsel
`Lenovo (United States) Inc.
`
`
`EX-1031
`Microsoft Inc. v. LiTL LLC
`
`