`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 23-816-MN
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`JURY TRIAL DEMANDED
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`FRIENDLIAI INC.,
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`Plaintiff,
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`v.
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`HUGGING FACE, INC.,
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`Defendant.
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`PLAINTIFF’S DISCLOSURE OF PROPOSED CONSTRUCTIONS OF CLAIM TERMS
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`Pursuant to Section 10 of the Court’s Scheduling Order (D.I. 17; See D.I. 41), Plaintiff
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`FriendliAI Inc. (“FriendliAI”) states that it is not proposing that the Court construe any claims
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`terms from U.S. Patent Nos. 11,442,775 and 11,836,520. All claim terms identified by
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`Defendant should be construed according to their plain and ordinary meaning.
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`This disclosure is made solely for the purpose of this action. Discovery and
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`investigations in connection with this lawsuit are ongoing. FriendliAI’s disclosure is based on
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`information that is currently available to it. FriendliAI’s positions concerning the meaning,
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`scope, construction, and application of the asserted claims are to the extent those positions can be
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`deduced from the Initial Contentions served by both parties in this case so far. Given that
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`discovery is currently ongoing, FriendliAI’s proposed constructions are subject to change.
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`Further, FriendliAI does not know yet what constructions Defendant may propose, and
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`the parties must meet and confer after the exchange of the terms and proposed constructions in
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`accordance with the Court’s Scheduling Order. FriendliAI expressly reserves it right to add,
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`remove, and supplement the terms and constructions identified herein during that meet and
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`confer process. FriendliAI intends to respond to any constructions Hugging Face may identify
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`Petitioner, EX1011
`IPR2024-01234
`Hugging Face, Inc., v. FriendliAI Inc.
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`1
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`and reserves the right to revisit its position if necessary after receiving Hugging Face’s claim
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`construction disclosures.
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`OF COUNSEL:
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`Michael J. Sacksteder
`Shreyas A. Kale
`Samantha Ong
`FENWICK & WEST LLP
`555 California Street, 12th Floor
`San Francisco, CA 94104
`Tel: (415) 875-2300
`
`Jessica Kaempf
`FENWICK & WEST LLP
`401 Union Street, 5th Floor
`Seattle, WA 98101
`Tel: (206) 389-4550
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`Dated: May 28, 2024
` 11531308 / 23295.00001
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`POTTER ANDERSON & CORROON LLP
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`By: /s/ Andrew L. Brown
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Andrew L. Brown (#6766)
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`abrown@potteranderson.com
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`Attorneys for Plaintiff FriendliAI Inc.
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`2
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`2
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`CERTIFICATE OF SERVICE
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`I, Andrew L. Brown, hereby certify that on May 28, 2024, true and correct copies of the
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`within document were served on the following counsel of record at the addresses and in the
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`manner indicated:
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`VIA ELECTRONIC MAIL
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`Stephen J. Kraftschik
`POLSINELLI PC
`222 Delaware Avenue,
`Suite 1101
`Wilmington, DE 19801
`skraftschik@polsinelli.com
`
`Jason A. Wietjes
`POLSINELLI PC
`2950 N. Harwood St., Ste 2100
`Dallas, TX 75201
`jwietjes@polsinelli.com
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`11143262/23295.00001
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` /s/ Andrew L. Brown
`Andrew L. Brown
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`3
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