`Case 2:17-cv-00514—JRG Document 162-11 Filed 02/13/19 Page 1 of 3 PageID #: 14477
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`(cid:3)(cid:3)(cid:3)(cid:3)(cid:40)(cid:59)(cid:43)(cid:44)(cid:37)(cid:44)(cid:55)(cid:3)(cid:20)(cid:19)(cid:3)
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`Case 2:17-cv-00514-JRG Document 162-11 Filed 02/13/19 Page 2 of 3 PageID #: 14478
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`AGIS SOFTWARE DEVELOPMENT
`LLC,
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`HTC CORPORATION,
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`
`
`
`
`
` Defendant.
`
`
`
`
`
`
`Civil Action No. 2:17-CV-514-JRG
`(Lead Case)
`
`JURY TRIAL DEMANDED
`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`PLAINTIFF’S DISCLOSURE OF ASSERTED CLAIMS
`AND INFRINGEMENT CONTENTIONS
`Plaintiff AGIS Software Development LLC (“AGIS”) hereby makes the following
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`infringement disclosures under the Patent Local Rules with respect to United States Patent Nos.
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`9,467,838 (the “’838 Patent”), 9,445,251 (the “’251 Patent”), 9,408,055 (the “’055 Patent”), and
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`8,213,970 (the “’970 Patent”) (collectively, “patents-in-suit”). AGIS’s investigation is ongoing and
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`discovery has not yet commenced. Accordingly, these disclosures are based on information
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`available to AGIS at this time. AGIS reserves the right to supplement this disclosure after further
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`discovery from the defendants and non-parties, particularly documents and other discovery
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`regarding the HTC Accused Products set forth below. AGIS also reserves the right to assert
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`additional claims of the patents-in-suit, accuse different products, or find alternative literal and/or
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`equivalent infringing elements in the HTC Accused Products.
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`Case 2:17-cv-00514-JRG Document 162-11 Filed 02/13/19 Page 3 of 3 PageID #: 14479
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`
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`E.
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`PRIORITY DATES
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`Under P.R. 3-1(e), each of the asserted claims of the patents-in-suit are entitled to a
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`priority date of at least as early as September 21, 2004.2 AGIS reserves the right to establish an
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`earlier date of invention based upon actions related to conception and reduction to practice of the
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`claimed inventions.
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`F.
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`AGIS’S OWN PRODUCTS
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`At the present time, AGIS does not intend to rely on the assertion that its own apparatuses,
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`products, devices, processes, methods, acts, or other instrumentalities practice the claimed
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`inventions. AGIS reserves the right to amend this statement to identify covered products as
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`discovery progresses.
`
`II.
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`PRODUCTION OF DOCUMENTS PURSUANT TO PATENT LOCAL RULE 3-2
`
`AGIS is producing or making available for inspection documents that are in AGIS’S
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`possession, custody or control as set forth in Patent Local Rule 3-2. An AGIS 3-2 Production
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`Index identifying these documents is attached hereto.
`
`This preliminary identification of documents is for convenience and is not an admission
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`that each document falls within any exemplary categories in the Patent Local Rules, or that any
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`
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`2 AGIS continues to rely on interim priority dates identified in each of the Patents-in-Suit to 2 AGIS continues to rely on interim priority dates identified in each of the Patents-in-Suit to
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`
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`establish priority prior to the actual filing date of the Patents-in-Suit (e.g., interim priority date establish priority prior to the actual filing date of the Patents-in-Suit (e.g., interim priority date
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`April 18, 2006 which corresponds to the filing date of U.S. Patent No. 7,630,724).
`April 18, 2006 which corresponds to the filing date of U.S. Patent No. 7,630,724).
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`
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`PLAINTIFF’S DISCLOSURE OF ASSERTED CLAIMS
`AND INFRINGEMENT CONTENTIONS
`
`
`
`19
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