`EXHIBIT B
`
`EXCERPT OF DEFENDANT APPLE INC.’S INITIAL AND ADDITIONAL
`DISCLOSURES
`
`C.
`
`The Le-:ga!l Theodes and F, dual Bases. of the Disdosing PaFty S C.laims, or
`Defenses
`
`Apple· is curren ly aw3!£e of the Jeg3.l thearie!.-and fa~TI:fill bases of its c:Icarims :ind defenses
`
`l:isted below,.
`
`.Apple has not yet filed ;m Ans,1-rer in this rase but mcmporat - by reference the
`
`responses and defen5~ :raised m its M otion for Partiil Disumsal of Plaintiffs Complaint for
`
`F:ulme to Staten Claim [ECF 7] andi Reply msnpport ofsrune [ECF 37] oolloctivcly
`
`.4:pple s
`
`Motion to Dismiss'). Discovery is ongoing, and i\:ppk reserves the right to n;;.sen addi.t:i.oml
`
`def.eases. ~.\pple ailso resen•es the right to morufy or suppl1:111ent its theories a!ll or the filc:tua1
`
`bases for its claims or dd'enses:
`
`N on-mfrio~ m"enr. .l\:pple bas no· directly or .indirectly i.ofilnged. either literally or under
`
`the doctrine of' equivalents,. any valid and enforoeab1e d.<lii:m of any of U.S. Patent o _ 6 748,317
`
`,CZ' .H 7 Pa em "); 6.5 !i-OJ199 t'999 Patent' - 8 33,9 493 (' 93 PateDf 1; 7 Jl 6=438 , 4 3 8 Patent , -
`
`6 408.193 ( 193 Patent ')~ 10 084,991 (' 991 P: tent")~ 6,9_,_8,306
`
`306 Patent"')" 6 3 9,794
`
`~· 794 Pat.en ' ·· 10 .• J ... 586 (' 586 Patent ')~ .ind 6=430,498
`
`498 Patent"') , collecti ·ely; the
`
`"'P:atents-m-Su:vt''). Apple does not l:ll31llJfacmr use. sell. or offer t,o iiell m the Uniteid States or
`
`4
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
