`Case 1:20-cv-00393-LMB-TCB Document 1380-4 Filed 06/29/22 Page 1 of 4 PagelD# 34264
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`EXHIBIT 4
`EXHIBIT 4
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`Case 1:20-cv-00393-LMB-TCB Document 1380-4 Filed 06/29/22 Page 2 of 4 PageID# 34265
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`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
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`RAI STRATEGIC HOLDINGS, INC. and
`R.J. REYNOLDS VAPOR COMPANY,
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`Plaintiffs and Counterclaim
`Defendants,
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`
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`v.
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`ALTRIA CLIENT SERVICES LLC; PHILIP
`MORRIS USA INC.; and PHILIP MORRIS
`PRODUCTS S.A.,
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`Defendants and Counterclaim
`Plaintiffs.
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`Civil Action No. 1:20-cv-393
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`SUPPLEMENTAL OPENING EXPERT REPORT OF HAROLD J. WALBRINK
`RELATING TO INFRINGEMENT
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`CONTAINS CONFIDENTIAL BUSINESS INFORMATION
`SUBJECT TO PROTECTIVE ORDER
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`Case 1:20-cv-00393-LMB-TCB Document 1380-4 Filed 06/29/22 Page 3 of 4 PageID# 34266
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`3.
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`“and a heating device, configured to be connected to the mouthpiece,
`comprising:”
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`50.
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`The Accused Products include a heating device, configured to be connected to the
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`mouthpiece. I annotated where the heating device is in the photograph below, which I took of a
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`Vuse Alto that I dissembled.
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`12
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`CONTAINS CONFIDENTIAL BUSINESS INFORMATION
`SUBJECT TO PROTECTIVE ORDER
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`Case 1:20-cv-00393-LMB-TCB Document 1380-4 Filed 06/29/22 Page 4 of 4 PageID# 34267
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`The Alto PMTA refers to the heating device as a “Heater” shown as 7 in the Alto
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`51.
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`PMTA. The heater is “configured to be connected” to the mouthpiece described above.
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`Specifically, a “Heater Top Cover” “positions the Heater subassembly” and silicon 3 is a “seal”
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`between the Heater Top Cover and the mouthpiece described above (the cartomizer holder tap,
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`silicon 4, cartomizer tube, and silicon 1). Id. at 1360082-86.
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`52.
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`The “heater” is a heating device because it heats up when power is applied to
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`aerosolize e-liquid. RJRITC_001360053 at 1360086.
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`13
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`CONTAINS CONFIDENTIAL BUSINESS INFORMATION
`SUBJECT TO PROTECTIVE ORDER
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