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Case 1:19-cv-11586-FDS Document 168-1 Filed 03/31/21 Page 1 of 2
`Case 1:19-cv-11586-FDS Document 168-1 Filed 03/31/21 Page 1 of 2
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` EXHIBIT A
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`EXHIBIT A
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`Case 1:19-cv-11586-FDS Document 168-1 Filed 03/31/21 Page 2 of 2
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`From:
`To:
`Cc:
`Subject:
`Date:
`
`Rodrigues, Ruben J.
`Okano, David
`BOST - F - Philips - Fitbit; Philips - Fitbit
`Philips v. Fitbit (D. Mass) - Amendment of Contentions
`Monday, December 14, 2020 1:52:15 PM
`
`Hi David,
`
`As I suggested during one of the deposition last week, Philips will be seeking leave to amend its
`infringement contentions to add the products released by Fitbit since the service of Philips’s original
`contentions, including the Sense, Versa 3, Inspire 2, and Charge 4. These products infringe for many
`of the same reasons already set forth in the contentions for related products, but appear to have
`also introduced new features as well. Please advise as to whether Fitbit will agree to the
`amendment, or whether a meet and confer would be helpful. If Fitbit will not agree, we intend to
`file our motion by the end of this week.
`
`Regards,
`
`-Ruben
`
`Ruben J. Rodrigues
`Foley & Lardner LLP
`111 Huntington Ave, Suite 2600
`Boston, MA 02199
`
`rrodrigues@foley.com
`617-502-3228 (office)
`617-763-5089 (mobile)
`
`
`

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