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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
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`PHILIPS NORTH AMERICA LLC,
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`v.
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`FITBIT, INC.,
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`Plaintiff,
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`Defendant.
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`Civil Action No. 1:19-cv-11586-IT
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`UNOPPOSED NOTICE OF CORRECTION OF PARTIES’ JOINT CLAIM
`CONSTRUCTION CHART
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`Fitbit, Inc. (“Fitbit”) submits this Notice of Correction of the Parties’ Joint Claim
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`Construction Chart, which was filed on May 14, 2020 (see D.I. 65-1). The corrected chart is
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`attached to this Notice as Exhibit A. The corrected chart adds two words (“programmed to”) to
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`Fitbit’s construction of the term “in the event of an interruption of the wireless connection . . .
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`configured to store” that Fitbit previously failed to include in both its Local Rule 16.6(e)(1)(A)
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`disclosures and the parties’ Joint Claim Construction chart, but which were included in Fitbit’s
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`opening claim construction brief. (D.I. 72 at 8; see D.I. 78 at 13-14). Philips maintains its
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`objections to Fitbit’s proposed construction, but does not oppose the filing of a corrected chart.
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`
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`Case 1:19-cv-11586-IT Document 80 Filed 07/29/20 Page 2 of 3
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`Dated: July 29, 2020
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`FITBIT, INC.
`
`By Its Attorneys,
`
`/s/ Yar R. Chaikovsky
`Yar R. Chaikovsky
`yarchaikovsky@paulhastings.com
`Chad Peterman
`chadpeterman@paulhastings.com
`Dave Beckwith
`davidbeckwith@paulhastings.com
`David Okano
`davidokano@paulhastings.com
`Radhesh Devendran
`radheshdevendran@paulhastings.com
`Berkeley Fife
`berkeleyfife@paulhastings.com
`
`PAUL HASTINGS LLP
`1117 S. California Avenue
`Palo Alto, California 94304-1106
`Telephone: 1(650) 320-1800
`Facsimile:
`1(650) 320-1900
`
`Jennifer B. Furey (BBO # 634174)
`Andrew T. O’Connor (BBO # 664811)
`GOULSTON & STORRS PC
`400 Atlantic Avenue
`Boston, MA 02110
`Telephone: (617) 482-1776
`Facsimile: (617) 574-4112
`E-mail: jfurey@goulstonstorrs.com
`aoconnor@goulstonstorrs.com
`
`- 2 -
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`
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`Case 1:19-cv-11586-IT Document 80 Filed 07/29/20 Page 3 of 3
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`
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`CERTIFICATE OF SERVICE
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`I certify that a true copy of the above document was served on the attorney of record for
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`each party via the Court’s CM/ECF system, which will send notification of this filing (NEF) to
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`all registered participants, and paper copies will be sent to those indicated as nonregistered
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`participants.
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`Dated: July 29, 2020
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`
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`
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`By: /s/ Yar R. Chaikovsky
`
`
`Yar R. Chaikovsky (Pro Hac Vice)
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