Thursday, October 22, 2020 at 10:25:00 Eastern Daylight Time
`
`Subject:
`Re: Largan v. HP : Correspondence
`Date:
`Monday, May 18, 2020 at 7:29:20 PM Eastern Daylight Time
`From:
`Lisa Phillips
`To:
`Brandon Stroy, Bill Sigler, Largan
`CC:
`AOETTeam, Newmax_Largan, Victoria Hao, yang chrisNne, MaynardLargan-HPTeam
`AEachments: image001.png, image002.png
`
`Hi Brandon,
`
`Thank you for your email. The claim charts are correct, and our asserted claims for the ’796 Patent are 1-9,
`11, and 15-25. The cover pleading mistakenly didn’t include claims 5 and 23, and we apologize for any
`confusion caused by that typographical error. As for the differences between the charts, they include
`different claims because the different products idenNfied in each chart infringe different claims.
`
`Best,
`Lisa
`
`
`Lisa Phillips | Fisch Sigler LLP
`+1.202.362.3521 (o)
`+1.240.988.3448 (m)
`
`
`From: Brandon Stroy <BStroy@maynardcooper.com>
`Date: Monday, May 18, 2020 at 6:51 PM
`To: Lisa Phillips <Lisa.Phillips@fischllp.com>, Bill Sigler <Bill.Sigler@fischllp.com>, Largan
`<Largan@fischllp.com>
`Cc: AOETTeam <AOETTeam@jonesday.com>, Newmax_Largan <newmaxcnsl_largan@fr.com>, Victoria
`Hao <vhao@sjclawpc.com>, yang chrisNne <chrisyang@sjclawpc.com>, MaynardLargan HPTeam
`<MaynardLargan HPTeam@maynardcooper.com>
`Subject: Re: Largan v. HP : Correspondence
`
`Lisa,
`
`Further to my leeer from Friday, it appears that Largan’s infringement contenNons are also inconsistent
`regarding which claims of the ‘796 patent are asserted. In Largan’s cover pleading, Largan idenNfies claims 1-
`4, 6-9, 11, 15-22, 24, and 25 as asserted. However, Largan’s claim charts each include different subsets of
`asserted claims, and in some cases include claims not included in the list on the cover pleading:
`
`
`C1: 1, 2, 3, 5, 7-9, 21-23, 25
`C2: 1, 2, 4-9, 11, 15, 16, 18-23, 25
`C3: 1, 2, 4-8, 11, 15, 16, 18-23, 25
`C4: 1-9, 15, 17-22, 24, 25
`C5: 1-4, 6-9, 11, 15-20
`C6: 1, 2, 4-9, 11, 15, 16, 18-23, 25
`
`
`Please provide an accurate list of the asserted claims at your earliest convenience.
`
`
`Page 1 of 4
`
`EX 2015 Page 1
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`

`

`Thanks,
`Brandon
`
`
`
`BRANDON STROY
`T: 415.646.4703
`M: 650.380.0434
`
`
`
`
`
`From: Lisa Phillips <Lisa.Phillips@fischllp.com>
`Date: Monday, May 18, 2020 at 2:11 PM
`To: Brandon Stroy <BStroy@maynardcooper.com>, Bill Sigler <Bill.Sigler@fischllp.com>, Largan
`<Largan@fischllp.com>
`Cc: AOETTeam <AOETTeam@jonesday.com>, Newmax_Largan <newmaxcnsl_largan@fr.com>, Victoria
`Hao <vhao@sjclawpc.com>, yang chrisNne <chrisyang@sjclawpc.com>, MaynardLargan HPTeam
`<MaynardLargan HPTeam@maynardcooper.com>
`Subject: Re: Largan v. HP : Correspondence
`
`Hi Brandon,
`
`Thank you for your leeer. But it raises asserNons that are nearly idenNcal to those raised in Ability’s leeer
`nearly a month ago. We responded to Ability’s leeer on Wednesday, April 29, copying you and the other
`counsel for HP. I’ve aeached another copy for your convenience. The responses in our April 29 leeer to Ability
`apply equally to the asserNons raised in your May 15 leeer. If you disagree or have addiNonal quesNons ajer
`reviewing it, please let us know.
`
`And two points in your leeer warrant addiNonal responses. First, your leeer ignores Largan’s document
`producNon, including the documents relaNng to its pre-suit tesNng efforts, which were produced at least a
`month before your leeer. Largan also responded to HP’s specific interrogatories and idenNfied the Bates
`numbers of those documents on April 29, more than 2 weeks before your leeer. This and the contenNons’
`detailed matching of the accused products (and substanNally similar products) to the asserted claims,
`element by element, belies HP’s claim that it’s unable to understand the infringement contenNons.
`
`Second, your leeer avers that Largan “idenNfied various accused camera modules… and then simply used
`HP’s online spare parts database to determine which HP products might hypotheNcally be comparable…
`when they are used as spare parts,” and similarly, that “as HP does not manufacture any of the accused
`camera modules, HP has no knowledge of whether the lens systems within are substanNally similar, or at all
`similar, to those in the accused camera modules…” These asserNons are specious, at best. The charted lens
`systems were removed from the idenNfied HP camera modules and systems, most of them purchased directly
`through HP. Ajer extensive tesNng of those lens systems, Largan used publicly available informaNon taken
`from HP’s own database to idenNfy HP’s own part numbers for camera modules uNlizing those same lens
`systems. HP can’t pretend to know nothing of its own products sold on its own website under its own names
`and model numbers.
`
`Thank you.
`
`
`Page 2 of 4
`
`EX 2015 Page 2
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`

`

`Best,
`Lisa
`
`
`Lisa Phillips | Fisch Sigler LLP
`+1.202.362.3521 (o)
`+1.240.988.3448 (m)
`
`
`From: Brandon Stroy <BStroy@maynardcooper.com>
`Date: Friday, May 15, 2020 at 5:07 PM
`To: Bill Sigler <Bill.Sigler@fischllp.com>, Largan <Largan@fischllp.com>
`Cc: AOETTeam <AOETTeam@jonesday.com>, Newmax_Largan <newmaxcnsl_largan@fr.com>, Victoria
`Hao <vhao@sjclawpc.com>, yang chrisNne <chrisyang@sjclawpc.com>, MaynardLargan HPTeam
`<MaynardLargan HPTeam@maynardcooper.com>
`Subject: Largan v. HP : Correspondence
`
`Bill,
`
`Please see the aeached correspondence.
`
`Best,
`Brandon
`
`BRANDON STROY
`Partner
`T: 415.646.4703
`M: 650.380.0434
`bstroy@maynardcooper.com
`Transamer ca Pyram d Center
`600 Montgomery Street, 26th F oor
`San Franc sco, CA 94111
`www.maynardcooper.com
`
`
`
`
`
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`for the named recipient and may be legally privileged and include confidenNal informaNon. If you are not the
`intended recipient, be aware that any disclosure, distribuNon or copying of this e-mail or its aeachments is
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`
`ConfidenNality NoNce - The informaNon contained in this e-mail and any aeachments to it is intended only
`
`Page 3 of 4
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`EX 2015 Page 3
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`

`

`for the named recipient and may be legally privileged and include confidenNal informaNon. If you are not the
`intended recipient, be aware that any disclosure, distribuNon or copying of this e-mail or its aeachments is
`prohibited. If you have received this e-mail in error, please noNfy the sender immediately of that fact by
`return e-mail and permanently delete the e-mail and any aeachments to it. Thank you.
`
`Page 4 of 4
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`EX 2015 Page 4
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`