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Bretschneider SBN 50 W. August 11, Time: Courtroom 5, 4th Floor Judge: C PSG, U. R5, 12, Patent L. In its Motion, Samsung repeatedly misrepresents the ZTE Light Tab V9C (South America) Tablet USB and detail of Plaintiffs disclosures, as well as the past dealings between the parties concerning this issue. Samsung s Motion to Strike must be denied. First, by way of background, Samsung cannot possibly claim that it lacks reasonable notice of Plaintiffs Infringement Contentions as Samsung has been aware of the Plaintiffs infringement position for years.

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In the ITC proceeding, Dr. The claim charts that accompanied the Contentions are referred to as the Claim Charts.


To Strike at Dkt. Oklobdzija reiterated this same opinion at the ITC hearing, where he was subject to cross examination by Samsung s counsel. In addition, a separate case was tried against HTC in this Court involving certain of the same Qualcomm microprocessors that were at issue in the ITC proceeding. The transcript of Dr.

Oklobdzija s trial testimony along with his detailed trial demonstratives are available to Samsung and have been produced by Plaintiffs. Further, Plaintiffs infringement positions and Dr.

In light of these two proceedings and the hundreds if not thousands of pages of material in Samsung s possession detailing Plaintiffs infringement position, Samsung is unquestionably aware of Plaintiffs infringement theories that all of its Accused Products contain microprocessors that operate in the manner set forth in Plaintiffs Infringement Contentions. These documents would have provided at least some of the information Samsung now complains is absent. On November 3,Plaintiffs provided Samsung and the other defendants a draft cross use agreement that would have given Plaintiffs the ability to use the documents produced ZTE Light Tab V9C (South America) Tablet USB Samsung in the ITC Proceeding in this case. On November 18,Plaintiffs, operating under the understanding that defendants were going to propose their own cross-use agreement, asked for a copy of defendants agreement in hopes of finalizing it that week.

Two days later on November 20,Plaintiffs again asked defendants about the status of the agreement. On January 20,with no agreement in place, Plaintiffs submitted their Infringement Contentions without the benefit of using discovery already obtained from Samsung. But by that time Plaintiffs Infringement Contentions were already served and Plaintiffs had already destroyed Samsung s confidential information pursuant to the terms of the ITC protective order. Third, Samsung s position that Plaintiffs Contentions are predicated solely on a conclusory statement ZTE Light Tab V9C (South America) Tablet USB Plaintiffs information and belief does not withstand scrutiny.

To Strike at 2: As set forth below, Plaintiffs Claim Charts do in fact detail Plaintiffs infringement position and give multiple, detailed examples and citations to evidence in support of Plaintiffs position that all of the Accused Products operate in the same manner with respect to the features relevant to the Patent. ZTE Light Tab V9C (South America) Tablet USB

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Detailed Claim Charts are also provided for the other patents-in-suit, U. Although the Infringement Contentions do not cite to a Declaration of Dr. Oklobdzija, the Infringement Contentions rely upon the expert opinion of Dr. Oklobdzija, of which Samsung is unquestionably aware from the infringement opinions he provided against Samsung products in the ITC Investigation. Plaintiffs are more than willing to supplement the Infringement Contentions to expressly identify the expert report and testimony of Dr.

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Oklobdzija information already in Samsung s possession. Fourth, Plaintiffs exercised reasonable diligence in identifying specific microprocessors for each Accused Product. However, some of the microprocessors could not be identified by Plaintiff after an exhaustive search of publicly available information. For example, Samsung does not appear to publicly disclose the specific microprocessor used in all of its product lines. However, characteristics of the Accused Products e.


Bluetooth capabilities reveal that such devices must in fact contain a microprocessor possessing certain, relevant qualities. And as already stated, Plaintiffs expert s opinion is that these microprocessors operate in the same manner with respect to features relevant to the Patent.

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Although Samsung s Motion to Strike focuses on the date Accused Products were released, it is Plaintiffs informed belief that such products are in fact made, used, sold, or offered for sale e. This was explained to Samsung during the meet and confer process. Plaintiffs offered to work with Samsung to remove any products that were not made, used, sold, or offered for sale within the United States from the suit.

Samsung, however, refused to work ZTE Light Tab V9C (South America) Tablet USB Plaintiffs to remove any products it contends could not infringe during the time prior to the expiration of and Patents. Samsung s Motion to Strike is a litigation tactic and must be denied. Plaintiffs infringement positions are set forth in detail in its Infringement Contentions and, to the extent the Court finds otherwise, Plaintiffs should be given an opportunity to supplement such Contentions with information already in Samsung s possession and Samsung s non-public information obtained through discovery in this case II. This package contains the files for installing the ZTE Light Tab V9C (South America) Tablet USB Driver for Ecuador only.

If it has been installed, updating. Softpedia > Drivers > Drivers filed under: ZTE Light Tab V9C Tablet USB Driver ZTE Light Tab V9C (South America) Tablet USB Driver (Ecuador).

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