Aquatic AQ-DM-4U Manual do Utilizador descarregar pdf (Página 6)

Aquatic, as part of its opposition to the motion for summary judgment of non-infringement

of the ‘756 patent, is submitting proof of infringement by both the Magnadyne’s Wireless and

Wired Remotes. There is no prejudice to Magnadyne in this regard. Not only are the Wired

Remotes Magnadyne products for which it has full knowledge of any relevant construction,

operation and function, but Magnadyne has taken the position that the relevant ‘756 claim terms and

the mapping of these terms to accused products does not require expert testimony. (See Dkt. 84

(“[T]here is no material dispute regarding the structure of the accused lockers. The products exist

and they are what should be compared to the construed claims to determine infringement.”).)

Magnadyne also will have the opportunity to address the proof of infringement by its Wired

Remotes in its reply brief in support of the motion for summary judgment.

V. CONCLUSION

For the foregoing reasons, there is good cause for an order allowing Aquatic leave to amend

its infringement contentions.

Dated: February 3, 2015

VALOREM LAW GROUP, LLP

/s/ David C. Bohrer

David C. Bohrer

60 South Market Street, Suite 1250

San Jose, California 95113

Telephone: (408) 938-3882

Facsimile: (408) 915-2672

J. Pat Heptig (Texas Bar No. 793940) (pro hac vice)

pat.heptig@valoremlaw.com

Of Counsel

15050 E. Beltwood Pkwy.

Addison, Texas 75001

Telephone: (214) 451-2154

Facsimile: (312) 676-5499

Attorneys for Plaintiff

Aquatic AV, Inc.

-5-

AQUATIC’S NOT. OF MOT. AND MOT. FOR LEAVE TO AMEND INFRINGEMENT CONTENTIONS

Case No. 3:14-cv-01931-WHA

Case3:14-cv-01931-WHA Document87 Filed02/03/15 Page6 of 7

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