Aquatic AQ-DM-4U Uživatelský manuál stáhnout pdf (Strana 23)

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PLAINTIFF AQUATIC AV, INC’S AM. DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT

CONTENTIONS / Case No. 3-14-cv-01931-WHA

SSV was also aware of the ‘756 patent since at least January 2011, before it began making,

using, selling, offering for sale and/or importing the Accused Instrumentalities. On information and

belief, SSV had actual notice that it is infringing the ‘756 patent, at least as early as January 2011,

but no later than November 2013, when it received notice of Aquatic’s infringement notice letter to

Magnadyne. Nonetheless, SSV continued its activities with respect to the Accused Instrumentalities

despite the objectively high likelihood that its actions constituted infringement of at least the ‘756

patent.

AQUATIC’S ACCOMPANYING DOCUMENT PRODUCTION

Aquatic identifies the following documents, which may correspond to Patent Local rules 3-2

categories (a), (b), (c), (d), and (e).

 Patent Local Rule 3-2(a): Aquatic identifies Bates Nos. AQUATIC000405 –

AQUATIC000453.

 Patent Local Rule 3-2(b): Aquatic identifies Bates Nos. AQUATIC000405 –

AQUATIC000453.

 Patent Local Rule 3-2(c): Aquatic identifies Bates Nos. AQUATIC000001 –

AQUATIC000404.

 Patent Local Rule 3-2(d): Aquatic identifies Bates Nos. AQUATIC000454 –

AQUATIC000456.

 Patent Local Rule 3-2(e): Aquatic identifies Bates Nos. AQUATIC000457 –

AQUATIC000636.

Aquatic continues to investigate the facts relating to this action. Aquatic anticipates that, as

this action proceeds, further documents may be discovered, or their significance better understood,

and Aquatic reserves the right to modify, amend, and/or supplement its responses with such

pertinent documents.

Pursuant to the Protective Order authorized by Patent Local Rule 2-2, Aquatic has

designated certain documents as confidential pursuant to the Protective Order authorized by the

Northern District of California.

Case3:14-cv-01931-WHA Document87-2 Filed02/03/15 Page12 of 13

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Aquatic AQ-DM-4U Uživatelský manuál Strana 23