Sakar manufactures, uses, sells and offers to sell, and/or imports into the United

States for subsequent use and sale products that directly infringe, or which employ systems or

components that make use of systems that directly infringe, at least claims 1 and 18 of the ‘774

Patent, and indirectly infringe (by inducement and/or contributory infringement) or which

employ systems or components that make use of systems that indirectly infringe at least claims 3

and 19 of the ‘774 Patent, including without limitation, the Vivitar DVR865HD Digital Video

Camcorder and other camera and video products acting or capable of acting in the manner

described and claimed in the ‘774 Patent (collectively referred to as “Sakar Infringing

Products”). (Id. at ¶ 39). As part of e.Digital’s Initial Disclosures served on April 7, 2010,

e.Digital supplemented its “Currently Identified Products” list to also include Sakar’s

DVR865HD; DVR 840XHD; DVR 830XHD; DVR 820HD; 3.1 Mega Pixel Digital Video; 5.1

MP; Digital Camcorder; iCarly Digital Camcorder; and Girls Gear Digital Camcorder. (See

Initial Disclosures attached as Exhibit G at p. 11). Moreover, e.Digital specifically advised in

those Initial Disclosures that its list was based on its investigation to date and that its list was not

“all inclusive because only the Defendants have access to a complete list of products that

conform to the definition of accused products previously provided to them by e.Digital in

February 2010. (Id. at 9).