Upon information and belief, Nokia manufactures, uses, sells and offers to sell,and/or imports into the United States for subsequent use and sale products that directly or
indirectly (by inducement and/or contributory infringement) infringe, or which employ systemsor components that make use of systems that directly or indirectly (by inducement and/orcontributory infringement) infringe at least claim 5 of the ‘737 Patent, including withoutlimitation, the Nokia Infringing Products.
With respect to the Defendants’ indirect infringement of claim 5 of the ‘737Patent, such allegations of indirect infringement are based on, at least, the Defendants offering
for sale the Infringing Products that perform the method steps of claim 5 upon the insertion ofan SD or microSD flash memory card. The corresponding acts of direct infringement would include at least the end users of those products using the Infringing Products in conjunction with an SD or micro SD flash memory card to perform the method steps.
From Duane Morris litigation
