e.DIGITAL will persue Infringement of patent # 737 & 170 against Motorola
in response to
by
Message: MicroSignet
COUNT ONE
INFRINGEMENT OF THE ’737 PATENT BY DEFENDANT
13. Plaintiff re-alleges and incorporates by reference each of the
allegations set forth in paragraphs 1 through 12 above.
14. Upon information and belief, Defendant, without authority, (a) has
directly infringed and continues to directly infringe the ’737 patent by making,
using, offering to sell, or selling within the United States, or importing into the
United States, products that practice one ore more claims of the ’737 patent in
violation of 35 U.S.C. § 271(a); (b) has induced and continues to induce
infringement of one or more claims of the ’737 patent in violation of 35 U.S.C. §
271(b); and (c) has contributed and continues to contribute to the infringement of
one ore more claims of the ’737 patent in violation of 35 U.S.C. § 271(c).
15. The accused products, alone or in combination with other products,
practice each of the limitations of independent claims 1, 4, 9, and 13, and
dependent claims 3, 6 and 7 of the ’737 patent.
16. The accused products for purposes of the ‘737 patent include but are
INFRINGEMENT OF THE ’737 PATENT BY DEFENDANT
13. Plaintiff re-alleges and incorporates by reference each of the
allegations set forth in paragraphs 1 through 12 above.
14. Upon information and belief, Defendant, without authority, (a) has
directly infringed and continues to directly infringe the ’737 patent by making,
using, offering to sell, or selling within the United States, or importing into the
United States, products that practice one ore more claims of the ’737 patent in
violation of 35 U.S.C. § 271(a); (b) has induced and continues to induce
infringement of one or more claims of the ’737 patent in violation of 35 U.S.C. §
271(b); and (c) has contributed and continues to contribute to the infringement of
one ore more claims of the ’737 patent in violation of 35 U.S.C. § 271(c).
15. The accused products, alone or in combination with other products,
practice each of the limitations of independent claims 1, 4, 9, and 13, and
dependent claims 3, 6 and 7 of the ’737 patent.
16. The accused products for purposes of the ‘737 patent include but are
not limited to Motorola smartphones including, but not limited to, the Razr, Razr
Maxx, Razr M, Razr HD, Razr Maxx HD, Razr M Developer Edition, Razr HD
Developer Edition, Droid 4, Photon Q 4G LTE, Photon 4G, Admiral, ES400S,
Electrify 2, Electrify M, Electrify, Defy XT, Atrix HD Developer Edition, Atrix
HD, Atrix 2, Triumph, i867, Titanium, and the XT 886; and certain Motorola
mobile phones including, but not limited, to the Quantico and the Brute i686.
Maxx, Razr M, Razr HD, Razr Maxx HD, Razr M Developer Edition, Razr HD
Developer Edition, Droid 4, Photon Q 4G LTE, Photon 4G, Admiral, ES400S,
Electrify 2, Electrify M, Electrify, Defy XT, Atrix HD Developer Edition, Atrix
HD, Atrix 2, Triumph, i867, Titanium, and the XT 886; and certain Motorola
mobile phones including, but not limited, to the Quantico and the Brute i686.
-----------------------------------------------------------------------------------------------------------------
COUNT FOUR
INFRINGEMENT OF THE ’170 PATENT BY DEFENDANT
43. Plaintiff re-alleges and incorporates by reference each of the
allegations set forth in paragraphs 1 through 12 above.
44. Upon information and belief, Defendant, without authority, (a) has
directly infringed and continues to directly infringe the ’170 patent by making,
using, offering to sell, or selling within the United States, or importing into the
United States, products that practice one ore more claims of the ’170 patent in
violation of 35 U.S.C. § 271(a); (b) has induced and continues to induce
infringement of one or more claims of the ’170 patent in violation of 35 U.S.C. §
271(b); and (c) has contributed and continues to contribute to the infringement of
one ore more claims of the ’170 patent in violation of 35 U.S.C. § 271(c).
45. The accused products, alone or in combination with other products,
practice each of the limitations of independent claims 1 and 7 and certain
dependent claims 2, 3 and 8, 9, 10, 11 and 12 of the ’170 patent.
46. The accused products for purposes of the ’170 patent include but are
not limited to Motorola smartphones including, but not limited to, the Razr, Razr
Maxx, Razr M, Razr HD, Razr Maxx HD, Razr M Developer Edition, Razr HD
Developer Edition, Droid 4, Photon 4G, ES400S, Electrify 2, Electrify M, Atrix
HD Developer Edition, Atrix HD, Atrix 2, i867, Titanium, and the XT 886; and
certain Motorola mobile phones including, but not limited to, the Brute i686.
INFRINGEMENT OF THE ’170 PATENT BY DEFENDANT
43. Plaintiff re-alleges and incorporates by reference each of the
allegations set forth in paragraphs 1 through 12 above.
44. Upon information and belief, Defendant, without authority, (a) has
directly infringed and continues to directly infringe the ’170 patent by making,
using, offering to sell, or selling within the United States, or importing into the
United States, products that practice one ore more claims of the ’170 patent in
violation of 35 U.S.C. § 271(a); (b) has induced and continues to induce
infringement of one or more claims of the ’170 patent in violation of 35 U.S.C. §
271(b); and (c) has contributed and continues to contribute to the infringement of
one ore more claims of the ’170 patent in violation of 35 U.S.C. § 271(c).
45. The accused products, alone or in combination with other products,
practice each of the limitations of independent claims 1 and 7 and certain
dependent claims 2, 3 and 8, 9, 10, 11 and 12 of the ’170 patent.
46. The accused products for purposes of the ’170 patent include but are
not limited to Motorola smartphones including, but not limited to, the Razr, Razr
Maxx, Razr M, Razr HD, Razr Maxx HD, Razr M Developer Edition, Razr HD
Developer Edition, Droid 4, Photon 4G, ES400S, Electrify 2, Electrify M, Atrix
HD Developer Edition, Atrix HD, Atrix 2, i867, Titanium, and the XT 886; and
certain Motorola mobile phones including, but not limited to, the Brute i686.
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