Re: Latest Pacer: EDIG v.Micron -10 pages- complaint,Demand for jury trial..sman
posted on
Mar 23, 2014 07:49AM
Here's some links taken from document 15-main, it shows how MICRON instructs users to UPGRADE to their SSD ... take a look.
Plaintiff alleges that Micron sold, sells, offers to sell, ships, or otherwise delivers the accused products to customers or end-users with all the features required to infringe Claim 1 of the ’108 patent. Upon information and belief, Micron knows that the accused products infringe Claim 1 of the ‘108 patent and intends to induce third parties to include its customers and end-users to also infringe Claim 1 of the ‘108 patent.
14. Upon information and belief, the accused products, alone or in combination with other products, directly or, alternatively, under the doctrine of equivalents practice each of the limitations of independent Claim 1 of the ’108 patent when they are used for their normal and intended purpose of writing to and storing electronic data on non-volatile memory. Thus, Micron directly infringes Claim 1 of the ’108 patent in violation of 35 U.S.C. § 271(a) when it demonstrates, tests or otherwise uses the accused products in the United States
By way of example, Micron’s demonstration and informational video(s), posted by Micron on Micron’s website(s) or other public websites to include those of its "brand name Crucial and/or Crucial Memory, show Micron and/or its authorized agents or employees migrating or transferring data from the memory of one or more devices to one or more of the accused products. An example can be found at
https://www.youtube.com/watch?v=Zn31L-jHpfU
Micron provides a direct link to this website on its website at
http://investors.micron.com/releasedetail.cfm?ReleaseID=833504
Another example can be found on YouTube at
https://www.youtube.com/watch?v=_vRCgNylkOo
Upon information and belief, Micron directs consumers and end-users to information. Such conduct evidences Micron’s act of direct infringement of Claim 1 of the ’108 patent.