alleged infringing products: emphasis by Plank...

for you youngies out there, "thinkpad" laptops were owned by IBM and sold to Lenovo.

10. The accused products include but are not limited to Defendant’s

products that utilize Flash Memory Storage including but not limited to its line of

tablets and PC’s. A primary and substantial function of the accused products is to

process information and write electronic data to and store such data in electronic

format in non-volatile flash memory utilizing embedded memory, SD card memory

and/or SSD memory. The accused products include but are not limited to

Defendant’s tablets and laptops sold under its Thinkpad and Yoga Tablet brands

Case 3:15-cv-00135-BTM-NLS Document 1 Filed 01/21/15 Page 3 of 10COMPLAINT

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