The specifications of each of the Asserted Patents contain word-for-word identical disclosures. For the sake of brevity and efficiency, Plaintiff cites specifically herein to the specification of the parent ’522 patent. However, Plaintiff represents and hereby notifies the Court and Defendant that Plaintiff intends to rely on the exact same disclosures contained in the ’514 patent, ’523 patent, ’524 patent, ’618 patent and ’619 patent, which specifications, again,contain exactly the same disclosures as the specification of the ’522 patent. ( e.DIGITAL Patents )

The parties anticipate they will need three (3) hours for the Claim Construction Hearing.

V. Witnesses

Neither party intends to call witnesses at the Claim Construction Hearing.