thank you wolf. what do you think of this in particular. Is it typical lawyer stuff or did TPL fall down?
6
The Note at the bottom of the page shows that the “Serial Interface 10”, which TPL relies on in its infringement contention, is only found in the “representative” chip. This
demonstrates both that TPL has not done the homework necessary to assert that its representative chips are truly representative, and that TPL must have been aware of this at some point in time. Another striking example of TPL’s Preliminary Infringement Contention materials contradicting its assertion that the products it has chosen are representative of broader families is found with regard to “ìPD77111”, which TPL claims represents the family “Digital Signal Processor Devices”. See Exhibit 1 attached to TPL’s Motion, page 4, Table “NEC’s
Accused Chips”, row entry 7. The claim chart TPL has drawn up indicates that the “on chip input/output interface” limitation is met by an “Audio Serial Interface:”
