This is the only part of their contentions that has me a bit nervous. Anyone else feel this way? Comments welcome.

VI. CONCLUSION
For the foregoing reasons, defendants respectfully request that the Court deny TPL’s motion to amend its infringement contentions. Simply pointing to an on-chip clock generator, a connection of an external crystal to plus and minus pins, or a PLL, cannot be sufficient because those structures all existed in prior art, including prior art that TPL explicitly argued did not contain an entire on-chip ring oscillator. See, e.g., Ex. CC at 4 [‘336 File History, 7/7/97 Amendment] <B>(distinguishing Magar prior art reference that disclosed an external crystal across plus and minus pins connected to on-chip clock generator).</B>