'Them's fightin' words' !!!

I. INTRODUCTION
Plaintiffs have established that good cause exists for this Court to permit Plaintiffs to serve their Amended PICs. Indeed, this Court previously ordered that it would allow the Amended PICs as long as Plaintiffs provided claim charts for each accused chip, which they have now done. Quite telling, the NEC and Toshiba Defendants have already agreed to the Amended PICs, and have agreed to the terms of a representative parts stipulation, which will allow the parties to streamline discovery and efficiently present the infringement claims at trial, as well as to finally resolve all of Plaintiffs' present infringement claims against these defendants in this lawsuit.
The crux of MEI's opposition is that Plaintiffs waited too long to file this motion, and during this period, their list of accused chips has been "ever-changing." As shown below, these accusations are utterly false. If MEI had spent one-tenth the time trying to reach an agreement as to the list of chips in controversy (rather than pretending to participate in good faith in the parties' meet and confer negotiations) as it has spent in generating the phony controversy that has necessitated this motion, this motion would not have been necessary and an agreed list of chips would be in place. However, MEI (but not the other Defendants) has chosen to rewrite history by depicting Plaintiffs' efforts to provide MEI with part numbers for hundreds of MEI chips and their corresponding families based on information Plaintiffs did not receive from MEI, but had to
scour public sources for, as indicative of "ever-changing" infringement contentions. MEI's claims of prejudice are a fiction. MEI has had a near complete list of accused chips since August and a complete list since December. During the past eight months, MEI should have produced, or at a minimum compiled, the relevant technical and damages-related documents and information to Plaintiffs. MEI cannot skirt its discovery obligations, and then ARM's claim that Plaintiffs delayed bringing this motion similarly fails for the same reason: Plaintiffs acted reasonably and with diligence to serve this motion and Amended PICs and then
engaged in good faith negotiations with all Defendants to resolve any disputes and to blame Plaintiffs for having done so.