INFRINGEMENT OF U.S. PATENT NO. 5,784,584
posted on
Jul 08, 2007 10:10AM
INFRINGEMENT OF U.S. PATENT NO. 5,784,584
A. Infringed ClaimsBased on the information presently available to it, TPL asserts that Defendants NECinfringe directly or indirectly, at least claim 29 of United States Patent No. 5,784,584 (the “‘584Patent”). Each of the NEC products identified by "Chip Part Number" in the table captioned“NEC Accused Chips [Exhibit A]” infringes claim 29 of the '584 Patent identified in the claimcharts attached as Exhibit A, and is representative for purposes of infringement of its associatedChip Family. Each of the NEC products identified by “Chip Family” in that table infringes thesame claim as the associated representative chip, with additional information on each NEC ChipFamily shown in Exhibit H; and each of NEC’s End-User Products identified in the list attachedas Exhibit D infringes a claim of the ’584 Patent, as set forth in the claim charts attached asExhibit A, B, C and G, if discovery establishes that it embodies an NEC Accused Chip, ToshibaAccused Chip, MEI Accused Chip or Covered Fujitsu Chip which infringes or is covered by such claim.
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