1 ARM should not be forced to incur unnecessary expenses defending either this lawsuit or a future lawsuit. ARM should be entitled to include in the judgment those products for which Plaintiffs demanded discovery. ARM will not contract or stipulate to less than what it should be entitled (this must be applying great pressure to them?)– no rational company would do so. To do so would only invite the future expense of re-litigating those same products. Accordingly, ending this dispute here and now is the appropriate course of conduct. Plaintiffs’ unreasonable stipulation raises the question: Why are they attempting to withhold the ability to threaten ARM’s products? The answer is that Plaintiffs with(spelling error) to continue to make unfounded accusations of infringement against ARM’s customer licensees. Inclusion of ARM’s set of products for which Plaintiffs demanded discovery into the judgment should end Plaintiffs’ campaign of harassment against ARM’s customer licensees.(tryinging to save face with customers)2 Plaintiffs may not want to stop making such unwarranted accusations, but ARM should not be forced to stipulate to anything that does not end this campaign. If Plaintiffs accept the reasonable stipulation offered by defendants, (did anybody find this offer anywhere?)then the ‘584 patent and ARM will be out of this case. Until that point, ARM vigorously opposes any effort by Plaintiffs to delay the trial by more than two months.
1 See Exh. H. The Patent and Trademark Office recently rejected the asserted ‘584 claim as anticipated by 11 separate references – using Plaintiffs’ own claim construction.(cheap shot by bringing this issue up)
2 Any continued accusations against ARM products in the face of a judgment may raise issues such as patent misuse, antitrust violations and unfair trade torts.

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