This is what I was referring to in my previous post

II. ARM’S OBJECTIONS ARE NOT MOOT BECAUSE PLAINTIFFS SEEK TO
WITHHOLD LEGAL CLAIMS TO ASSERT IN A FUTURE LAWSUIT.
Plaintiffs’ brief wrongly implies that ARM’s objections are moot because of an alleged stipulation which would eliminate the ‘584 patent. Unfortunately, Plaintiffs’ proposed stipulation retains the ability to sue ARM again in the future. ARM should be entitled to a stipulation of non-infringement for all products which were, or could have been, accused of infringement. Plaintiffs’ proposed stipulation only addresses products that were specifically accused and reserves the ability to bring a future lawsuit against other products. ARM’s position is simple: either Plaintiffs bring their claims now or they should be foreclosed in the future. One specific dispute is over the whether ARM’s “Cortex” and “SecurCore” processors are included in the stipulation. Plaintiffs specifically forced ARM to collect and process documents related to these cores in an exchange between the parties: Nov. 22, 2006: Letter from ARM to TPL: ARM suggests that TPL define the “ARM Accused Products” as the ARM7, ARM9, ARM10, and ARM11 microprocessor core families. (Exh. C) Dec. 7, 2006: TPL demands a much more expansive definition: You have suggested that the ARM Accused Products be defined as the "ARM7, ARM9, ARM10, and ARM11 microprocessor families." We think this definition is too narrow. The Accused Products should also include all ARM product families that are licensed to or otherwise made available to the NEC, Toshiba and MEI Defendants, or any of them, including but not limited to, the ARM7, ARM9, ARM9E, ARM10E, ARM11, Cortex, and SecurCore microprocessor families. (Exh. D) Simply put, Plaintiffs cannot legitimately force ARM to collect and process documents regarding certain products and then reserve the ability to bring a separate lawsuit on those products. ARM’s products do not infringe Plaintiffs’ invalid claims.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