Thank you for your continued patience with me.

But IF the Judge were to make the requested judgment, what's left?  It seems to me it would only leave the determination of damages (by jury trial), which appears requested as item "e.".  For ease of reference:

PRAYER FOR RELIEF WHEREFORE, TPL respectfully requests judgment of the Court against NEC Electronics as follows:
a. a declaration that NEC Electronics' accused products infringe U.S. Patent Nos. 6,598,148 and 5,809, 336;
b. a declaration that U.S. Patent Nos. 6,598,148 and 5,809, 336 are not invalid;
c. a declaration that U.S. Patent Nos. 6,598,148 and 5,809, 336 are not unenforceable;
d. an award of attorney's fees and costs; and
e. such other costs and further relief as the Court may deem just and equitable.

So the document isn't presented as a motion (for SJ), but it sure looks to me like all the ingredients are there.

Apologies for belaboring...

SGE