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Message: TPL amended Infringed contention based on changes made in the Re-Exam(Opty

It seems that a lot of your contentions arise from one of two things (recently): Whether amendments to the '336 are significant from the standpoint of infringement claims, and whether both the technologies of the '336 and '148 go hand in hand in their application in product.

I believe (I haven't gone back to confirm) that we've been advised that the amendments/replacement of claims had everything to do with clarifications to overcome asserted prior art issues during reexam, and where not for the purpose of altering original intent. Or perhaps it was from a trusted source here on Agora. Either way, it is subject to interpretation - perhaps by the court - and is not a foregone conclusion one way or the other. While your cautions along these lines are appreciated, please don't get carried away in acknowledged ignorance.

As for whether the '148 and '336 go hand in hand, my understanding from an experienced EE/Chip Designer years ago was that both of these technologies exist in all "modern" high performance processors. "They're all that way".

Another consideration is the basis for both of these patents. Recall that the were originally (along with the five others comprising the MMP) part of one, all-inclusive patent. The intent was that all these technologies would be applied in concert to achieve maximum performance. Why would anyone deviate from that intent? Don't need that level of performance? Use chips designed pre-MMP.

Perhaps put another way, if part of the technology ('148) is applied for some "middle" level performance improvement, what is the manufacturing cost difference from applying the complimentry technology ('336) and achieving more desireable performance, broader market, and greater product value? IMO, the cost difference would probably be miniscule, but here I speak in relative ignorance.

And finally, it does seem to come down to the same old thing. It only takes one. One infringed claim in one valid patent = infringement. End of story.

FWIW,

SGE

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