TPL, PTSC and PDS each hold rights to the Moore Microprocessor Patent (“MMP”) Portfolio, which includes the ’336 Patent, through respective assignments and/or licenses from each of the co-inventors of the MMP Portfolio, Charles H. Moore and Russell H. Fish, Ill. TPL is the assignee of a forty-five percent ownership interest in all of Mr. Moore’s rights, title and interest in the MMP Portfolio. TPL is also the exclusive licensee of all substantial rights in Mr. Moore’s remaining fifty-five percent ownership interest in the MMP Portfolio. See Confidential Exhibit 2-M. PTSC is the assignee of all of Mr. Fish’s rights, title and interest in the MMP Portfolio. See Exhibit 2-N. Through a series of transactions, TPL and PTSC each licensed to Phoenix Digital Solutions, LLC (“PDS”), a company they jointly own, the exclusive right to assert and/or grant licenses under the MMP Portfolio. See Confidential Exhibits 2-O and 2—P.PDS then granted to TPL all the rights licensed to it by both TPL and PTSC, including the exclusive right to assert and/or grant licenses under the MMP Portfolio. See Confidential Exhibit 2-Q. Thus, all substantial rights to the MMP Portfolio are held in the aggregate by Complainant TPL (along with any residual rights maintained by Complainants PTSC and PDS). A Patent Assignment Abstract of Title and the recorded assignments for the ’336 Patent are attached as Exhibits 2-A through 2-L.

The technology claimed in the ’336 Patent was created by Moore and Fish in connection with the development of a microprocessor, which came to be known as “ShBoom.”

Beginning in 1989, TPL organized and funded the ShBoom development program, which resulted in the MMP Portfolio (which includes the ’336 Patent), with Moore and Fish as coinventors. Each co-inventor had an undivided and unfettered right to the whole, thereby creating two independent chains of title, one for Moore and one for Fish. The rights of Fish ultimately came to be owned by PTSC. The rights of Moore ultimately came to be the subject of an Exclusive License and Assignment between Moore and TPL, which made TPL the exclusive licensee of all of Moore’s substantial rights in the MMP Portfolio, and gave TPL the exclusive right to manage, license, and enforce the MMP Portfolio, as well as a 45% ownership interest.

Over the years, TPL has developed a number of innovative technologies relating to the MMP Portfolio that have been embodied in TPL’s products; and, through licensing, the MMP technology has been incorporated into other companies’ products. TPL continues to make significant investments in the design, development, and marketing of MMP-based products (including embedded processors and development boards used in wireless consumer electronic devices and components thereof and products containing the same) under the OnSpec brand.

The MMP Portfolio is the subject of an extensive licensing program through which TPL provides access to the ’336 Patent and other patents. TPL has been successful in its licensing efforts, and the MMP licensing program currently includes 94 licensed entities across a variety of industries, such as consumer electronics, computers, audio/visual products, automobiles, medical equipment, industrial products, scientific instruments, and more. Among the licensees of the Asserted Patent are Ford, Mattel, Sony, HP, Fujitsu, Toshiba and Philips.

Following reexamination, the ’336 Patent has six independent claims and six dependent claims. See Exhibit l. TPL is currently asserting one or more of independent claims 1, 6, 10, ll, l3, 16 and one or more of dependent claims 7, 9, 14, and l5 against certain Respondents, as stated herein. Further investigation and discovery may lead to the assertion of additional claims of the ’336 Patent against one or more Respondents.

On January 27, 2012, the Court held the Markman hearing and, on June 12, 2012, the Court issued its First Claim Construction Order. The Related Actions remain pending.

(emphases by me)