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More docs filed by EDIG today. Apparently the Defendants are not opposing EDIG's Ammended Complaint motion so they filed it today (Doc 188). Defendants have until mid-March to respond to Ammended Complaint (can't remember the exact date but will post tonight).
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Date Filed |
# |
Docket Text |
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02/19/2010 |
Unopposed MOTION to Withdraw MOTION FOR LEAVE TO AMEND COMPLAINT by Plaintiff e.Digital Corporation. (Attachments: # 1 Proposed Order (PDF Only))(Yungwirth, Matthew) (Entered: 02/19/2010) |
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02/19/2010 |
186 |
MEMORANDUM regarding 185 Unopposed MOTION to Withdraw MOTION FOR LEAVE TO AMEND COMPLAINT filed by e.Digital Corporation.Motions referred to Magistrate Judge Michael J. Watanabe by Judge Marcia S. Krieger on 2/19/10. TEXT ONLY ENTRY - NO DOCUMENT ATTACHED(msksec, ) (Entered: 02/19/2010) |
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02/19/2010 |
NOTICE of Consent to Amend Complaint and Stipulation Pursuant to Local Rule 6.1A of Extension of Time to Respond to Amended Complaint by Plaintiff e.Digital Corporation (Yungwirth, Matthew) (Entered: 02/19/2010) |
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02/19/2010 |
AMENDED COMPLAINT for Patent Infringement against HTC America, Inc., HTC Corporation, Ikegami Electronics (USA), Inc., Imation Corporation, Kyocera Communications, Inc., Kyocera International, Inc., Kyocera Corporation, Leica Camera, Inc., Marantz America, Inc., D&M Holdings U.S. Inc., D&M Holdings, Inc., Nokia, Inc., Nokia Corporation, Panasonic Corporation of North America, Panasonic Corporation, Roland Systems Group U.S., Roland Corporation, Sakar International, Inc., Samson Technologies Corp., Teac America, Inc., VTech Electronics North America, LLC, Pentax of America, Inc., Hoya Corporation, Hoya Corporation USA, Canon USA, Inc., Canon Inc., Coby Electronics Corp., DXG Technology (U.S.A.), Inc., filed by e.Digital Corporation. (Attachments: # 1 Exhibit, # 2 Exhibit)(Yungwirth, Matthew) (Entered: 02/19/2010) |
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Interesting para #66 from Doc 188:
66. With respect to the Defendants’ indirect infringement of claim 5 of the ‘737 Patent, such allegations of indirect infringement are based on, at least, the Defendants offering for sale the Infringing Products that perform the method steps of claim 5 upon the insertion of an SD or microSD flash memory card. The corresponding acts of direct infringement would include at least the end users of those products using the Infringing Products in conjunction with an SD or micro SD flash memory card to perform the method steps. Furthermore, upon information and belief, Defendants have had knowledge of the ‘737 Patent since no later than January 7, 2010.
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Here's claim 5 of the '737 patent:
5. A method for verifying the integrity of memory on a removable flash memory recording medium chip for use within a hand held recording device, such that the flash memory is suitable for recording voice messages, said method comprising the steps of:
a) providing a removable flash memory recording chip and a hand held recording device with a plug assembly for electrically coupling the flash memory and the recording device; and
b) activating a memory integrity test by manually inserting the flash memory chip into the plug assembly of said recording device to electrically couple the flash memory to the recording device.
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