"I don't think they would have invested so much effort into this response if they were feeling confident about the forthcoming Collateral Estoppel decision."

IMO, I feel the arguments presented are what one would consider for general arguments of the case...

e.Digital vs. Apple and Apple vs. e.Digital.

Technical arguments are present in the recent dissertation....Why are they, as I see, presented in the 12C action?

They initially answered e.Digitlas complaint and asked for a counter complaint with jury demand....Now they present this and ask for yet another jury demand?

For all the technical issues considered in the argument....does the 12C issue boil down to local rule issues represented in the arguments? IMO that would be a legal technicality

To me, the info presented would amount to redundant action.

Or are they looking for some sort of legal technicality as I see surrounding RIM?

I was looking for a legal technicality outside the general infringement issues, however the dissertation is so lengthy it appears they are arguing the case in general and are looking for some sort of ....let me go.