Re: Summary of e.Digital Infringement Cases 39 - Patent 108, claim: 1
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Message: Re: Summary of e.Digital Infringement Cases 39 - Patent 108, claim: 1
And Here's how we presume so -
INFRINGEMENT OF THE ’108 PATENT BY DEFENDANT 9.
Plaintiff re-alleges and incorporates by reference each of the allegations set forth in paragraphs 1 through 8 above.
10. Upon information and belief, Defendants, without authority, (a) have induced and continue to induce infringement of one or more claims of the ’108
patent in violation of 35 U.S.C. § 271(b); and, (b) have contributed and continue to contribute to the infringement of one or more claims of the ’108 patent in violation of 35 U.S.C. § 271(c).
11. The accused products for purposes of the ’108 patent include but are not limited to the Defendants’ memory card products for Flash Memory Storage including but not limited to its USB, SSD, SD, microSD, and/or Compact Flash products. The accused products include but are not limited to the Defendant’s SDHC Class 10 memory card products for Flash Memory Storage.
12. The accused products, alone or in combination with other products, practice each of the limitations of independent claim 1 of the ’108 patent.
13. Upon information and belief, Defendants, without authority, have actively induced infringement and continue to actively induce infringement of the ’108 patent in violation of 35 U.S.C. § 271(b) by causing others to directly infringe the claims of the ’108 patent and/or by intentionally instructing others how to use the accused products in a manner that infringes the claims of the ’108 patent. On information and belief, Defendants have induced and continue to induce infringement by instructing customers to operate the product in an infringing the claims of the ’108 patent and/or by intentionally instructing others how to use the accused products in a manner that infringes the claims of the ’108 patent. On information and belief, Defendants have induced and continue to induce infringement by instructing customers to operate the product in an infringing manner and/or when Defendants test or otherwise operate the accused products in the United States.
14. Upon information and belief, Defendants, without authority, have contributed and continue to contribute to the infringement of the ’108 patent in violation of 35 U.S.C. § 271(c) by importing into the United States, selling and/or offering to sell within the United States accused products that (1) embody and constitute a material part of the invention of the ’108 patent, (2) Defendants know to be especially adapted for use in infringing the ’108 patent, and (3) are not staple articles of commerce suitable for substantial non-infringing use with respect to the ’108 patent.
15. Based on information and belief, Plaintiff alleges that Defendants sell, ship, or otherwise deliver the accused product with all the features required to infringe the asserted claims of the ’108 patent. On information and belief, these products are designed to practice the infringing features.
16. Upon information and belief, certain of these products manufactured by Pretec have been and/or are currently sold and/or offered for sale at, among other places, online at website of Pretec’s global partner in the United States, Amtron Technology Inc. at http://www.amtron.com to consumers including, but not limited to, consumers located within the State of California.
17. Defendants had knowledge of infringement of the ’108 patent since at least the filing of this complaint. On information and belief, Defendants have continued to sell products that practice the ’108 patent after acquiring knowledge of infringement.
Claim 1 of 108...
What is claimed is:
1. A method of memory management for a primary memory created from a non-volatile, long-term storage medium, said method enabling direct manipulation of contiguous and non-contiguous discrete data segments stored therein by a file system, and comprising the steps of:
(a) creating the primary memory from a non-volatile, long-term storage medium, wherein the primary memory comprises a plurality of blocks in which the data segments are to be stored;
(b) coupling a cache memory to the primary memory, said cache memory providing temporary and volatile storage for at least one of the data segments;
(c) writing a new data segment from the cache memory to the primary memory by linking said new data segment to a sequentially previous logical data segment by the following steps:
(1) receiving the new data segment in the cache memory;
(2) moving the new data segment from the cache memory to a next available space within primary memory such that the new data segment is stored in primary memory in non-used memory space;
(3) identifying the previous logical data segment in primary memory;
(4) creating a logical link between the previous logical data segment and the new data segment such that the logical link provides a path for sequentially accessing the data segments within the primary memory;
(5) creating additional serial and logical links as subsequent new data segments are written to primary memory, said logical links providing the path for serially accessing the data segments regardless of contiguity of the data segments relative to each other within the primary memory; and
(6) storing the data segments to primary memory in a manner consistent with an industry standard data storage format while retaining linking between data segments created in previous steps.
emit it's far form a last ditch effort....this is where it all started for many investors....the file system and memory management...they are going after the physical characteristics on board the Flash products that allow the paging of data into the flash ...item (b) above is the physical characteristic involved ..." On information and belief, these products are designed to practice the infringing features."
doni
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