Jef , Agree for your comment . The bulk of Handal strategy hidden in these paragraphs from Pacer.
As argued below, Apple’s “Motion for Judgment on the Pleadings Pursuant to Rule 12(c)” is without merit. The Motion amounts to little more than a strategic attempt to force e.Digital to prematurely disclose its claim construction positions well before it has had a chance to conduct discovery or review Apple’s invalidity contentions. Indeed, the bulk of Apple’s Motion depends entirely on how the Court will ultimately construe certain key claim terms after the Markman hearing scheduled in March 2014.
