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PLAINTIFF AQUATIC AV, INC’S AM. DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT
CONTENTIONS / Case No. 3-14-cv-01931-WHA
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it, Aquatic identifies at least the following claims of U.S. Patent No. 7,831,756 (the “’756 patent”)
as infringed by Magnadyne and SSV under at least subsections (a)-(c) of 35 U.S.C. § 271:
As to Magnadyne: claims 16, 18, 19, 21, 22, and 26.
As to SSV: claims 16, 18, 19, 20, 21, and 26.
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Also, pursuant to Patent Local Rule 3-1(a), based on public information presently available
to it, Aquatic also identifies at least the following claims of U.S. Patent No. 8,578,081 (the “‘081
patent”) as infringed by Magnadyne and SSV under at least subsections (a)-(c) of 35 U.S.C. § 271:
As to Magnadyne: claims 1, 3, 4, 5, 7, 8, 9, 10, 11, 29, 30, 60, 61, 63, 64, 66, 67, and
68.
As to SSV: claims 1, 3, 4, 5, 7, 8, 9, 10, 11, 29, 30, 60, 61, 63, 64, 66, 67, and 68.
Aquatic expressly reserves its right to assert infringement of additional claims or additional
subsections of 35 U.S.C. § 271, as appropriate, in light of information that it may obtain through
discovery in this case.
Pursuant to Patent Local Rule 3-1(b), based on the information presently available to it,
Aquatic identifies at least the following apparatuses, products, devices, processes, methods, acts, or
other instrumentalities of Defendants (collectively, the “Accused Instrumentalities”:
As to Magnadyne: Magnadyne’s “Aquavibe” entertainment centers with docking station
model nos. AV-100, MD-100, MD-150, MD-150MS, MD-200, MD-250, MD-300, MD-350,
and WP-ID4, WP-ID5, WP-ID5BT, WP-ID5BTD (the Magnadyne “Docking Stations”),
separately and in combination with (1) Magnadyne’s wireless remote controllers model nos.
CCR-100, CCR-150, CCR-200, CCR-250, CCR-300, and CCR-350 (the Magnadyne
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SSV and Magnadyne to-date, in both their informal communications with counsel and in
their formal discovery responses, have denied that the accused WP line of docking stations was sold
or offered for sale with a remote control device. Accordingly, the operative complaint had not
previously asserted infringement of the ‘756 patent by SSV and Magnadyne in connection with their
making, using, offering for sale or selling of the accused WP line of docking stations. However,
Plaintiff has recently discovered that the SSV is making, using, selling or offering for sale a remote
control device that works with the WP line of docking stations. Accordingly, Plaintiff includes the
infringement of the ‘756 patent by the WP line of docking stations in its infringement contentions
and reserves the right to amend its complaint to assert infringement of the ‘756 patent by SSV
and/or Magnadyne consistent with these disclosures.
Case3:14-cv-01931-WHA Document87-2 Filed02/03/15 Page4 of 13
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