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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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Magnadyne Wireless Remote and/or Wired Remote with the Magnadyne Docking
Stations or by inducing such third parties to make, use, sell, offer for sale or import
an infringing combination of the Magnadyne Docking Station with a Magnadyne
Wireless Remote and/or Wired Remote. Magnadyne was aware of the ‘756 patent
since at least January of 2011, before it began making, using, selling, offering for
sale, and/or importing the Accused Instrumentalities. Magnadyne had actual notice
that is directly infringing the ‘756 patent, at least since January 2011.
Magnadyne has actively induced infringement of the ‘756 patent under 35 U.S.C. §
271(b). Magnadyne has intentionally caused third parties to infringe the ‘756 patent
under 35 U.S.C. § 271(a) by inducing SSV (and SSV’s customers) to make, use, sell,
offer for sale or import an infringing combination of the “WP” line of Magnadyne
Docking Stations with an “iPod RF Remote” wireless controller. Magnadyne was
aware of the ‘756 patent since at least January of 2011, before it began making,
using, selling, offering for sale, and/or importing the Accused Instrumentalities.
Magnadyne had actual notice that is infringing the ‘756 patent, at least since January
2011.
Magnadyne has actively induced infringement of the ‘081 patent under 35 U.S.C. §
271(b). Magnadyne has intentionally caused third parties to directly infringe the
‘081 patent under 35 U.S.C. § 271(a) by inducing such third parties to use the
Magnadyne Docking Station separately or in combination with a Magnadyne
Wireless Remote and/or Wired Remote or by inducing such third parties to make,
use, sell, offer for sale or import the Magnadyne Docking Station or an infringing
combination of the Magnadyne Docking Station with a Magnadyne Wireless Remote
and/or Wired Remote or an “iPod RF Remote” wireless controller. On information
and belief, Magnadyne was aware of the ‘081 patent since at least November of
2013. Magnadyne had actual notice that is directly infringing the ‘081 patent, at least
since April 25, 2014.
Case3:14-cv-01931-WHA Document87-2 Filed02/03/15 Page6 of 13
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