M Edge Accessories LLC v. Amazon.Com Inc.

Filing 10

AMENDED COMPLAINT against Amazon.Com Inc., filed by M Edge Accessories LLC. (Attachments: # 1 Redlined Version, # 2 Exhibit A, # 3 Exhibit B)(Jasani, Ranak)

Claim 1: A cover assembly for an eReader
comprising:

Amazon named the Amazon product the
“Kindle Lighted Leather Cover” and an Amazon
website for the Amazon product refers to the
Amazon product as “[o]ur all-new Kindle
cover” under “Product Description.” The
website for the Amazon product is at
http://www.amazon.com/Kindle-LightedLeather-Cover-Keyboard/dp/B003DZ165W.
Under “Frequently Bought Together,” the
website states that “[c]ustomers buy this item
with Kindle Keyboard 3G.”

On the Amazon website for the “Kindle
Keyboard 3G” under “Features,” the website
states that the “Kindle Keyboard 3G is easy to
hold and read” and further explains that “[w]e
designed our e-reader with long-form reading in
mind.” The website for the Kindle Keyboard
3G is at http://www.amazon.com/KindleKeyboard-Free-Wi-Fi-Display/dp/
B004HZYA6E/ref=pd_bxgy_kinh_text_b.
Thus, the Amazon product is a cover for the
Kindle, which is described as an e-reader by
Amazon.

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Exhibit B

a protective cover including:

The website states under “Product Features” that
a “[s]oft, grey, microfiber suede interior protects
Kindle.”
The website states under “Product Description”
that the “contoured, pebble-grain leather
(available in 7 different colors) keeps your
Kindle safe and secure, while the soft charcoal
microfiber interior protects the screen from
scratches.”

Thus, Amazon considers either the interior, the
exterior, or both as providing a protective cover
for the Kindle.

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a first and second cover each including, an
interior surface and an exterior surface,

The website states under “Product Description”
that “the reading light is located in the top righthand corner of the back cover.”
Thus, the Amazon product includes at least a
“back cover” that is distinguished by Amazon
from the rest of the “Kindle Lighted Leather
Cover.”
The website states under “Product Features” that
the “Kindle Lighted Leather Cover” includes
“stylish, genuine leather exterior” and a “[s]oft,
grey, microfiber suede interior…”
The website states under “Product Description”
that the “cover is designed to fold back, so you
can read comfortably with just one hand.” Thus,
the Amazon product includes at least two
portions so that one portion can fold back onto
another portion.
Pictures from the website (provided below)
show at least a front cover and a back cover.

Thus, the Amazon product includes a first cover
and a second cover, i.e., a front cover and a back
cover, and each includes an exterior surface and
an interior surface.

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a spine connecting the first and second covers
which are pivotable with respect to each other
about the spine, and

The website states under “Product Description”
that the “cover is designed to fold back, so you
can read comfortably with just one hand.”
A picture from the website (provided below)
shows a portion defined by creases around
which a front cover and a back cover are
pivotable.

Thus, the Amazon product includes a spine
connecting the front cover and the back cover so
that they are pivotable with respect to each other
about the spine so as to be folded back.

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a pocket formed between the interior surface
and the exterior surface of one of the first and
second covers,

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
At least a portion of the light for the Amazon
product is disposed in a pocket in its “back
cover” between the interior and exterior of the
“back cover”.

Thus, the Amazon product includes a pocket
formed between the interior and exterior
surfaces of the back cover so that the light can
be pulled out from the pocket of the back cover.

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wherein the pocket does not traverse the spine
and extends away from the spine and has an
opening formed at an edge of one of the
interior surfaces,

The pocket for the light of the Amazon product
extends from a crease that allows the Amazon
product to “fold back”. The pocket does not
traverse the crease.
The pocket for the light of the Amazon product
extends from the crease to a corner of the “back
cover”. Thus, the pocket extends away from the
crease.
The pocket for the light of the Amazon product
has an opening, from which the light can be
pulled out, at a corner edge of the “back cover”.
Thus, the pocket has an opening at an edge of
the interior surface of the back cover.

Thus, the Amazon product includes a pocket,
wherein the pocket does not traverse the spine
and extends away from the spine. The pocket
has an opening at an edge of the interior surface
of the back cover.

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a booklight including,

The website states under “Product Description”
that “[o]ur new design seamlessly incorporates a
reading light into the cover, so you can carry
your Kindle wherever you go and always have a
reading light with you.”

Thus, the Amazon product includes a booklight.
a base with a protrusion,

The light for the Amazon product includes at
least two portions. The first portion includes a
light housing assembly comprising a light
source, a neck extending from the light housing
assembly, and a base at the end of the neck
opposite the light housing assembly. The base
includes at least two protrusions.

Thus, the Amazon product includes a booklight
with a base with protrusions.

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a substantially flat portion that is disposed
within the pocket formed between the interior
surface and the exterior surface of one of the
first and second covers,

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
The light for the Amazon product includes at
least two portions. The first portion includes a
light housing assembly comprising a light
source, a neck extending from the light housing
assembly, and a base at the end of the neck
opposite the light housing assembly. The
second portion receives the first portion.
The second portion is positioned within the
“back cover” between its interior and exterior.
Thus, in order to fit within the back cover
between its interior and exterior, the second
portion is flat.

Thus, the Amazon product includes a light with
a substantially flat portion that is disposed
within a pocket formed between the interior
surface and the exterior surface of the back
cover.

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the substantially flat portion including a slot
that receives the protrusion, so that the base is
coupled with the substantially flat portion
while the base is capable of moving relative
to the substantially flat portion,

The light for the Amazon product includes at
least two portions. The first portion includes a
light housing assembly comprising a light
source, a neck extending from the light housing
assembly, and a base at the end of the neck
opposite the light housing assembly.
The base includes at least two protrusions at
opposite sides of the base and extending away
from the base. The two protrusions extend
perpendicularly with respect to the neck
between the base and the light housing
assembly.
The second portion receives the first portion and
is flat so that it can be positioned between the
interior and exterior of the back cover. The
second portion includes slots that receive the
two protrusions of the first portion, respectively.
The protrusions of the first portion slide within
the slots of the second portion, respectively, so
that first portion is capable of moving relative to
the flat second portion.

Thus, the Amazon product includes a light with
a substantially flat portion that includes a slot
that receives protrusions at the base of the light
so that the base is coupled with the substantially
flat portion while the base is capable of moving
relative to the substantially flat portion.

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a light housing assembly having a light
source, and

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
A picture from the website (provided below)
shows a light housing assembly comprising a
light source.

Thus, the Amazon product includes a light
comprising a light housing assembly that has a
light source.

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a neck between the base and the light housing
assembly.

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
For the light of the Amazon product to “pull out
from the back cover when needed”, the light of
the Amazon product includes a neck between its
base and the light housing assembly.

The light for the Amazon product includes at
least two portions. The first portion includes a
light housing assembly comprising a light
source, a neck extending from the light housing
assembly, and a base at the end of the neck
opposite the light housing assembly.

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Claim 2: The cover assembly of claim 1,
wherein the neck is a flexible neck.

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
For the light of the Amazon product to “pull out
from the back cover when needed”, the light of
the Amazon product includes a flexible neck
between its base and light housing assembly.

The light for the Amazon product includes at
least two portions. The first portion includes a
neck that extends from the light housing
assembly and is flexible.

Thus, the Amazon product has a flexible neck.

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Claim 3: The cover assembly of claim 1,
wherein the light source includes a light
emitting diode (LED).

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”

Thus, the Amazon product has a light source
that includes a LED, as described by Amazon.

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Claim 4: The cover assembly of claim 1,
wherein the interior surface further includes
an axis and the interior surface is bendable
around the axis, and
wherein the pocket is formed at an angle with
respect to the axis.

The website states under “Product Description”
that the “cover is designed to fold back, so you
can read comfortably with just one hand.”
The interior of Amazon product includes a
crease that allows the cover to fold back for
reading with just one hand. Thus, the Amazon
product includes an axis and an interior surface
that is bendable around the axis.
The pocket for the light of the Amazon product
extends from a middle portion of the crease to a
corner of the “back cover” and thus is formed at
an angle with respect to the crease of the
Amazon product.

Thus, the Amazon product includes an axis, an
interior surface that is bendable around the axis,
and a pocket that is formed at an angle with
respect to the axis.

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Claim 5: The cover assembly of claim 1,
wherein the pocket is coupled to the interior
surface.

The website under “Product Features” states that
a “built-in, retractable LED reading light pulls
out from the back cover when needed, and slides
away to become invisible when not in use.” The
light for the Amazon product is in a pocket
between the interior and exterior of the “back
cover”. The pocket is formed as a part of the
interior of the “back cover”.

.
Thus, the Amazon product includes a pocket
that is coupled to its interior surface.

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Claim 6: A cover assembly for an eReader,
comprising:

Amazon named the Amazon product the
“Kindle Lighted Leather Cover” and an Amazon
website for the Amazon product refers to the
Amazon product as “[o]ur all-new Kindle
cover” under “Product Description.”
Under “Frequently Bought Together,” the
website states that “[c]ustomers buy this item
with Kindle Keyboard 3G.”

On the Amazon website for the “Kindle
Keyboard 3G” under “Features,” the website
states that the “Kindle Keyboard 3G is easy to
hold and read” and further explains that “[w]e
designed our e-reader with long-form reading in
mind.”
Thus, the Amazon product is a cover for the
Kindle, which is described as an e-reader by
Amazon.

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a protective cover including a first and second The website states under “Product Features” that
cover each including,
a “[s]oft, grey, microfiber suede interior protects
Kindle.” The website states under “Product
Description” that the “contoured, pebble-grain
leather (available in 7 different colors) keeps
your Kindle safe and secure, while the soft
charcoal microfiber interior protects the screen
from scratches.” Thus, the Amazon product has
an interior, an exterior, or both that protects the
Kindle.
The website states under “Product Description”
that “the reading light is located in the top righthand corner of the back cover.” Thus, the
Amazon product includes at least a “back cover”
that is distinguished by Amazon from the rest of
the “Kindle Lighted Leather Cover.”
The website states under “Product Description”
that the “cover is designed to fold back, so you
can read comfortably with just one hand.” Thus,
the Amazon product includes at least two
portions so that one portion can fold back onto
another portion.
Pictures from the website (provided below)
show at least a front cover and a back cover.

Thus, the Amazon product includes a protective
cover that includes a first cover and a second
cover, i.e., a front cover and a back cover.

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an interior surface, wherein a portion of the
interior surface of one of the first and second
covers is sized to secure the eReader, and

The website states under “Product Features” that
a “[s]oft, grey, microfiber suede interior protects
Kindle.”
The website also states under “On the Go” that
the “[t]his compact cover is perfect for taking
Kindle wherever you go” and that the “sleek
leather ensures the ultimate fit and protection,
without adding bulk or weight.”
The website has a picture (provided below) that
shows that a back cover is sized to secure the
Kindle.

Thus, the Amazon product includes an interior
surface, wherein a portion of the interior cover
of the back cover is sized to secure the Kindle.

an exterior surface

The website states under “Product Features” that
the “Kindle Lighted Leather Cover” includes
“stylish, genuine leather exterior” and a “[s]oft,
grey, microfiber suede interior…”
Thus, the Amazon product includes an exterior
surface.

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the protective cover having an axis around
which the interior surfaces of the first and
second covers are bendable, and

The website states under “Product Description”
that the “cover is designed to fold back, so you
can read comfortably with just one hand.”
A picture from the website shows a portion
defined by creases around which interior
surfaces of the front cover and the back cover
are bendable.

Thus, the Amazon product includes an axis
around which the interior surfaces of the front
and back covers are bendable.

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a pocket formed between the interior surface
and the exterior surface of one of the first and
second covers,

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
At least a portion of the light for the Amazon
product is disposed in a pocket in its “back
cover” between the interior and exterior of the
“back cover”.

Thus, the Amazon product includes a pocket
formed between the interior and exterior
surfaces of the back cover so that the light can
be pulled out from the pocket of the back cover.

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the pocket not traversing the axis and being
adjacent to an end of the interior surface and
in the portion of the interior surface sized to
secure the eReader,

The pocket for the light of the Amazon product
extends to a crease but does not traverse the
crease so that the Amazon product can “fold
back”.
The pocket for the light of the Amazon product
also extends from the crease to a corner of the
“back cover” or an end of an interior surface of
the back cover.

The website states under “On the Go” that the
“sleek leather ensures the ultimate fit and
protection, without adding bulk or weight.” The
website also has a picture (provided below) that
shows that a back cover is sized to secure the
Kindle.

Thus, the Amazon product includes a pocket,
wherein the pocket does not traverse the axis to
an end or corner of an interior surface and is in
the back cover which is sized to secure the
Kindle.

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wherein the pocket is formed at an angle with
respect to the axis; and

The pocket for the light of the Amazon product
extends from a middle portion of the crease to a
corner of the “back cover” and thus is formed at
an angle with respect to the crease of the
Amazon product.

Thus, the Amazon product includes a pocket,
wherein the pocket is formed at an angle with
respect to an axis.
a booklight including,

The website states under “Product Description”
that “[o]ur new design seamlessly incorporates a
reading light into the cover, so you can carry
your Kindle wherever you go and always have a
reading light with you.”

Thus, the Amazon product includes a booklight.

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a base coupled to a substantially flat portion
that is disposed within the pocket,

The light for the Amazon product includes at
least two portions. The first portion includes a
light housing assembly comprising a light
source, a neck extending from the light housing
assembly, and a base at the end of the neck
opposite the light housing assembly.

The second portion is flat and disposed within a
pocket formed between the interior and exterior
of the back cover.

Thus, the Amazon product includes a booklight
with a base coupled to a substantially flat
portion that is disposed within a pocket.

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the substantially flat portion including a slot
and the base including a protrusion received
by the slot so that the base is movably
coupled with the substantially flat portion,

The light for the Amazon product includes at
least two portions. The first portion includes a
light housing assembly comprising a light
source, a neck extending from the light housing
assembly, and a base at the end of the neck
opposite the light housing assembly. The base
includes two protrusions extending away from
the base, perpendicularly with respect to the
neck.

The second portion includes slots that receive
the two protrusions of the first portion,
respectively. The second portion is flat so that it
can be placed between the interior and exterior
of the back cover.
The protrusions of the first portion slide within
the slots of the second portion, respectively, so
that first portion is movably coupled with
respect to the flat second portion.

Thus, the Amazon product includes a booklight
with a substantially flat portion including a slot
and the base including a protrusion received by
the slot so that the base is movably coupled with
the substantially flat portion.

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a light housing assembly having a light
source, and

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
A picture on the website (provided below)
shows that the LED reading light includes a
light housing assembly comprising a light
source.

Thus, the Amazon product includes a booklight
comprising a light housing assembly having a
light source.

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a neck between the base and the light housing
assembly.

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
For the light of the Amazon product to “pull out
from the back cover when needed”, the light of
the Amazon product includes a neck between its
base and light housing assembly.

Thus, the Amazon product includes a booklight
with a neck between a base and a light housing
assembly.

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Claim 7: The cover assembly for an eReader
according to claim 6, wherein the pocket is
coupled to the interior surface.

The website under “Product Features” states that
a “built-in, retractable LED reading light pulls
out from the back cover when needed, and slides
away to become invisible when not in use.” The
light for the Amazon product is in a pocket
between the interior and exterior of the “back
cover”. The pocket is formed as a part of the
interior of the “back cover”.

.
Thus, the Amazon product includes a pocket
that is coupled to its interior surface.

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Claim 8: A cover and light assembly, the
cover and light assembly comprising:

Amazon named the Amazon product as “Kindle
Lighted Leather Cover” and an Amazon website
for the Amazon product refers to the Amazon
product as “[o]ur all-new Kindle cover” under
“Product Description.”
The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”

Thus, the Amazon product is a cover and light
assembly.

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a protective cover including, a first and
second cover each including

The website states under “Product Features” that
a “[s]oft, grey, microfiber suede interior protects
Kindle.” The website states under “Product
Description” that the “contoured, pebble-grain
leather (available in 7 different colors) keeps
your Kindle safe and secure, while the soft
charcoal microfiber interior protects the screen
from scratches.” Thus, the Amazon product has
an interior, an exterior, or both that protects the
Kindle.
The website states under “Product Description”
that “the reading light is located in the top righthand corner of the back cover.” Thus, the
Amazon product includes at least a “back cover”
that is distinguished by Amazon from the rest of
the “Kindle Lighted Leather Cover.”
The website states under “Product Description”
that the “cover is designed to fold back, so you
can read comfortably with just one hand.” Thus,
the Amazon product includes at least two
portions so that one portion can fold back onto
another portion.
Pictures from the website (provided below)
show at least a front cover and a back cover.

Thus, the Amazon product includes a protective
cover that includes a first cover and a second
cover, i.e., a front cover and a back cover.

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an exterior surface and an interior surface,

The website states under “Product Features” that
the “Kindle Lighted Leather Cover” includes
“stylish, genuine leather exterior” and a “[s]oft,
grey, microfiber suede interior…”
Thus, the Amazon product has a protective
cover that includes a leather exterior surface and
a suede interior surface.

and an axis around which the interior surfaces
of the first and second covers are bendable,
and

The website states under “Product Description”
that the “cover is designed to fold back, so you
can read comfortably with just one hand.”
A picture from the website shows a portion
defined by creases around which interior
surfaces of the front cover and the back cover
are bendable.

Thus, the Amazon product includes an axis
around which the interior surfaces of the front
and back covers are bendable.

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a pocket formed between the exterior surface
and at least a portion of the interior surface of
one of the first and second covers,

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
At least a portion of the light for the Amazon
product is disposed in a pocket in its “back
cover” between the interior and exterior of the
“back cover”.

Thus, the Amazon product includes a pocket
formed between the exterior surface and at least
a portion of the interior surface of the back
cover.

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the pocket not traversing the axis and having
an opening formed at an edge of the interior
surface; and

The pocket for the light of the Amazon product
extends to a crease but does not traverse the
crease so that the Amazon product can “fold
back” for reading with just one hand.
The pocket for the light of the Amazon product
also extends from the crease to an opening in a
corner of the “back cover” or an edge of an
interior surface of the back cover. The light is
pulled from the opening at the corner of the
back cover.

Thus, the Amazon product includes a pocket,
wherein the pocket does not traverse the axis
and has an opening formed at an edge or corner
of an interior surface of the back corner.

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a light including,

The website states under “Product Description”
that “[o]ur new design seamlessly incorporates a
reading light into the cover, so you can carry
your Kindle wherever you go and always have a
reading light with you.”

Thus, the Amazon product includes a light.

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a planar base disposed within the pocket and
having a slot,

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
The light for the Amazon product includes at
least two portions. The first portion includes a
light housing comprising a light source, a neck
extending from the light housing, and a movable
base at the end of the neck opposite the light
housing. The movable base of the first portion
includes at least two protrusions at opposite
sides of the movable base and extending away
from the movable base.
The second portion includes slots that receive
the two protrusions of the first portion,
respectively. The second portion is also placed
in the “back cover” between its interior and
exterior. Thus, in order to fit in the back cover
between its interior and exterior, the second
portion is planar.

Thus, the Amazon product has a light that
includes a planar base disposed within a pocket
of the back cover and having a slot.

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a movable base with a protrusion that is
received by the slot of the planar base so that
the movable base is movably coupled to the
planar base,

The light for the Amazon product includes at
least two portions. The first portion includes a
light housing comprising a light source, a neck
extending from the light housing, and a movable
base at the end of the neck opposite the light
housing. The movable base of the first portion
includes at least two protrusions at opposite
sides of the movable base and extending away
from the movable base.

The second portion includes slots that receive
the two protrusions of the first portion,
respectively, so that the movable base of the
first portion is movably coupled to the planar
second portion.
Thus, the Amazon product has a light that
includes a movable base with a protrusion that is
received by a slot of a planar base so that the
movable base is movably coupled to the planar
base.

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a neck extending from the movable base, and

The light for the Amazon product includes at
least two portions. The first portion includes a
light housing and a neck extending from the
light housing.

Thus, the Amazon product has a light that
includes a neck extending from a movable base.
a light housing disposed at a distal end of the
neck.

The light for the Amazon product includes at
least two portions. The first portion includes a
light housing, a neck extending from the light
housing, and a movable base at the end of the
neck opposite the light housing.

Thus, the Amazon product has a light that
includes a light housing disposed at a distal end
of the neck.

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Claim 9: The cover and light assembly
according to claim 8, wherein the movable
base has a first position with respect to the
planar base, and in the first position, the light
housing is in a stored position.

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
Thus, the Amazon product has a light that
includes a movable base that has a first position
with respect to a planar base, and in the first
position, a light housing is in a stored position.

Claim 10: The cover and light assembly
according to claim 8, wherein the movable
base has a second position with respect to the
planar base, and in the second position, the
light housing is in a lighting position.

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
Thus, the Amazon product has a light that
includes a movable base that has a second
position with respect to a planar base, and in the
second position, a light housing is in a lighting
position.

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Claim 11: The cover and light assembly
according to claim 8, wherein the pocket is
formed between the exterior surface and a
corner portion of the interior surface.

The light for the Amazon product is in a pocket
between the interior and exterior of the “back
cover”.
The pocket for the light of the Amazon product
extends from a crease that allows the Amazon
product to “fold back” to a corner of the “back
cover”.

Thus, the Amazon product has a pocket wherein
the pocket is formed between an exterior surface
and a corner portion of an interior surface.

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Claim 12: The cover and light assembly
according to claim 8, wherein the exterior
cover is sized to wrap around an eReader.

The website states under “On the Go” that the
“[t]his compact cover is perfect for taking
Kindle wherever you go” and that the “sleek
leather ensures the ultimate fit and protection,
without adding bulk or weight.”
Pictures from the website (provided below)
show an exterior cover that is sized to wrap
around the Kindle “without adding bulk or
weight.”

Thus, the Amazon product has an exterior cover
wherein the exterior cover is sized to wrap
around an eReader.

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Claim 13: The cover and light assembly
according to claim 8, wherein the interior
surface includes at least one mounting device
disposed on the interior surface.

The website states under “How It Works” that
“[i]n addition to securing Kindle in place, our
new hinge system conducts electricity from
Kindle’s battery to the reading light – when
Kindle is attached to the hinge, an electrical
connection is formed that powers the light.”
The website also includes diagrams to show
how to secure Kindle to the “new hinge
system.”
A picture from the website (provided below)
shows the hinge system.

Thus, the Amazon product has an interior
surface wherein the interior surface includes at
least one mounting device disposed on the
interior surface.

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Claim 14: The cover and light assembly
according to claim 8, wherein the interior
surface and the exterior surface form a first
cover and a second cover and the pocket is
formed in one of the first cover and the
second cover.

The website states under “Product Description”
that “the reading light is located in the top righthand corner of the back cover.” Thus, the
Amazon product includes at least a “back cover”
that is distinguished from the rest of the “Kindle
Lighted Leather Cover.”
The website states under “Product Description”
that the “cover is designed to fold back, so you
can read comfortably with just one hand.” Thus,
the Amazon product includes at least two
portions so that one portion can fold back onto
another portion. Pictures from the website show
at least a front cover and a back cover.
The light for the Amazon product is in a pocket
in its “back cover” between the interior and
exterior of the back cover.

Thus, the Amazon product has an interior
surface and an exterior surface, wherein the
interior surface and the exterior surface form a
first cover and a second cover, i.e., a front cover
and a back cover, and the pocket is formed in
the back cover.

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Claim 15: The cover and light assembly
according to claim 8, wherein the pocket is
formed at an angle with respect to the axis.

As described above, interior of Amazon product
includes a crease that allows the cover to fold
back for reading with just one hand, and thus,
the Amazon product includes an axis
The pocket for the Amazon product extends
from a middle portion of the crease to a corner
of the “back cover” and thus is formed at an
angle with respect to the crease of the Amazon
product.

Thus, the Amazon product includes a pocket
formed at an angle with respect to an axis.

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Claim 16: The cover and light assembly
according to claim 8, wherein the pocket is
coupled to the interior surface.

As described above, the light for the Amazon
product is in a pocket between the interior and
exterior of the “back cover”. The pocket is
formed as a part of the interior of the “back
cover”.

.
Thus, the Amazon product includes a pocket
that is coupled to its interior surface.

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Claim 17: A cover and light assembly, the
cover and light assembly comprising:

Amazon named the Amazon product as “Kindle
Lighted Leather Cover” and an Amazon website
for the Amazon product refers to the Amazon
product as “[o]ur all-new Kindle cover” under
“Product Description.”
The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”

Thus, the Amazon product is a cover and light
assembly.

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a protective cover including, a first and
second cover each including

The website states under “Product Features” that
a “[s]oft, grey, microfiber suede interior protects
Kindle.” The website also states under “Product
Description” that the “contoured, pebble-grain
leather (available in 7 different colors) keeps
your Kindle safe and secure, while the soft
charcoal microfiber interior protects the screen
from scratches.” Thus, the Amazon product has
an interior, an exterior, or both that protects the
Kindle.
The website states under “Product Description”
that “the reading light is located in the top righthand corner of the back cover.” Thus, the
Amazon product includes at least a “back cover”
that is distinguished by Amazon from the rest of
the “Kindle Lighted Leather Cover.”
The website states under “Product Description”
that the “cover is designed to fold back, so you
can read comfortably with just one hand.” Thus,
the Amazon product includes at least two
portions so that one portion can fold back onto
another portion.
Pictures from the website (provided below)
show at least a front cover and a back cover.

Thus, the Amazon product includes a protective
cover that includes a first cover and a second
cover, i.e., a front cover and a back cover.

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an exterior surface, an interior surface,

The website states under “Product Features” that
the “Kindle Lighted Leather Cover” includes
“stylish, genuine leather exterior” and a “[s]oft,
grey, microfiber suede interior…”
Thus, the Amazon product has a protective
cover that includes a leather exterior surface and
a suede interior surface.

the protective cover having an axis around
which the interior surfaces of the first and
second covers are bendable, and

The website states under “Product Description”
that the “cover is designed to fold back, so you
can read comfortably with just one hand.”
A picture from the website shows a portion
defined by creases around which interior
surfaces of the front cover and the back cover
are bendable.

Thus, the Amazon product includes an axis
around which the interior surfaces of the front
and back covers are bendable.

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a pocket formed between the exterior surface
and a corner portion of the interior surface of
one of the first and second covers and
extending away from the axis,

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
At least a portion of the light for the Amazon
product is disposed in a pocket in its “back
cover” between the interior and exterior of the
“back cover”.
The pocket for the light of the Amazon product
extends to a crease but does not traverse the
crease so that the Amazon product can “fold
back” for reading with just one hand.
The pocket for the light of the Amazon product
also extends away from the crease to an opening
in a corner of an interior surface of the “back
cover” so that the light can be pulled from the
opening at the corner of the back cover.

Thus, the Amazon product includes a pocket
formed between an exterior surface and a corner
portion of an interior surface of the back cover
and extends away from an axis.

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the pocket being formed with two opposing
surfaces at an angle with respect to the axis,

The pocket for the light of the Amazon product
is formed between an interior and exterior
surface of the Amazon product. The interior
and exterior surfaces form two opposing
surfaces in the pocket.
Also, the website states under “Product
Description” that the “cover is designed to fold
back, so you can read comfortably with just one
hand.” The interior of Amazon product includes
a crease that allows the cover to fold back for
reading with just one hand. Thus, the Amazon
product includes an axis.
The pocket for the light of the Amazon product
extends from a middle portion of the crease to a
corner of the “back cover” and thus is formed at
an angle with respect to the crease of the
Amazon product.

Thus, the Amazon product includes a pocket
formed with two opposing surfaces at an angle
with respect to an axis.

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the pocket being formed with at least one
opening at an end of the two opposing
surfaces; and

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
The pocket for the light of the Amazon product
has an opening, from which the light can be
pulled, at an end of the interior and exterior
surfaces that form the opposing surfaces of the
pocket.

Thus, the Amazon product includes a pocket
formed with at least one opening at an end of the
two opposing surfaces.

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a light including,

The website states under “Product Description”
that “[o]ur new design seamlessly incorporates a
reading light into the cover, so you can carry
your Kindle wherever you go and always have a
reading light with you.”

Thus, the Amazon product includes a light.

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an elongated planar base disposed within the
pocket between the two opposing surfaces of
the pocket,

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
The light for the Amazon product includes at
least two portions that provide for the pulling
out and sliding away of the light. One portion is
placed in the “back cover” between its interior
and exterior. In order to fit in the back cover
between its interior and exterior, the second
portion has an elongated, planar shape.
The interior and exterior surfaces of the back
cover form the opposing surfaces of the pocket.

Thus, the Amazon product has a light that
includes an elongated planar base disposed
within a pocket between two opposing surfaces
of the pocket.

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the elongated planar base having a slot,

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
The light for the Amazon product includes at
least two portions that provide for the pulling
out and sliding away of the light. The first
portion includes a light housing, a neck
extending from the light housing, and a movable
base at the end of the neck opposite the light
housing. The movable base of the first portion
includes at least two protrusions at opposite
sides of the movable base and extending away
from the movable base.
The second portion includes slots that receive
the two protrusions of the first portion.

Thus, the Amazon product has a light that
includes an elongated planar base having a slot.

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the elongated planar base being sized to be
received between the two opposing surfaces
of the pocket and the at least one opening at
the end of the two opposing surfaces,

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
The light for the Amazon product includes at
least two portions that provide for the pulling
out and sliding away of the light. One portion is
placed in the “back cover” between its interior
and exterior. Thus, in order to fit in the back
cover between its interior and exterior, the
second portion has an elongated, planar shape.

The elongated planar base is also sized to be
received between opposing surfaces of a pocket
formed by the interior and exterior surfaces of
the back cover. Furthermore, the elongated
planar base is sized to be received in an opening
in the corner of the back cover, from which the
light can be pulled out.
Thus, the Amazon product has a light that
includes an elongated planar base sized to be
received between two opposing surfaces of a
pocket and at least one opening at an end of the
two opposing surfaces.

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a movable base that moves with respect to the
elongated planar base, the movable base
having a protrusion that is received by the slot
of the elongated planar base so that the
movable base is movably coupled to the
elongated planar base,

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
The light for the Amazon product includes at
least two portions that provide for the pulling
out and sliding away of the light from the back
cover.
The first portion includes a light housing, a neck
extending from the light housing, and a movable
base at the end of the neck opposite the light
housing. The movable base includes at least
two protrusions.

A second portion of the light for the Amazon
product includes slots that receive the two
protrusions of the first portion, respectively, so
that the movable base of the first portion is
movably coupled to the elongated planar second
portion.
Therefore, the Amazon product includes a light
with a movable base that moves with respect to
an elongated planar base, and the movable base
has a protrusion that is received by a slot of the
elongated planar base so that the movable base
is movably coupled to the elongated planar base.

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a neck extending from the movable base, and

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
For the light of the Amazon product to “pull out
from the back cover when needed”, the light of
the Amazon product includes a neck between its
base and light housing.

Thus, the Amazon product includes a light with
a neck extending from a movable base.

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a light housing disposed at a distal end of the
neck and including a light adapted to light at
least a portion of the interior surface of the
cover,

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
A picture on the website (provided below)
shows that the LED reading light includes a
light housing with a light source.

Another picture from the website (provided
below) shows the light lighting at least a portion
of the interior surface of the cover.

Thus, the Amazon product includes a light with
a light housing disposed at a distal end of the
neck and including a light adapted to light at
least a portion of the interior surface of the
cover.

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wherein the movable base has at least a first
position and a second position with respect to
the elongated planar base, and in the first
position, the light housing is in a stored
position, and in the second position, the light
housing is in a lighting position.

The website under “Product Features” states that
the Amazon product includes a “built-in,
retractable LED reading light” that “pulls out
from the back cover when needed, and slides
away to become invisible when not in use.”
As described above, the light for the Amazon
product includes at least two portions that
provide for the pulling out and sliding away of
the light from the back cover. When a movable
base is inserted into the back cover and thus in a
first position with respect to an elongated planar
base in the back cover, the light housing is in a
stored position. When the movable base is
pulled away from the back cover, the movable
base is in a second position with respect to the
elongated planar base and in a lighting position.
Thus, the Amazon product includes a light
wherein a movable base has at least a first
position and a second position with respect to an
elongated planar base, and in the first position,
the light housing is in a stored position, and in
the second position, the light housing is in a
lighting position.

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