Mirror Worlds, LLC v. Apple, Inc.

Filing 377

REPLY to Response to Motion re #309 MOTION To Limit the Number of Asserted Claims filed by Apple, Inc.. (Attachments: #1 Affidavit Supplemental Declaration of Jeffrey G. Randall, #2 Exhibit I, #3 Exhibit J)(Randall, Jeffrey)

Mirror Worlds, LLC v. Apple, Inc.

Doc. 377 Att. 2

SUPPLEMENTAL DECLARATION OF JEFFREY G. RANDALL

EXHIBIT I

Dockets.Justia.com

Page 1 of 1

From: Sent: To: Cc:

Solo, Alex [[e-mail]] Friday, August 20, 2010 11:54 AM Mirror Worlds MW_v_Apple

Subject: Meet and Confer

Christian, Is anyone from your team available for a short meet and confer this afternoon? As you know, Mirror Worlds is planning on filing a motion to limit Apple's prior art and prior art obviousness combinations to be presented at trial. While we are looking forward to having a fruitful discussion regarding an amicable resolution of these issues on Monday (when we will provide Apple with our proposed claims for trial), Apple's motion to limit claims forces Mirror Worlds to move to preserve our rights in the event that no resolution is reached. Based on our anticipated reduction of claims to about 18, and due to the commonality of disclosure among the Mirror Worlds' patents and the fact that the `999 patent has a single claim, we anticipate moving the court to limit Apple to one primary reference per patent, and three secondary references, with no more than a total of 5 obviousness combinations for all patents. Of course, should the Court restrict Mirror Worlds to fewer claims, we would seek to further limit Apple's prior art. Regards, Alex
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