WI-LAN Inc. v. Alcatel-Lucent USA Inc. et al

Filing 212

MOTION for Protective Order by Sony Mobile Communications (USA) Inc., Sony Mobile Communications AB. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Text of Proposed Order)(Wynne, Richard)

EXHIBIT D

onson&Elkins
Ajeet P Pai apai@velaw com
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May 31, 2012

Via Email
Richard L. Wynne, Jr.
Thompson & Knight LLP
1722 Routh Street, Suite 1500
Dallas, Texas 75201
Re:

Wi-LANv. Alcatel-Lucent USA et al. (10-cv-521) (E.D. Tex.)
Infringement Contentions / Sony and Ericsson Productions

Dear Rich:
As you will recall, Wi-LAN's preliminary infringement contentions include "all other
[Sony/Ericsson] products which are reasonably similar in structure and/or operation" to the
listed products. The products identified in Wi-LAN's response to Defendants' Common
Interrogatory No. 4 (many of which were released by Sony or Ericsson after Wi-LAN's
preliminary infringement contentions were served) are such products and indeed infringe
because they implement the same functionality described in the standards listed in those
contentions. Accordingly, all these products are already included within Wi-LAN's
preliminary infringement contentions. That said, we reserve our right to supplement those
contentions as appropriate under P.R. 3-6(a) without leave of Court.

Ajeet P. Pai

US 1421403

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