WI-LAN Inc. v. Alcatel-Lucent USA Inc. et al
Filing
484
RESPONSE in Opposition re 475 MOTION for Attorney Fees filed by WI-LAN Inc.. (Attachments: # 1 Exhibit A - July 9 PM Tr, # 2 Exhibit B - 2013-03-21 Pre-Trial Hearing Transcript, # 3 Exhibit C - July 10 AM Tr, # 4 Exhibit D - Lanning report excerpt, # 5 Exhibit E - Email from Justin Cohen to Ajeet Pai (June 23, 2013), # 6 Exhibit F - July 12 AM Tr, # 7 Text of Proposed Order)(Weaver, David)
Exhibit E
Han, Jeff
From:
Sent:
To:
Cc:
Subject:
Cohen, Justin S.
Sunday, June 23, 2013 10:26 PM
Pai, Ajeet
Wi-LAN; 'wh@wsfirm.com'; Ericsson: WI LAN Defense; 'LegalTm-WiLANHTC@sheppardmullin.com'; 'Alcatel-Lucent-Wi-LAN-Defense@kirkland.com'
RE: Wi-LAN v Alcatel-Lucent et al / Proposal to narrow case
Counsel – this confirms Defendants’ list of prior art references to prove that the asserted claims are invalid. We reserve
the right, however, to present other documents, including prior‐art references, for other purposes.
1. U.S. Patent No. 6,018,528
2. “Spread Spectrum and Time Division Multiple Access Satellite Communications” by Mohanty
3. TIA/EIA IS‐95‐A Standard
4. U.S. Patent No. 6,112,080
5. PCT Application WO 95/03652
6. U.S. Patent No. 5,533,013
7. “CDMA for Cellular and PCS” by Tiedemann
8. “The PCS CDMA System Overview” by Zehavi and Tiedemann
From: Cohen, Justin S.
Sent: Sunday, June 23, 2013 5:02 PM
To: Pai, Ajeet
Cc: Wi-LAN; 'wh@wsfirm.com'; Ericsson: WI LAN Defense; 'LegalTm-WiLAN-HTC@sheppardmullin.com'; 'AlcatelLucent-Wi-LAN-Defense@kirkland.com'
Subject: RE: Wi-LAN v Alcatel-Lucent et al / Proposal to narrow case
Counsel – per the parties’ agreement, the Defendants identify the following prior art references to prove that
the asserted claims are invalid. We reserve the right, however, to present other documents, including prior‐art
references, for other purposes.
Due to traveling schedules, we have not been able to obtain final approval of this list from lead counsel for all
defendants. Therefore, we may need to substitute no more than one or two references. Rather than asking to
extend the deadline (due to the difficulties of getting in touch with everyone on a Sunday), we wanted to
provide a preliminary list now. We will confirm the list no later than midnight tonight.
1. U.S. Patent 6,018,528
2. “Spread Spectrum and Time Division Multiple Access Satellite Communications” by Mohanty
3. TIA/EIA IS‐95‐A Standard
4. PCT Application WO 93/15573
5. PCT Application WO 95/03652
6. U.S. Patent No. 5,533,013
7. “CDMA for Cellular and PCS” by Tiedemann
8. “The PCS CDMA System Overview” by Zehavi and Tiedemann
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