Nokia Corporation v. Apple Inc.

Filing 22

Declaration of Coby S. Nixon filed by Plaintiff Nokia Corporation in Support of Brief in Opposition to Dkt 12 re: 12 Motionto Transfer to District of Delaware filed by Apple Inc. (Attachments: # 1 Exhibit 1 - Complaint dated 10-22-09, # 2 Exhibit 2 - Apple's First Amended Answer, # 3 Exhibit 3 - Joint Status Report 3-8-10, # 4 Exhibit 4 - 854 Patent - Order Granting Request, # 5 Exhibit 5 - 105 Patent-Order Granting Request, # 6 Exhibit 6 - 703 Patent-Order Granting Request, # 7 Exhibit 7 - 074 Patent-Order Granting Request, # 8 Exhibit 8 - 381 Patent-Order Granting Request, # 9 Exhibit 9 - Notice of Filing Date-Apple 034, # 10 Exhibit 10 - Notice of Filing Date-Apple 795, # 11 Exhibit 11 - Notice of Filing Date-453 Patent, # 12 Exhibit 12 - 3-11-10 Nokia's Motion to Dismiss, # 13 Exhibit 13 - 7-2-10 Nokia's Opening Brief, # 14 Exhibit 14 - Nokia's First Proposed Amended Complaint, # 15 Exhibit 15 - 4-30-10 Scheduling Order, # 16 Exhibit 16 - 701 Complaint 12-29-09, # 17 Exhibit 17 - 12-29-10 Complaint 1002, # 18 Exhibit 18 - 704 Complaint 1-15-10, # 19 Exhibit 19 - 2-12-10 Stipulation and Order to Stay, # 20 Exhibit 20 - 1002 3-3-10 Stipulation and Order to Stay, # 21 Exhibit 21 - 5-24-10 Motion to Consolidate, # 22 Exhibit 22 - 6-21-10 Answering Brief, # 23 Exhibit 23 - 6-21-10 HTC's Answering Brief in Opposition, # 24 Exhibit 24 - Judicial Case Load Profile - Delaware, # 25 Exhibit 25 - Judicial Case Load Profile - WD Wis, # 26 Exhibit 26 - First Amended Complaint - Apple v. Creative Labs, # 27 Exhibit 27 - Complaint in Apple v HTC 10-166, # 28 Exhibit 28 - Complaint in Apple v. HTC 10-544, # 29 Exhibit 29 - Complaint in Apple v. HTC 10-167, # 30 Exhibit 30 - Nokia Counterclaims in Qualcomm v Nokia, # 31 Exhibit 31 - Nokia's Motion to Transfer, # 32 Exhibit 32 - US 6373345, # 33 Exhibit 33 - US 6359904) (Scheller, John)

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Nokia Corporation v. Apple Inc. Doc. 22 Att. 30 Exhibit 30 Nokia's Counterclaims and Demand for Trial by Jury dated May 23, 2007. Dockets.Justia.com IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN QUALCOMM INCORPORATED, Plaintiff, v. NOKIA CORPORATION and NOKIA, INC., Defendants. COUNTERCLAIMS OF NOKIA CORPORATION AND NOKIA, INC. AND DEMAND FOR TRIAL BY JURY CASE NO. 07 C 0187 C Defendants and Counterclaimants Nokia Corporation and Nokia, Inc., for their counterclaims against Plaintiff and Counterclaim Defendant QUALCOMM Incorporated ("Qualcomm"), allege the following: THE PARTIES 1. Defendant and Counterclaimant Nokia Corporation is a Finnish corporation having its principal place of business at Keilalahdentie 4, P.O. Box 226, FIN-00045 Espoo, Finland. Nokia Corporation owns by assignment the entire right, title, and interest in and to each of the Asserted Patents. 2. Defendant and Counterclaimant Nokia, Inc. is a corporation organized under the laws of Delaware and headquartered in Irving, Texas. Nokia, Inc. is a subsidiary of Nokia Corporation. 3. Defendant Qualcomm is a corporation existing under the laws of the state of Delaware, with its principal place of business at 5775 Morehouse Drive, San Diego, California, 92121. 20300/2127053.10300/2124645.1 1 JURISDICTION AND VENUE 4. This Court has subject matter jurisdiction over the Counterclaims of Nokia Corporation and Nokia, Inc. under the patent laws of the United States, Title 35, United States Code, §§ 1 et seq. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a) because this case arises out of the federal patent laws. 5. By filing its Complaint, Qualcomm has consented to the personal jurisdiction of this Court. Nokia Corporation and Nokia, Inc. are also informed and believe and thereon allege that Qualcomm is doing business in Wisconsin and in this district. 6. Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(b) and 1391(c) and/or 28 U.S.C. § 1400(b). THE PATENTS-IN-SUIT 7. On April 18, 2006, U.S. Patent No. 7,031,687 (the "'687 Patent"), entitled "Balanced Circuit Arrangement and Method for Linearizing Such an Arrangement," was duly and legally issued to the inventors Kalle Kivekäs and Aarno Pärssinen and is assigned to Nokia Corporation. A true and correct copy of the '687 Patent is attached hereto as Exhibit A. 8. On December 19, 2006, U.S. Patent No. 7,151,915 (the "'915 Patent"), entitled "Dual Mode Voltage Controlled Oscillator Having Controllable Bias Modes and Power Consumption," was duly and legally issued to the inventors Jarmo Heinonen, Vesa Viitaniemi, Kai Leino, and Jyrki Koljonen and is assigned to Nokia Corporation. A true and correct copy of the '915 Patent is attached hereto as Exhibit B. 9. On September 5, 2000, U.S. Patent No. 6,115,593 (the "'593 Patent'), entitled "Elimination of D.C. Offset and Spurious AM Suppression in a Direct Conversion Receiver," was duly and lawfully issued to the inventors Petteri Alinikula, Hans-Otto Scheck, 20300/2127053.10300/2124645.1 2 and Kari-Pekka Estola and is assigned to Nokia Corporation. A true and correct copy of the '593 Patent is attached hereto as Exhibit C. 10. On September 18, 2001, U.S. Patent No. 6,292,474 (the "'474 Patent"), entitled "Multi-Frequency Band Multi-Mode Radio Receiver and Associated Method Having Shared Circuit Elements," was duly and lawfully issued to the inventors Fazal Ali, Thomas C. Wakeham, and Konstantina A. Rovos and is assigned to Nokia Corporation. A true and correct copy of the '474 Patent is attached hereto as Exhibit D. 11. On March 30, 2004, U.S. Patent No. 6,714,091 (the "'091 Patent"), entitled "VCO with Programmable Output Power," was duly and lawfully issued to the inventors Soren Norskov, Carsten Rasmussen, and Niels Thomas Hedegaard Povlsen and is assigned to Nokia Corporation. A true and correct copy of the '091 Patent is attached hereto as Exhibit E. 12. On April 27, 1999, U.S. Patent No. 5,898,740 (the "'740 Patent"), entitled "Power Control Method in a Cellular Communication System, and a Receiver," was duly and lawfully issued to the inventors Timo Laakso and Hannu Hakkinen and is assigned to Nokia Corporation. A true and correct copy of the '740 Patent is attached hereto as Exhibit F. 13. The '687, '915, '593, '474, '091, and '740 Patents described in paragraphs 7 through 12 above, are herein referred to collectively as "Nokia's Patents-in-Suit." Nokia's Patents-in-Suit relate generally to technology used, for example, to reduce the battery consumption, size and cost of and to improve the performance and efficiency of wireless communication devices. QUALCOMM'S INFRINGEMENT OF NOKIA'S PATENTS-IN-SUIT 14. On information and belief, Qualcomm manufactures, uses, sells, offers for sale in the United States, and/or imports into the United States chipsets and/or other products that practice one or more of the claims of Nokia's Patents-in-Suit ("Qualcomm Products"). 20300/2127053.10300/2124645.1 3 15. On information and belief, Qualcomm directly or indirectly infringes, literally and/or under the doctrine of equivalents, Nokia's Patents-in-Suit, pursuant to 35 U.S.C. §§ 271(a), (b), (c) and/or (f), by making, using, selling, offering for sale, and/or importing to the United States Qualcomm Products that practice one or more of the claims of Nokia's Patents-inSuit and/or by practicing one or more of the claimed methods of Nokia's Patents-in-Suit. FIRST COUNTERCLAIM (OF NOKIA CORPORATION) (INFRINGEMENT OF THE '687 PATENT) 16. Nokia Corporation realleges and incorporates by reference each and every allegation contained in paragraphs 1 through 15 as if fully set forth herein. 17. On information and belief, Qualcomm makes, uses, sells, or offers for sale in the United States, and/or imports into the United States Qualcomm devices, including but not limited to at least one of the following Qualcomm devices: RFR6120, RFR6122, RFR6125, RFR6185, RFR6220, RFR6250, RFR6275, RFR6500, QTP-6800, TM7200 and/or TM6280 that, alone and/or in combination with other devices, directly and/or indirectly infringes and is continuing to infringe, literally and/or under the doctrine of equivalents, the '687 Patent directly or indirectly in violation of 35 U.S.C. § 271. 18. On information and belief, Qualcomm has infringed and is continuing to infringe the '687 Patent by contributing to and/or inducing the infringement by others of claims of the '687 Patent in violation of 35 U.S.C. § 271. 19. As a result of Qualcomm's direct and/or indirect infringement of the '687 Patent, Nokia Corporation has suffered and continues to suffer injury to its business, property, and patent rights, for which Nokia Corporation is entitled to damages pursuant to 35 U.S.C. § 284 in an amount to be proved at trial. 20300/2127053.10300/2124645.1 4 20. Unless Qualcomm is enjoined by this Court from continuing its infringement of the '687 Patent, Nokia Corporation will suffer additional irreparable harm and impairment of the value of its patent rights for which there is no adequate remedy at law. Thus, Nokia Corporation is entitled to an injunction against further infringement of the '687 Patent pursuant to 35 U.S.C. § 283. 21. Qualcomm's acts of infringement of the '687 Patent have been and continue to be willful, entitling Nokia Corporation to treble damages pursuant to 35 U.S.C. § 284. In addition, Qualcomm's willful infringement qualifies this case as an exceptional case pursuant to 35 U.S.C. § 285. SECOND COUNTERCLAIM (OF NOKIA CORPORATION) (INFRINGEMENT OF THE '915 PATENT) 22. Nokia Corporation realleges and incorporates by reference each and every allegation contained in paragraphs 1 through 21 as if fully set forth herein. 23. On information and belief, Qualcomm makes, uses, sells, or offers for sale in the United States, and/or imports into the United States Qualcomm devices, including but not limited to at least one of the following Qualcomm devices: RFR6500, RTR6250, RFT6150, QTP6800 and/or TM7200 that, alone and/or in combination with other devices, directly and/or indirectly infringes and is continuing to infringe, literally and/or under the doctrine of equivalents, the '915 Patent directly or indirectly in violation of 35 U.S.C. § 271. 24. On information and belief, Qualcomm has infringed and is continuing to infringe the '915 Patent by contributing to and/or inducing the infringement by others of claims of the '915 Patent in violation of 35 U.S.C. § 271. 25. As a result of Qualcomm's direct and/or indirect infringement of the '915 Patent, Nokia Corporation has suffered and continues to suffer injury to its business, property, 20300/2127053.10300/2124645.1 5 and patent rights, for which Nokia Corporation is entitled to damages pursuant to 35 U.S.C. § 284 in an amount to be proved at trial. 26. Unless Qualcomm is enjoined by this Court from continuing its infringement of the '915 Patent, Nokia Corporation will suffer additional irreparable harm and impairment of the value of its patent rights for which there is no adequate remedy at law. Thus, Nokia Corporation is entitled to an injunction against further infringement of the '915 Patent pursuant to 35 U.S.C. § 283. 27. Qualcomm's acts of infringement of the '915 Patent have been and continue to be willful, entitling Nokia Corporation to treble damages pursuant to 35 U.S.C. § 284. In addition, Qualcomm's willful infringement qualifies this case as an exceptional case pursuant to 35 U.S.C. § 285. THIRD COUNTERCLAIM (OF NOKIA CORPORATION) (INFRINGEMENT OF THE '593 PATENT) 28. Nokia Corporation realleges and incorporates by reference each and every allegation contained in paragraphs 1 through 27 as if fully set forth herein. 29. On information and belief, Qualcomm makes, uses, sells, or offers for sale in the United States, and/or imports into the United States Qualcomm devices, including but not limited to at least one of the following Qualcomm devices: RFR6185, RFR6275, RFR6250, RFR6500, QTP-6800, TM7200 and/or TM6280 that, alone and/or in combination with other devices, directly and/or indirectly infringes and is continuing to infringe, literally and/or under the doctrine of equivalents, the '593 Patent directly or indirectly in violation of 35 U.S.C. § 271. 30. On information and belief, Qualcomm has infringed and is continuing to infringe the '593 Patent by contributing to and/or inducing the infringement by others of the '593 Patent in violation of 35 U.S.C. § 271. 20300/2127053.10300/2124645.1 6 31. As a result of Qualcomm's direct and/or indirect infringement of the '593 Patent, Nokia Corporation has suffered and continues to suffer injury to its business, property, and patent rights, for which Nokia Corporation is entitled to damages pursuant to 35 U.S.C. § 284 in an amount to be proved at trial. 32. Unless Qualcomm is enjoined by this Court from continuing its infringement of the '593 Patent, Nokia Corporation will suffer additional irreparable harm and impairment of the value of its patent rights for which there is no adequate remedy at law. Thus, Nokia Corporation is entitled to an injunction against further infringement of the '593 Patent pursuant to 35 U.S.C. § 283. 33. Qualcomm's acts of infringement of the '593 Patent have been and continue to be willful, entitling Nokia Corporation to treble damages pursuant to 35 U.S.C. § 284. In addition, Qualcomm's willful infringement qualifies this case as an exceptional case pursuant to 35 U.S.C. § 285. FOURTH COUNTERCLAIM (OF NOKIA CORPORATION) (INFRINGEMENT OF THE '474 PATENT) 34. Nokia Corporation realleges and incorporates by reference each and every allegation contained in paragraphs 1 through 33 as if fully set forth herein. 35. On information and belief, Qualcomm makes, uses, sells, or offers for sale in the United States, and/or imports into the United States Qualcomm devices, including but not limited to at least one of the following Qualcomm devices: RFR6185, RFR6275, RFR6250, RFR6500, RTR6250, RTR6300, QTP-6800, TM7200 and/or TM6280 that, alone and/or in combination with other devices, directly and/or indirectly infringes and is continuing to infringe, literally and/or under the doctrine of equivalents, the '474 Patent directly or indirectly in violation of 35 U.S.C. § 271. 20300/2127053.10300/2124645.1 7 36. On information and belief, Qualcomm has infringed and is continuing to infringe the '474 Patent by contributing to and/or inducing the infringement by others of the '474 Patent in violation of 35 U.S.C. § 271. 37. As a result of Qualcomm's direct and/or indirect infringement of the '474 Patent, Nokia Corporation has suffered and continues to suffer injury to its business, property, and patent rights, for which Nokia Corporation is entitled to damages pursuant to 35 U.S.C. § 284 in an amount to be proved at trial. 38. Unless Qualcomm is enjoined by this Court from continuing its infringement of the '474 Patent, Nokia Corporation will suffer additional irreparable harm and impairment of the value of its patent rights for which there is no adequate remedy at law. Thus, Nokia Corporation is entitled to an injunction against further infringement of the '474 Patent pursuant to 35 U.S.C. § 283. 39. Qualcomm's acts of infringement of the '474 Patent have been and continue to be willful, entitling Nokia Corporation to treble damages pursuant to 35 U.S.C. § 284. In addition, Qualcomm's willful infringement qualifies this case as an exceptional case pursuant to 35 U.S.C. § 285. FIFTH COUNTERCLAIM (OF NOKIA CORPORATION) (INFRINGEMENT OF THE '091 PATENT) 40. Nokia Corporation realleges and incorporates by reference each and every allegation contained in paragraphs 1 through 39 as if fully set forth herein. 41. On information and belief, Qualcomm makes, uses, sells, or offers for sale in the United States, and/or imports into the United States Qualcomm devices, including but not limited to at least one of the following Qualcomm devices: RFR6120, RFR6125, RFR6220, RFR6250, RFR6500, RTR6250, RTR6300, RFT6150, QTP-6800, and/or TM7200 that, alone 20300/2127053.10300/2124645.1 8 and/or in combination with other devices, directly and/or indirectly infringes and is continuing to infringe, literally and/or under the doctrine of equivalents, the '091 Patent directly or indirectly in violation of 35 U.S.C. § 271. 42. On information and belief, Qualcomm has infringed and is continuing to infringe the '091 Patent by contributing to and/or inducing the infringement by others of the '091 Patent in violation of 35 U.S.C. § 271. 43. As a result of Qualcomm's direct and/or indirect infringement of the '091 Patent, Nokia Corporation has suffered and continues to suffer injury to its business, property, and patent rights, for which Nokia Corporation is entitled to damages pursuant to 35 U.S.C. § 284 in an amount to be proved at trial. 44. Unless Qualcomm is enjoined by this Court from continuing its infringement of the '091 Patent, Nokia Corporation will suffer additional irreparable harm and impairment of the value of its patent rights for which there is no adequate remedy at law. Thus, Nokia Corporation is entitled to an injunction against further infringement of the '091 Patent pursuant to 35 U.S.C. § 283. 45. Qualcomm's acts of infringement of the '901 Patent have been and continue to be willful, entitling Nokia Corporation to treble damages pursuant to 35 U.S.C. § 284. In addition, Qualcomm's willful infringement qualifies this case as an exceptional case pursuant to 35 U.S.C. § 285. SIXTH COUNTERCLAIM (OF NOKIA CORPORATION) (INFRINGEMENT OF THE '740 PATENT) 46. Nokia Corporation realleges and incorporates by reference each and every allegation contained in paragraphs 1 through 45 as if fully set forth herein. 20300/2127053.10300/2124645.1 9 47. On information and belief, Qualcomm makes, uses, sells, or offers for sale in the United States, and/or imports into the United States Qualcomm devices, including but not limited to at least one of the following Qualcomm devices: QSC1100, QSC6055, QSC6075, QSC6065, MSM6800, CSM6800 and/or QTP-6800, that alone and/or in combination with other devices, directly and/or indirectly infringes and is continuing to infringe, literally and/or under the doctrine of equivalents, the '740 Patent directly or indirectly in violation of 35 U.S.C. § 271. 48. On information and belief, Qualcomm has infringed and is continuing to infringe the '740 Patent by contributing to and/or inducing the infringement by others of the '740 Patent in violation of 35 U.S.C. § 271. 49. As a result of Qualcomm's direct and/or indirect infringement of the '740 Patent, Nokia Corporation has suffered and continues to suffer injury to its business, property, and patent rights, for which Nokia Corporation is entitled to damages pursuant to 35 U.S.C. § 284 in an amount to be proved at trial. 50. Unless Qualcomm is enjoined by this Court from continuing its infringement of the '740 Patent, Nokia Corporation will suffer additional irreparable harm and impairment of the value of its patent rights for which there is no adequate remedy at law. Thus, Nokia Corporation is entitled to an injunction against further infringement of the '740 Patent pursuant to 35 U.S.C. § 283. 51. Qualcomm's acts of infringement of the '740 Patent have been and continue to be willful, entitling Nokia Corporation to treble damages pursuant to 35 U.S.C. § 284. In addition, Qualcomm's willful infringement qualifies this case as an exceptional case pursuant to 35 U.S.C. § 285. 20300/2127053.10300/2124645.1 10 SEVENTH COUNTERCLAIM (OF NOKIA CORPORATION AND NOKIA, INC.) (DECLARATORY JUDGMENT OF INVALIDITY, NON-INFRINGEMENT, AND UNENFORCEABILITY OF THE '954 AND '130 PATENTS) 52. Nokia Corporation and Nokia, Inc. reallege and incorporate by reference each and every allegation contained in paragraphs 1 through 51 as if fully set forth herein. 53. Qualcomm claims to be the assignee and owner of the entire right, title, and interest in and to United States Patent No. 7,184,954 (the "'954 Patent") and United States Patent No. 6,205,130 (the "'130 Patent") and that the '954 and '130 Patents were duly and lawfully issued. Qualcomm also alleges that Nokia Corporation and Nokia, Inc. are infringing, have infringed, and will continue to infringe the '954 and '130 Patents. These allegations have caused an actual, substantial, and continuing justiciable controversy between Nokia Corporation and Nokia, Inc., on the one hand, and Qualcomm, on the other hand, as to the infringement, validity, and unenforceability of the '954 and '130 Patents. This Court has subject matter jurisdiction over the Counterclaims of Nokia Corporation and Nokia, Inc. under the Declaratory Judgment Act, 28 U.S.C. §§ 2201-2202. 54. Nokia Corporation and Nokia, Inc. deny Qualcomm's allegations of infringement. Neither Nokia Corporation nor Nokia, Inc. have infringed, contributed to the infringement of, induced the infringement of, or otherwise directly, indirectly, or under the doctrine of equivalents, infringed any valid claim of the '954 and '130 Patents. 55. The '954 and '130 Patents are invalid and unenforceable under one or more provisions of 35 U.S.C. §§ 102, 103, and/or 112, and/or are otherwise unenforceable. 56. Nokia Corporation and Nokia, Inc. are therefore entitled to a declaratory judgment that each does not infringe and has not infringed the '954 and '130 Patents and/or that the '954 and '130 Patents are invalid and/or unenforceable. 20300/2127053.10300/2124645.1 11 PRAYER FOR RELIEF WHEREFORE, Nokia Corporation prays for judgment in its favor and against Qualcomm with respect to Nokia Corporation's counterclaims as follows: (a) for judgment that Qualcomm has infringed, directly or indirectly, one or more of Nokia's Patents-in-Suit; (b) awarding damages to Nokia Corporation in an amount to be proved at trial, including prejudgment and post-judgment interest, for Qualcomm's infringement of one or more of Nokia's Patents-in-Suit pursuant to 35 U.S.C. § 284; (c) awarding treble damages to Nokia Corporation pursuant to 35 U.S.C. § 284 for Qualcomm's willful infringement of one or more of Nokia's Patents-in-Suit; (d) enjoining Qualcomm, its officers, agents, servants, employees, and those persons acting in active concert or in participation with them, from directly or indirectly further infringing one or more of Nokia's Patents-in-Suit pursuant to 35 U.S.C. § 283; and WHEREFORE, Nokia Corporation and Nokia, Inc. each pray for judgment in its favor and against Qualcomm with respect to Nokia Corporation's and Nokia, Inc.'s counterclaims as follows: (e) declaring that Nokia Corporation does not and has not directly or indirectly infringed the '954 and '130 Patents, and that Nokia, Inc. does not and has not directly or indirectly infringed the '954 and '130 Patents; (f) (g) (h) declaring that each claim of the '954 and '130 Patents is invalid; declaring that each claim of the '954 and '130 Patents is unenforceable; declaring this case exceptional pursuant to 35 U.S.C. § 285, and awarding Nokia Corporation and Nokia, Inc. its reasonable attorneys' fees, expenses, and costs incurred in this action; and 20300/2127053.10300/2124645.1 12 (i) proper. granting such other and additional relief as the Court deems just and 20300/2127053.10300/2124645.1 13 DEMAND FOR JURY TRIAL Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Nokia Corporation and Nokia, Inc. hereby demand a trial by jury as to all issues so triable. Dated: May 23, 2007 /s/ Allen Arntsen ___________________________________ Allen Arntsen FOLEY & LARDNER LLP 150 East Gilman Street Verex Plaza Madison, Wisconsin 53703 Telephone: 608-258-4293 Facsimile: 608-258-4258 G. Peter Albert, Jr. FOLEY & LARDNER LLP 11250 El Camino Real, Suite 200 San Diego, California 92130 Telephone: 858-847-6735 Facsimile: 858-792-6773 Attorneys for Defendants Nokia Corporation and Nokia, Inc. OF COUNSEL: A. William Urquhart (CA Bar No. 140996) Marshall M. Searcy III (CA Bar No. 169269) Erica P. Taggart (CA Bar No. 215817) Ryan S. Goldstein (CA Bar No. 208444) QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP 865 South Figueroa Street, 10th Floor Los Angeles, California 90017-2543 Telephone: (213) 443-3000 Facsimile: (213) 443-3100 Charles K. Verhoeven (CA Bar No. 170151) QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP 50 California Street, 22nd Floor San Francisco, California 9411 Telephone: (415) 875-6600 Facsimile: (415) 875-6700 Keith E. Broyles (GA Bar No. 090152) Alan L. Whitehurst (DC Bar No. 484873) John D. Haynes (GA Bar No. 340599) ALSTON & BIRD LLP One Atlantic Center 1201 West Peachtree Street Atlanta, Georgia 30309-3424 Telephone: (404) 881-7000 Facsimile: (404) 881-7777 Attorneys for Defendants Nokia Corporation and Nokia, Inc. 20300/2127053.10300/2124645.1 14 Exhibit A Page 1 Exhibit A Page 2 Exhibit A Page 3 Exhibit A Page 4 Exhibit A Page 5 Exhibit A Page 6 Exhibit A Page 7 Exhibit A Page 8 Exhibit A Page 9 Exhibit A Page 10 Exhibit A Page 11 Exhibit B Page 1 Exhibit B Page 2 Exhibit B Page 3 Exhibit B Page 4 Exhibit B Page 5 Exhibit B Page 6 Exhibit B Page 7 Exhibit B Page 8 Exhibit B Page 9 Exhibit B Page 10 Exhibit B Page 11 Exhibit B Page 12 Exhibit B Page 13 This PDF of U.S. Utility Patent 6115593 provided by Patent FetcherTM, a product of Stroke of Color, Inc. - Page 1 of 12 Exhibit C Page 1 This PDF of U.S. Utility Patent 6115593 provided by Patent FetcherTM, a product of Stroke of Color, Inc. - Page 2 of 12 Exhibit C Page 2 This PDF of U.S. Utility Patent 6115593 provided by Patent FetcherTM, a product of Stroke of Color, Inc. - Page 3 of 12 Exhibit C Page 3 This PDF of U.S. Utility Patent 6115593 provided by Patent FetcherTM, a product of Stroke of Color, Inc. - Page 4 of 12 Exhibit C Page 4 This PDF of U.S. Utility Patent 6115593 provided by Patent FetcherTM, a product of Stroke of Color, Inc. - Page 5 of 12 Exhibit C Page 5 This PDF of U.S. Utility Patent 6115593 provided by Patent FetcherTM, a product of Stroke of Color, Inc. - Page 6 of 12 Exhibit C Page 6 This PDF of U.S. Utility Patent 6115593 provided by Patent FetcherTM, a product of Stroke of Color, Inc. - Page 7 of 12 Exhibit C Page 7 This PDF of U.S. Utility Patent 6115593 provided by Patent FetcherTM, a product of Stroke of Color, Inc. - Page 8 of 12 Exhibit C Page 8 This PDF of U.S. Utility Patent 6115593 provided by Patent FetcherTM, a product of Stroke of Color, Inc. - Page 9 of 12 Exhibit C Page 9 This PDF of U.S. Utility Patent 6115593 provided by Patent FetcherTM, a product of Stroke of Color, Inc. - Page 10 of 12 Exhibit C Page 10 This PDF of U.S. Utility Patent 6115593 provided by Patent FetcherTM, a product of Stroke of Color, Inc. - Page 11 of 12 Exhibit C Page 11 This PDF of U.S. Utility Patent 6115593 provided by Patent FetcherTM, a product of Stroke of Color, Inc. - Page 12 of 12 Exhibit C Page 12 Exhibit D Page 1 Exhibit D Page 2 Exhibit D Page 3 Exhibit D Page 4 Exhibit D Page 5 Exhibit D Page 6 Exhibit D Page 7 Exhibit D Page 8 Exhibit D Page 9 Exhibit D Page 10 Exhibit D Page 11 Exhibit D Page 12 Exhibit D Page 13 Exhibit E Page 1 Exhibit E Page 2 Exhibit E Page 3 Exhibit E Page 4 Exhibit E Page 5 Exhibit E Page 6 Exhibit F Page 1 Exhibit F Page 2 Exhibit F Page 3 Exhibit F Page 4 Exhibit F Page 5 Exhibit F Page 6 Exhibit F Page 7 Exhibit F Page 8 Exhibit F Page 9

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