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PLAINTIFF AQUATIC AV, INC’S AM. DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT

CONTENTIONS / Case No. 3-14-cv-01931-WHA

“Wireless Remotes”) or (2) Magnadyne’s wired remote control model numbers WRC-100,

WRC-150, WRC-200, WRC-250, WRC-300, and WRC-350 (“Wired Remotes”);

As to SSV: “WP Series” docking station model nos. WP-ID4, WP-ID5, WP-ID5BT, WP-

ID5BTD and SSV’s “iPod Overhead Systems” (the SSV “Docking Stations”) and SSV Works

Media Dock Overhead Audio products 1XD-H81C0-T0, 2878320, 2878803, 2879231, 2879232,

2879233, 2879234, 2PG-H81C0-VO, WP-GRJC4, WP-JPO, WP-JXO8, WPOJP, WP-OJX8, WP-

OJX8KM, WP-ORZ, WP-ORZ34, WP-ORZF4, WP-ORZF4KM, WP-OU2, WP-OU4, WP-OU4L,

WP-OU4S, WP-OWC4, WP-OWC4KM, WP-PNO, RZ3O4, WP-RZF3O4, WP-RZFO4, WP-RZO,

SSV-WP-UO2, WP-UO4L, WP-UO4S, WP-WCO4, RZR, RZR4, RZR 500, RZR S, RZR 800, RZR

S 800, RZR 800XC, RZR 900, RZR XP 900, RZR-XP4 900, RZR4 1000, RZR XP 1000, WP-

RZO+2, WP-WCO4, WP-UO2, WP-RZ3O4, WP-RZ3O+2 (the SSV “Audio Docks”), both

separately and in combination with the SSV wireless remote controller (the “iPod RF Remote” or

“RFC” sold by SSV, shown at http://www.ssvworks.com/product/ipod-rf-remote-with-steering-

wheel-mount).Aquatic expressly reserves the right to identify different or additional apparatuses,

products, devices, processes, methods, acts, or other instrumentalities of Defendants, as appropriate,

in light of information that it may obtain through discovery in this case.

Pursuant to Patent Local Rule 3-1(c), based on the information presently available to it,

Aquatic provides the infringement charts in Amended Appendix A and Appendices BA-D. Aquatic

expressly reserves the right to modify, supplement, or amend these infringement charts, as

appropriate, in light of information that it may obtain through discovery in this case.

II. Patent Local Rules 3-1(d)

Pursuant to Patent Local Rule 3-1(d), based on the information presently available to it,

Aquatic alleges, on information and belief, that:

As to Magnadyne:

 Magnadyne has actively induced infringement of the ‘756 patent under 35 U.S.C. §

271(b). Magnadyne has intentionally caused third parties to directly infringe the

‘756 patent under 35 U.S.C. § 271(a) by inducing such third parties to use the

Case3:14-cv-01931-WHA Document87-2 Filed02/03/15 Page5 of 13

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Aquatic AQ-DM-4U Manuale Utente Pagina 16