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

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

the United States the SSV Docking Stations separately or in combination with the

SSV Audio Docks. The SSV Docking Stations and SSV Audio Docks are made or

especially adapted to be used in a manner that infringes the claims of the ‘081 patent.

The SSV Docking Stations, individually or in combination an SSV Audio Dock,

constitute a material part of the inventions claimed in the ‘081 patent. The SSV

Docking Stations and SSV Audio Docks are not a staple article or a commodity of

commerce suitable for substantial non-infringing use. On information and belief,

SSV was aware of the ‘081 patent since at least November of 2013. SSV had actual

notice of its infringement of the ‘081 patent since at least April 25, 2014.

 SSV has actively induced infringement of the ‘756 patent under 35 U.S.C. § 271(b).

SSV has intentionally caused third parties to directly infringe the ‘756 patent under

35 U.S.C. § 271(a) by inducing its customers to make an infringing combination of

the SSV Docking Stations or the SSV Audio Docks with an “iPod RF Remote”

wireless controller. SSV was aware of the ‘756 patent since at least January2011,

before it began making, using, selling, offering for sale, and/or importing the

Accused Instrumentalities. SSV had actual notice that is infringing the ‘756 patent, at

least since January 2011.

To the extent that Defendants do not sell, offer for sale, make, or use the Accused

Instrumentalities in the United States, or import the Accused Instrumentalities into the United

States, but rely upon third parties to sell, offer for sale, make, or use the Accused Instrumentalities

in the United States, or to import the Accused Instrumentalities into the United States, Magnadyne

and SSV have actively induced infringement of the ‘756 and ‘081 patents and Magnadyne and SSV

have contributorily infringed the ‘081 patent.

Plaintiff also incorporates by reference herein the discussion of indirect infringement at

paragraphs 66-79 and 87-101 of the Second Amended Complaint.

III. Patent Local Rules 3-1(e)

Case3:14-cv-01931-WHA Document87-2 Filed02/03/15 Page8 of 13

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Aquatic AQ-DM-4U Manuale Utente Pagina 19