Aquatic AQ-DM-4U Instrukcja Użytkownika Pobierz pdf (Strona 18)

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

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

 Magnadyne has contributorily infringed the ‘081 patent under 35 U.S.C. § 271(c).

Magnadyne offers to sell or sells or otherwise provides within the United States or

imports into the United States the Magnadyne Docking Stations, Magnadyne

Wireless Remotes and/or Wired Remotes, and the SSV Docking Stations. The

Magnadyne Docking Stations and the SSV Docking Stations are made or especially

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

Magnadyne Wireless Remotes and/or Wired Remotes are made or especially adapted

for use with the Magnadyne Docking Stations, and when used therewith, together

infringe certain claims of the ‘081 patent. The Magnadyne Wireless Remotes and/or

Wired Remotes, Magnadyne Docking Stations, and SSV Docking Stations,

individually or in combination, constitute a material part of the inventions claimed in

the ‘081 patent. None of the Magnadyne Wireless Remotes and/or Wired Remotes,

Magnadyne Docking Stations or SSV Docking Stations are a staple article or a

commodity of commerce suitable for substantial non-infringing use. On information

and belief, Magnadyne was aware of the ‘081 patent since at least November of

2013. Magnadyne had actual notice of its infringement of the ‘081 patent since at

least April 25, 2014.

As to SSV:

 SSV has actively induced infringement of the ‘081 patent under 35 U.S.C. § 271(b).

SSV has intentionally caused third parties to directly infringe the ‘081 patent under

35 U.S.C. § 271(a) by inducing such third parties to use, offer or sale or sell the SSV

Docking Station separately or in combination with the SSV Audio Docks and/or with

an “iPod RF Remote” wireless controller. On information and belief, SSV was

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

is directly infringing the ‘081 patent, at least since April 25, 2014.

 SSV has contributorily infringed the ‘081 patent under 35 U.S.C. § 271(c). SSV

offers to sell or sells or otherwise provides within the United States or imports into

Case3:14-cv-01931-WHA Document87-2 Filed02/03/15 Page7 of 13

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