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PLAINTIFF AQUATIC AV, INC’S AM. DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT
CONTENTIONS / Case No. 3-14-cv-01931-WHA
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INTRODUCTION
Pursuant to Patent Local Rule 3-1, Plaintiff Aquatic AV, Inc. (“Aquatic”) hereby provides its
First Amended Disclosure of Asserted Claims and Infringement Contentions to defendants
Magnadyne Corporation (“Magnadyne”) and SSV Works, Inc. (“SSV”) (collectively,
“Defendants”).
This disclosure is made solely for the purpose of this action. This disclosure is subject to all
objections on any grounds that would require the exclusion of statements contained herein if such
disclosure were asked of, or statements contained herein were made by, a witness present and
testifying in court, all of which objections and grounds are expressly reserved and may be
interposed at the time of trial.
Aquatic’s investigation regarding these and other potential grounds of infringement is
ongoing. Defendant Magnadyne did not produce any technical documentation relating to its
accused products until two weeks before the deadline for these Patent Local Rule 3-1 Disclosures,
and produced product samples only two days before the deadline for these Disclosures. Defendant
SSV has not yet produced any technical documents or specimens relating to its accused products for
investigation or analysis in this case. As a result of Defendants’ dilatory and incomplete discovery
productions, Aquatic has not had a reasonable opportunity to fully review and analyze the materials
produced to-date. Aquatic therefore reserves the right to modify and/or supplement these disclosures
based on its ongoing investigation and analysis of the materials that have either been produced by
Magnadyne and will be produced by either defendant in the future. Aquatic’s disclosure is therefore
based upon information that Aquatic has been able to obtain from publicly available sources, and is
given without prejudice to Aquatic’s right to modify, supplement, or amend its disclosure as
additional facts are ascertained, analyses are made, research is completed, and contentions are made.
AQUATIC’S DISCLOSURE OF
ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
I. Patent Local Rules 3-1(a), 3-1(b), and 3-1(c)
Pursuant to Patent Local Rule 3-1(a), based on the public information presently available to
Case3:14-cv-01931-WHA Document87-2 Filed02/03/15 Page3 of 13
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