`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 23-278-MN
`
`JURY TRIAL DEMANDED
`
`)))))))))
`
`PAYRANGE INC.,
`
`Plaintiff,
`
`v.
`
`CSC SERVICEWORKS, INC.,
`
`Defendant.
`
`PLAINTIFF’S NOTICE OF STATUTORY DISCLAIMER
`
`In connection with Defendant’s Renewed Motion to Dismiss (D.I. 14), Plaintiff presents
`
`the Statutory Disclaimers per Manual of Patent Examining Procedure (MPEP) 1490, Disclaimer
`
`in a Patent Under 37 CFR § 1.321(a), filed on November 22, 2023, with respect to the patent-in-
`
`suit U.S. Patent No. 11,481,772 (“’772 patent”). Ex. A. Plaintiff disclaims Claims 1-6, 8-10 and
`
`12-20 of the ’772 patent. Id. Plaintiff no longer asserts the disclaimed claims, and the only
`
`remaining asserted claim in this action for the ’772 patent is claim 11. As a result, Plaintiff
`
`believes that Defendant’s Renewed Motion to Dismiss is moot with respect to the patent eligibility
`
`under 35 U.S.C § 101 of the disclaimed claims. Additionally, Plaintiff believes that the parties’
`
`arguments about the representativeness of claim 1 and whether it is materially distinct from
`
`dependent claims 7 and 9 are also moot.
`
`
`
`Case 1:23-cv-00278-MN Document 42 Filed 12/21/23 Page 2 of 2 PageID #: 967
`
`Respectfully submitted,
`POTTER ANDERSON & CORROON LLP
`
`By: /s/ Andrew M. Moshos
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Andrew M. Moshos (#6685)
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`amoshos@potteranderson.com
`
`Attorneys for Plaintiff PayRange Inc.
`
`OF COUNSEL:
`
`James C. Yoon
`Ryan R. Smith
`Christopher D. Mays
`Alexander Miller
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`Tel: (650) 493-9300
`
`Jamie Y. Otto
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`953 East Third Street, Suite 100
`Los Angeles, CA 90013
`Tel: (323) 210-2900
`
`Dated: December 21, 2023
`11218615 / 23372.00001
`
`-2-
`
`
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