UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF NEW YORK
`__________________________________________
`
`
`
`
`
`
`
`
`
`
`
`:
`
`
`: Civil Action No.
`
`: 2:14-cv-06659-KAM-SIL
`
`
`: Kiyo A. Matsumoto, U.S.D.J.
`
`
`THINK PRODUCTS, INC.
`
`
`
`
`
`
`
` Plaintiff,
`
`
`
`
`
`
`
`-v.-
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`ACCO BRANDS CORPORATION
`
` :
`
`and ACCO BRANDS USA LLC,
`
` Steven I. Locke
`
`
`Defendants.
`
`
`: U.S. Magistrate Judge
`__________________________________________
`
`
`
`PLAINTIFF THINK PRODUCTS, INC.’S DISCLOSURE OF
`ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS,
`PURSUANT TO LOCAL PATENT RULE 6
`
`
`Plaintiff Think Products, Inc. (“Think Products”), as and for its Local Patent
`
`
`
`Rule 6 “Disclosure of Asserted Claims and Infringement Contentions,” hereby
`
`identifies each and every claim of U.S. Patent No. 8,717,758 (“the „758 Patent”) and
`
`of U.S. Patent No. 8,837,144 (“the „144 Patent”) that is alleged to be infringed by each
`
`product and/or process manufactured and/or sold in the United States by Defendants
`
`ACCO Brands Corporation and ACCO Brands USA LCC (collectively “ACCO
`
`Brands”) and which are being asserted by Think Products against ACCO Brands in the
`
`above-captioned civil action for patent infringement:
`
`United States Patent No. 8,717,758 – Independent Claim 1:
`
` A locking assembly for securing a
`portable electronic device having at least
`one housing to a substantially immovable
`object, the locking assembly comprising:
`
`
`
`The preamble of independent apparatus
`Claim 1 of U.S. Patent No. 8,717,758 recites
`an “intended use” of the claimed locking
`assembly and is not a limitation on the scope
`of the apparatus being claimed.
`
`
`
`
`- 1 -
`
`Ex. 1020 - Page 1 of 25
`
`ACCO Brands
`Exhibit 1020
`ACCO Brands v. Think Products
`IPR2015-01152
`
`

`

`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF NEW YORK
`__________________________________________
`
`
`
`
`
`
`
`
`
`
`
`:
`
`
`: Civil Action No.
`
`: 2:14-cv-06659-KAM-SIL
`
`
`: Kiyo A. Matsumoto, U.S.D.J.
`
`
`THINK PRODUCTS, INC.
`
`
`
`
`
`
`
` Plaintiff,
`
`
`
`
`
`
`
`-v.-
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`ACCO BRANDS CORPORATION
`
` :
`
`and ACCO BRANDS USA LLC,
`
` Steven I. Locke
`
`
`Defendants.
`
`
`: U.S. Magistrate Judge
`__________________________________________
`
`
`
`PLAINTIFF THINK PRODUCTS, INC.’S DISCLOSURE OF
`ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS,
`PURSUANT TO LOCAL PATENT RULE 6
`
`
`Plaintiff Think Products, Inc. (“Think Products”), as and for its Local Patent
`
`
`
`Rule 6 “Disclosure of Asserted Claims and Infringement Contentions,” hereby
`
`identifies each and every claim of U.S. Patent No. 8,717,758 (“the „758 Patent”) and
`
`of U.S. Patent No. 8,837,144 (“the „144 Patent”) that is alleged to be infringed by each
`
`product and/or process manufactured and/or sold in the United States by Defendants
`
`ACCO Brands Corporation and ACCO Brands USA LCC (collectively “ACCO
`
`Brands”) and which are being asserted by Think Products against ACCO Brands in the
`
`above-captioned civil action for patent infringement:
`
`United States Patent No. 8,717,758 – Independent Claim 1:
`
` A locking assembly for securing a
`portable electronic device having at least
`one housing to a substantially immovable
`object, the locking assembly comprising:
`
`
`
`The preamble of independent apparatus
`Claim 1 of U.S. Patent No. 8,717,758 recites
`an “intended use” of the claimed locking
`assembly and is not a limitation on the scope
`of the apparatus being claimed.
`
`
`
`
`- 1 -
`
`Ex. 1020 - Page 2 of 25
`
`

`

`The following non-exclusive list of ACCO
`Brands Products are alleged to infringe
`independent apparatus Claim 1 of U.S. Patent
`No. 8,717,758:
`
`The Kensington ClickSafe Portable
`Combination Laptop Lock (K64698US);
`
`Kensington ClickSafe Keyed Laptop Lock
`(K64637WW);
`
`Kensington ClickSafe Point 2 Point Keyed
`Lock - Keyed Lock (K64998WW);
`
`Kensington ClickSafe Anywhere Keyed
`Lock 2Pack Model (K64661WW)
`
`Kensington ClickSafe Keyed Retractable
`Laptop Lock (K64955WW); and,
`
`Kensington ClickSafe Keyed Twin Laptop
`Lock (K64638WW),
`
`collectively “The Asserted Infringement
`Products”
`
`An instruction guide reciting descriptive
`information and visually showing the
`elements of, and how to use, the locking
`assembly for the Kensington “ClickSafe
`Combination Laptop Lock” is being included
`with Think Products‟ Infringement
`Contentions as “Exhibit 1.”
`
`Alternatively, if the preamble of independ-
`ent Claim 1 of the „758 Patent is a limitation
`on the claim, then the Kensington “ClickSafe
`Combination Laptop Lock” is a “locking
`assembly” useful for the intended use recited
`in the preamble of Claim 1.
`
` a captive security rod having a
`“Exhibit 2” of Plaintiff‟s Infringement Con-
`
`locking end and an anchoring end, where- tentions is photograph of the Kensington
`in the anchoring end is passed through
`“ClickSafe Combination Laptop Lock” with
`the at least one housing to anchor the
`labels provided for the structural elements of
`captive security rod thereto;
`ACCO Brands‟ locking device:
`
`
`
`- 2 -
`
`Ex. 1020 - Page 3 of 25
`
`

`

`
`
` said captive security rod partially
`in said at least one housing and partially
`out of said at least one housing during
`and before locking use; and
`
` a locking device with a locking
`mechanism,
`
`
`wherein the locking device is configured
`with an opening to receive the locking
`end of the captive security rod to activate
`the locking mechanism, where the
`activation causes the locking mechanism
`to securely grasp the locking end and
`thereby lock the security rod and portable
`electronic device to the locking device.
`
`“Exhibit 2” shows a “captive security rod” or
`spike, while the instructional guide (“Exhibit
`1”) describes a sequence of acts required to
`anchor the captive security rod or anchor:
`
`Instruction No. 1 (“Exhibit 1”) depicts an
`anchor with an anchoring end and a locking
`end; the depiction shows an arrow directing
`the anchoring end through a slot in a
`computer housing;
`
`Instruction No. 2 (“Exhibit 1”) depicts the
`anchor in the housing;
`
`Instruction No. 3 (“Exhibit 1”) depicts the
`anchor being turned clockwise using an
`Allen wrench to anchor the anchor in the
`housing; and
`
`Instruction No. 4 (“Exhibit 1”) depicts the
`anchor fixed partially in and partially out of
`the housing, before locking use.
`
`“Exhibit 2” shows an “internal locking
`mechanism,” as labeled.
`
`In a second set of instructions, Nos. 1 – 4
`(“Exhibit 1”), is provided a sequence of steps
`for locking the computer using a cable
`assembly after the anchor has been secured in
`the housing.
`
`Instruction No. 1 (“Exhibit 1”) depicts a
`cable, to which a tamper resistant lock
`head/combination lock (“the lock head”) is
`attached, being wrapped around a table
`structure after the lock head is passed
`through a loop at the end of the cable;
`Instruction 2 (“Exhibit 1”) depicts the lock
`head being moved to the anchor fixed
`partially in, and partially out, of the housing,
`to receive the portion of the anchor extending
`out from the housing in the lock head;
`
`Instruction 3 (“Exhibit 1”) shows the lock
`head completely enveloping the locking end
`
`
`
`- 3 -
`
`Ex. 1020 - Page 4 of 25
`
`

`

`
`
`
`
`of the anchor; and
`
`Instruction 4 (“Exhibit 1”) shows the a
`computer secured to the table structure,
`deemed to be an “immovable object.”
`
`
`United States Patent No. 8,717,758 – Independent Claim 16:
`
`An instruction guide reciting descriptive
`information and visually showing the elements
`of, and how to use, the locking assembly for the
`Kensington “ClickSafe Combination Laptop
`Lock” is being included with Think Products‟
`Infringement Contentions as “Exhibit 1.”
`
`“Exhibit 2” of Plaintiff‟s Infringement
`Contentions is photograph of the Kensington
`“ClickSafe Combination Laptop Lock” with
`labels provided for the structural elements of
`ACCO Brands‟ locking device.
`
` A
`
` first set of instructions Nos. 1 – 4 (“Exhibit
`1”), all contained on a single page of the
`instruction guide, describes a sequence of acts
`required to anchor a captive security rod or
`anchor according to the following steps;
`
`Instruction No. 1 (“Exhibit 1”) depicts an anchor
`with an anchoring end and a locking end – the
`depiction shows an arrow directing the anchoring
`end through a slot in a computer housing;
`
`Instruction No. 2 (“Exhibit 1”) depicts the
`anchor in the housing;
`
`Instruction No. 3 (“Exhibit 1”) depicts the
`anchor being turned clockwise using an allen
`wrench to anchor the anchor in the housing; and,
`
`Instruction No. 4 (“Exhibit 1”) depicts the
`anchor fixed partially in and partially out of the
`housing, before locking use.
`
`
`
`
` A method for securing a portable
`electronic device having a horsing
`[sic: housing] to a substantially
`immovable object utilizing a locking
`assembly, the locking assembly
`comprising
`
` a captive security rod or spike
`formed with an anchoring end
`separated axially by a protruding end,
`
` said captive security rod being
`captive partially in said at least one
`housing and partially out of said at
`least one housing during and before
`locking use;
`
` a locking device with an
`internal locking mechanism and a
`cable permanently attached to the
`locking device at one end,
`
`
`
`
`- 4 -
`
`Ex. 1020 - Page 5 of 25
`
`

`

`the method comprising acts of:
`
` securedly fixing the anchoring
`end of the captive security rod or
`spike to the portable electronic device
`upon or through the housing;
`
` attaching another end of the
`cable to the substantially immovable
`object; and
`
`
` inserting the protruding end of
`the captive, security rod into an
`opening in the locking device to
`actuate the internal locking
`mechanism and lock the locking
`device to the captive security rod and,
`therefore, the portable
`electronic device to which it is
`anchored, to the substantially
`immovable object.
`
`
` In addition, the video at:
`
`http://www.kensington.com/us/us/4514/clicksafe
`%C2%AE-locks#.VTAVW3lFCcw
`
`indicates that the Kenssington Clicksafe laptop
`lock requires only one click to lock a laptop.
`
`
`In a second set of Instructions No. 1 – 4
`(“Exhibit 1”), presented over several pages of the
`instruction guide, a sequence of steps is depicted
`for locking the computer using the cable
`assembly after the anchor has been secured in the
`housing.
`
`Instruction No. 1 (“Exhibit 1”) depicts a cable, to
`which a tamper resistant lock head/combination
`lock (“the lock head”) is attached, being wrapped
`around a table structure after the lock head is
`passed through a loop at the end of the cable.
`
`Instruction No. 2 (“Exhibit 1”) depicts the lock
`head being moved to the anchor fixed partially in
`and partially out of the housing, to receive the
`portion of the anchor extending out from the
`housing in the lock head.
`
`Instruction No. 3 (“Exhibit 1”) shows the lock
`head completely enveloping the locking end of
`the anchor; and
`
`Instruction 4 shows the computer secured to the
`table structure (“substantially immovable
`object”),
`
`thereby practicing each and every method step of
`independent method Claim 16 of the „758 Patent.
`
`
`
`
`
`
`- 5 -
`
`Ex. 1020 - Page 6 of 25
`
`

`

`United States Patent No. 8,837,144 – Independent Claim 1:
`
` 1. A locking assembly for
`securing a portable electronic
`device having at least one
`housing to a substantially
`immovable object, the locking
`assembly comprising:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`The preamble of independent apparatus Claim 1 of
`U.S. Patent No. 8,837,144 recites an “intended use” of
`the claimed locking assembly and is not a limitation on
`the scope of the apparatus being claimed.
`
`The following non-exclusive list of ACCO Brands
`Products are alleged to infringe independent apparatus
`Claim 1 of U.S. Patent No. 8,837,144:
`
`The Kensington ClickSafe Portable Combination
`Laptop Lock (K64698US);
`
`Kensington ClickSafe Keyed Laptop Lock
`(K64637WW);
`
`Kensington ClickSafe Point 2 Point Keyed Lock -
`Keyed Lock (K64998WW);
`
`Kensington ClickSafe Anywhere Keyed Lock 2Pack
`Model (K64661WW)
`
`Kensington ClickSafe Keyed Retractable Laptop Lock
`(K64955WW); and,
`
`Kensington ClickSafe Keyed Twin Laptop Lock
`(K64638WW),
`
`collectively “The Asserted Infringement Products.”
`
`An instruction guide reciting descriptive information
`and visually showing the elements of, and how to use,
`the locking assembly for the Kensington “ClickSafe
`Combination Laptop Lock” is being included with
`Think Products‟ Infringement Contentions as “Exhibit
`1.”
`
`Alternatively, if the preamble of independent Claim 1
`of the „144 Patent is a limitation on the claim, then the
`Kensington “ClickSafe Combination Laptop Lock” is
`a “locking assembly” useful for the intended use
`recited in the preamble of Claim 1.
`
`
`
`
`
`
`
`- 6 -
`
`Ex. 1020 - Page 7 of 25
`
`

`

` a captive security rod
`having a locking end and an
`anchoring end, wherein the
`anchoring end is installed in the
`at least one housing to anchor
`the captive security rod thereto;
`
`
`
`
`
`“Exhibit 2” of Plaintiff‟s Infringement Contentions is
`photograph of the Kensington “ClickSafe Combination
`Laptop Lock” with labels provided for the structural
`elements of ACCO Brands‟ locking device:
`
`“Exhibit 2” shows a “captive security rod” or spike,
`while the instructional guide (“Exhibit 1”) describes a
`sequence of acts required to anchor the captive
`security rod or anchor.
`
` A
`
` first set of instructions, Nos. 1 – 4 (“Exhibit 1”), all
`contained on a single page of the instruction guide,
`shows the structural elements of a captive security rod
`with a locking end and the sequence of acts required to
`anchor the captive security rod or anchor recited in
`apparatus independent Claim 1.
`
`Instruction No. 1 (“Exhibit 1”) depicts an anchor with
`an anchoring end and a locking end; the depiction
`shows an arrow directing the anchoring end through a
`slot in a computer housing; and,
`
`Instruction No. 2 (“Exhibit 1”) depicts the anchor in
`the housing.
`
`Instruction No. 3 (“Exhibit 1”) depicts the anchor
`being turned clockwise using an Allen wrench to
`anchor the anchor in the housing; and,
`
`Instruction No. 4 (“Exhibit 1”) depicts the anchor
`fixed partially in and partially out of the housing,
`before locking use.
`
`
` said captive security rod
`being captive partially in said at
`least one housing after installa-
`tion and partially out of said at
`least one housing during and
`before locking use after install-
`lation; and,
`
`
`In a second set of instructions Nos. 1 – 4 (“Exhibit 1”),
` a locking device with a
`the instruction guide teaches locking the computer
`locking mechanism, wherein the
`after the anchor has one secured in the housing:
`locking device is configured
`
`with an opening to receive the
`Instruction No. 1 (“Exhibit 1”) shows a cable to which
`locking end of the captive
`a tamper resistant lock head and combination lock
`security rod to activate the
`(“the lock head”) is attached being wrapped around a
`locking mechanism,
`table structure (“substantially immovable object”) and
`
`through a loop at the end of the cable, proximate the
`where the activation causes the
`computer with the when the anchor fixed partially in
`locking mechanism to securely
`grasp the locking end and
`and partially out of the housing, positioned on the
`
`thereby lock the installed table structure;
`
`
`
`- 7 -
`
`Ex. 1020 - Page 8 of 25
`
`

`

`security rod and portable
`electronic device to the locking
`device.
`
`
`Instruction No. 2 (“Exhibit 1”) depicts the lock head
`being moved to the anchor fixed partially in and
`partially out of the housing, to receive the portion of
`the anchor extending out from the housing in the lock
`head;
`
`Instruction No. 3 (“Exhibit 1”) shows the lock head
`completely enveloping the locking end of the anchor;
`and,
`
`Instruction No. 4 (“Exhibit 1”) shows the computer
`secured to the table structure (“substantially
`immovable object.”)
`
`
`
`
`
`United States Patent No. 8,837,144 – Independent Claim 14:
`
` A locking assembly for securing
`a portable electronic device having at
`least one housing to a substantially
`immovable object, the locking
`assembly comprising:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`The preamble of independent apparatus Claim 14
`of U.S. Patent No. 8,837,144 recites an “intended
`use” of the claimed locking assembly and is not
`a limitation on the scope of the apparatus being
`claimed.
`
`The following non-exclusive list of ACCO
`Brands Products are alleged to infringe
`independent apparatus Claim 14 of U.S. Patent
`No. 8,837,144:
`
`The Kensington ClickSafe Portable Combination
`Laptop Lock (K64698US);
`
`Kensington ClickSafe Keyed Laptop Lock
`(K64637WW);
`
`Kensington ClickSafe Point 2 Point Keyed Lock
`- Keyed Lock (K64998WW);
`
`Kensington ClickSafe Anywhere Keyed Lock
`2Pack Model (K64661WW)
`
`Kensington ClickSafe Keyed Retractable Laptop
`Lock (K64955WW); and,
`
`Kensington ClickSafe Keyed Twin Laptop Lock
`(K64638WW),
`
`
`
`- 8 -
`
`Ex. 1020 - Page 9 of 25
`
`

`

`collectively “The Asserted Infringement
`Products.”
`
`An instruction guide reciting descriptive
`information and visually showing the elements
`of, and how to use, the locking assembly for the
`Kensington “ClickSafe Combination Laptop
`Lock” is being included with Think Products‟
`Infringement Contentions as “Exhibit 1.”
`
`Alternatively, if the preamble of independent
`Claim 1 of the „144 Patent is a limitation on the
`claim, then the Kensington “ClickSafe
`Combination Laptop Lock” is a “locking
`assembly” useful for the intended use recited in
`the preamble of Claim 1.
`
` A
`
` first set of instructions No. 1 – 4 (“Exhibit 1”)
`on a single leaf of the instruction guide first
`describes anchoring a captive security rod or
`anchor:
`
`Instruction No. 1 (“Exhibit 1”) depicts an anchor
`with an anchoring end and a locking end, with an
`arrow directing the anchoring end through a slot
`in a computer housing.
`
`Instruction No. 2 (“Exhibit 1”) depicts the
`anchor in the housing.
`
`Instruction No. 3 (“Exhibit 1”) depicts the
`anchor being turned clockwise using an Allen
`wrench to anchor the anchor.
`
`Instruction No. 4 (“Exhibit 1”) depicts the
`anchor fixed partially in and partially out of the
`housing, before locking use.
`
`
`In a second set of Instructions Nos. 1 – 4
`(“Exhibit 1”), the instruction guide teaches
`locking the computer after the anchor has one
`secured in the housing:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` a captive security rod or spike
`having a locking end and an
`anchoring end, said anchoring end of
`said captive security rod or spike
`configured for installing to the at least
`one housing by anchoring to the
`portable electronic device through the
`at least one housing;
`
`
` a locking device having a lock
`opening to a locking mechanism, said
`locking device configured to lock to
`said captive security rod or spike
`upon insertion of the locking end of
`said installed security rod or spike
`into said lock opening to actuate said
`locking mechanism, therein locking
`said locking device to said captive
`security rod or spike; and
` a cable attached to said locking
`device and configured for fastening to
`the substantially immovable object
`prior to locking said locking device to
`said installed captive security rod or
`spike,
`
`
`
`- 9 -
`
`Ex. 1020 - Page 10 of 25
`
`

`

`
`
`wherein said locking end of said
`installed captive security rod or spike
`comprises a small knob axially
`located on a distal end of said captive
`security rod or spike,
`
`
` wherein said installed captive
`security rod or spike is positioned in a
`recess in the at least one housing
`during non-use, and said small knob
`protrudes from the at least one
`housing during non-use.
`
`
`Instruction No. 1 (“Exhibit 1”) shows a cable to
`which a tamper resistant lock head and combina-
`tion lock (“the lock head”) is attached being
`wrapped around a table structure and through a
`loop at the end of the cable, proximate the
`computer with the when the anchor fixed
`partially in and partially out of the housing,
`positioned on the table structure (“substantially
`immovable object.”)
`Instruction No. 2 (“Exhibit 1”) depicts the lock
`head being moved to the anchor fixed partially in
`and partially out of the housing, to receive the
`portion of the anchor extending out from the
`housing in the lock head.
`
`Instruction No. 3 (“Exhibit 1”) shows the lock
`head completely enveloping the locking end of
`the anchor.
`
`Instruction No. 4 (“Exhibit 1”) shows the
`computer secured to the table structure
`(“substantially immovable object.”)
`
`
`
`
`
`United States Patent No. 8,837,144 – Independent Claim 20:
`
`An instruction guide reciting descriptive
`information and visually showing the
`elements of, and how to use, the locking
`assembly for the Kensington “ClickSafe
`Combination Laptop Lock” is being included
`with Think Products‟ Infringement
`Contentions as “Exhibit 1.”
`
`“Exhibit 2” of Plaintiff‟s Infringement
`Contentions is photograph of the Kensington
`“ClickSafe Combination Laptop Lock” with
`labels provided for the structural elements of
`ACCO Brands‟ locking device.
`
` A
`
` first set of instructions Nos. 1 – 4 (“Exhibit
`1”), all contained on a single page of the
`instruction guide, describes a sequence of
`acts required to anchor a captive security rod
`
` A method for securing a portable
`electronic device having a housing to a
`substantially immovable object utilizing
`a locking assembly,
`
` the locking assembly comprising a
`security rod or spike formed with an
`anchoring end separated axially by a
`protruding end,
`
` a locking device with an internal
`locking mechanism and a cable
`permanently attached to the locking
`device at one end,
`
`
`
`- 10 -
`
`Ex. 1020 - Page 11 of 25
`
`

`

`or anchor according to the following steps;
`
`Instruction No. 1 (“Exhibit 1”) depicts an
`anchor with an anchoring end and a locking
`end; the depiction shows an arrow directing
`the anchoring end through a slot in a
`computer housing;
`
`Instruction No. 2 (“Exhibit 1”) depicts the
`anchor in the housing;
`
`Instruction No. 3 (“Exhibit 1”) depicts the
`anchor being turned clockwise using an
`Allen wrench to anchor the anchor in the
`housing; and
`
`Instruction no. 4 depicts the anchor fixed
`partially in and partially out of the housing,
`before locking use.
`In a second set of instructions No. 1 – 4
`(“Exhibit 1”), presented over several pages of
`the instruction guide, a sequence of steps is
`depicted for locking the computer using the
`cable assembly after the anchor has been
`secured in the housing.
`
`Instruction No. 1 (“Exhibit 1”) depicts a
`cable, to which a tamper resistant lock
`head/combination lock (“the lock head”) is
`attached, being wrapped around a table
`structure after the lock head is passed
`through a loop at the end of the cable.
`
`Instruction No. 2 (“Exhibit 1”) depicts the
`lock head being moved to the anchor fixed
`partially in and partially out of the housing,
`to receive the portion of the anchor extending
`out from the housing in the lock head;
`
`Instruction No. 3 (“Exhibit 1”) shows the
`lock head completely enveloping the locking
`end of the anchor; and
`
`Instruction 4 (“Exhibit 1”) shows the
`computer secured to the table structure
`(“substantially immovable object”), thereby
`
`the method comprising acts of:
`
` securely installing the anchoring end
`of the security rod or spike to the portable
`electronic device in the housing;
`
`
` attaching another end of the cable to
`the substantially immovable object; and
`
`
` inserting the locking end of the
`security rod or spike into an opening in
`the locking device to actuate the internal
`
`
`
`- 11 -
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`Ex. 1020 - Page 12 of 25
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`

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`locking mechanism and lock the locking
`device to the captive security rod or spike
`and, therefore, the portable electronic
`device to which it is anchored, to the
`substantially immovable object.
`
`
`practicing each and every method step of
`independent method Claim 16 of the „144
`Patent.
`
`In addition, the video at:
`
`http://www.kensington.com/us/us/4514/click
`safe%C2%AE-locks#.VTAVW3lFCcw
`
`indicates that the Kenssington Clicksafe
`laptop lock requires only one click to lock a
`laptop.
`
`
`
`Think Products‟ Infringement Contentions are provided without prejudice to Think
`
`Products‟ rights and are based on a reasonable belief, understanding and information
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`available prior to completion of factor expert discovery. As such, Plaintiff Think
`
`Products reserves the right to amend, supplement, or otherwise modify these
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`Infringement Contentions as Think Products learns new information and additional
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`facts are ascertained as discovery progresses, including written discovery, document
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`- 12 -
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`Ex. 1020 - Page 13 of 25
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`

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`production, and both fact and expert depositions, analyses are made, research is
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`completed, and any additional contentions are made.
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`Dated: April 20, 2015
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`Respectfully submitted,
`
`THINK PRODUCTS, INC.
`
` By /s/ EdwinD. Schindler/
`
`Edwin D. Schindler (ES-7882)
`
`4 High Oaks Court
`
`P. O. Box 4259
`
`Huntington, New York 11743-0777
`Telephone: (631)474-5373
`
`Fax: (631)474-5374
`
`E-Mail: EDSchindler@att.net
`
` EDSchindler@optonline.net
`
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`
`John F. Vodopia (JV-6450)
`John F. Vodopia, PC
`191 New York Avenue
`Huntington, New York 11743
`Telephone: (631)673-7555, Ext. 128
`E-Mail: jvodopia@gmail.com
`
`Attorneys for Plaintiff Think Products, Inc.
`
`- 13 -
`
`Ex. 1020 - Page 14 of 25
`
`

`

`CERTIFICATE OF SERVICE
`I hereby certify that I caused a true and correct copy of the foregoing
`PLAINTIFF THINK PRODUCTS, INC.’S DISCLOSURE OF ASSERTED
`CLAIMS AND INFRINGEMENT CONTENTIONS, PURSUANT TO LOCAL
`PATENT RULE 6 to be served on counsel of record via electronic mail on April 20,
`2015.
`
`/s/ John F. Vodopia
`John F. Vodopia
`
`
`
`- 14 -
`
`Ex. 1020 - Page 15 of 25
`
`

`

`PLAIIYTIFF THI]YK PRODUCTS ,II{C.
`PLAINTIFF THINKPRODUCTS , INC.
`
`I ]Y F RI ]Y G E ME IY T C O IY TE ]Y TI O IV S
`INFRINGEMENT C0NTENTIONS
`
`EXHIBIT 1
`EXHIBIT 1
`
`Ex. 1020 - Page 16 of 25
`
`Ex. 1020 - Page 16 of 25
`
`

`

`Kensington'
`
`ClickSafe" Combination Laptop Lock
`HnszruAmn urnnurRro
`pRinuexn s PoKYNY
`INSTRUKCJA OBSI.UGI
`PyKOBOACTBO nO'| b3OBATEfl f
`MANUAL DE tNsrRUcOrs
`
`INSTRUCTION GUIDE
`GUIDE D'INSTRUCTIONS
`BEDIENUNGSANLEITUNG
`HANDLEIDING
`MANUALE DIISTRUZIONI
`MANUAL DE INSTRUCCIONES
`
`-z
`
`Ex. 1020 - Page 17 of 25
`
`

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`Ex. 1020 - Page 18 of 25
`
`Ex. 1020 - Page 18 of 25
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`

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`Ex. 1020 - Page 20 of 25
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`Ex. 1020 - Page 21 of 25
`
`

`

`l1i:ln',:,".:li,'lrt.e cricksare s;curitv Anchor on voul raptop?
`. Before installing ihe ClickSafe Securiiy Anchor you may need
`to loosen tk'e sclewii"" t+t't stepi2 through 4'
`
`: i:3il: 3i..,..' o :' q,': ?'.", T :,:H:X ;, iffI ll il :,: 3,?,
`iipeut 6tre utle
`on'r'or'
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`de desserr"' rt''ul! pliit al ;ep6ter les 6tapes 2 a 4'
`:"H;:n["t:il3'i eligite 1' cr i cksafe secu rtiv An ch o r a uf
`lhrem LatoP zu instllliern?
`sie
`. Vor der Install;;;;;;^ clicksafe securitv +":h?lmirssen
`tockein' wiede rholen sie
`moel icher*ti# ii't itt't "'ut
`;;#ii;Btnd die schritte 2bis 4'
`
`Ex. 1020 - Page 22 of 25
`
`

`

`Ycrpa uex ue Heucn pa enocrerl
`. He nnoxere ycraHoBkrrb 3aMoK ClickSafe Security Anchor sa
`nopraril BH ur r7r roun urcrep?
`. flpexge L{eM ycraHoBr4rb 3aMor ClickSafe Security Anchor,
`ocna6ure KpenneHne n noBTopnre 4erZcrarn 2-4.
`Resolug6o de problemas
`. Esta com problemas em instalar o ClickSafe Security Anchor
`no seu computador portdtil?
`. Antes de instalar o ClickSafe Security Anchor, poderA ter de
`desapertar o parafuso e depois repetir os passos 2 a 4.
`
`Kensington and the ACCO name and design are registered trademarks ofACCO Brands. The
`Kensington Promise is a service mark of ACCO Brands. All other registered and unregistered
`trademarks are the property of their respective owners. Covered by one or more of U5 Pat. No's
`; 6,360,4O5.
`6,081,97 4 ; 6,fll,936
`O20l-1 Kensington Computer Products Croup, a division ofACCO Brands. Any unauthorized
`copying, duplicating, or other reproduction of the contents hereof is prohibited without written
`consent from Kensington Computer Products Group. All rights reserved. 03/11
`
`For technica support visit
`Pour tolt support
`techn que veullez visiter:
`
`C o m p l e t e w a r r a n t y t e r m s a r e a v a i l a b l e a t
`www.warra nty.kensington.com
`
`d?
`
`Kensington Computer
`Products Group
`A Division ofACCO Brands
`333 Twin Dolphin Drive,
`6th Floor
`Redwood Shores, CA 94065
`
`ACCO Brands Europe
`Oxford House
`Oxford Road
`Aylesbury
`Bucks, HP21,852
`United Kingdom
`
`ACCO BrandsCanada A€€OAustralia
`5 Precidio Court
`Level 2,8 Lord St
`BramDton
`Botanv NsW 2019
`Ontaiio, 165 687
`PO Box 311
`Rosebery NSW l-445
`Canada
`Australia
`
`Ex. 1020 - Page 23 of 25
`
`

`

`PLAI]YTIFF THI]YK PRODTICTS , ilYC
`
`I]YFRI]YGEME]YT COIVT
`
`EXHIBIT 2
`
`Ex. 1020 - Page 24 of 25
`
`

`

` locking device
`
`cable permanently
`attached to the locking
`device at one end
`
`internal locking
`mechanism
`
`anchoring end
`
`captive security rod or
`spike
`
`protruding end— i. 1020 - Page 25 of 25
`
`Ex. 1020 - Page 25 of 25
`
`captive security rod or
`spike
`
`anchoring end
`
`protruding end
`
`locking device
`
`internal locking
`mechanism
`
`cable permanently
`attached to the locking
`device at one end
`
`