`adidas America, Inc.
`
`
`
`v.
`
`Under Armour, Inc.
`MapMyFitness, Inc.
`
`Plaintiffs,
`
`
`Defendants.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Civil Action No. 14-130-GMS
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT DELAWARE
`
`
`PLAINTIFFS ADIDAS AG AND ADIDAS AMERICA, INC.’S FOURTH
`SUPPLEMENTAL OBJECTIONS AND RESPONSES TO DEFENDANTS’
`FIRST SET OF INTERROGATORIES (NO. 12)
`
`Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, Local Rule 26.1,
`
`and stipulation of the parties (D.I. 67), Plaintiffs adidas AG and adidas America, Inc.
`
`(collectively, “adidas” or “Plaintiffs”), by undersigned counsel, hereby make the following
`
`Fourth Supplemental Objections and Responses to Defendants’ First Set of Interrogatories
`
`(No. 12).
`
`adidas incorporates by reference the General Objections and Reservation of Rights set
`
`forth in Plaintiffs Objections and Responses to Defendants’ First Set of Interrogatories.
`
`ADIDAS’S SUPPLEMENTAL OBJECTIONS AND RESPONSES
`
`INTERROGATORY NO. 12
`
`For each asserted claim of the adidas Patents-in-Suit, separately identify, by product
`
`name, version, description and/or other identifying characteristic, every product You contend
`
`embodies the alleged invention of the asserted claim and describe, on an element-by-element
`
`basis, the basis for your contention, whether made now or in the past, that the product so
`
`
`US2008 6579197 2
`
`
`
`
`UA-1014.001
`
`
`
`EXHIBIT A
`
`EXHIBIT A
`
`UA-1014.002
`
`UA-1014.002
`
`
`
`Adidas AG v. Under Armour, Inc. et al. Civil Action No. 1:14-cv-00130-GMS
`U.S. Patent No. 8,725,276 (Ellis) – Asserted Claim Nos. 3, 6, 7, 15, 18, 19, 22
`
`correlating the performance data
`with the position data with at least
`one processor; and
`
`The MMF App uses at least one processor to correlate the performance data received by the
`performance monitor (e.g., heart rate data, Intensity data, speed data, etc.) with the GPS data
`reflecting the user’s location at the time the performance data was collected. For example, as
`shown in the screenshot below, the user’s pace, heart rate, and elevation are correlated with the
`user’s location on the route at the time the data was collected (represented by the flame icon on
`the map):
`
`
`The MMF App simultaneously displays a graphical representation of the route data, the user’s
`current position, and performance data, such as the user’s heart rate or pace, as shown in the
`screenshots below:
`
`
`
`simultaneously displaying the
`position data and the performance
`data over a graphical
`representation of the route data
`during the traversal of the route
`with a display screen.
`
`UA-1014.003
`
`
`
`Adidas AG v. Under Armour, Inc. et al. Civil Action No. 1:14-cv-00130-GMS
`U.S. Patent No. 8,725,276 (Ellis) – Asserted Claim Nos. 3, 6, 7, 15, 18, 19, 22
`
`
`UA-1014.004
`
`
`
`Adidas AG v. Under Armour, Inc. et al. Civil Action No. 1:14-cv-00130-GMS
`U.S. Patent No. 8,725,276 (Ellis) – Asserted Claim Nos. 3, 6, 7, 15, 18, 19, 22
`
`
`
`18. The method of claim 16,
`wherein the position monitor
`comprises a global positioning
`satellite receiver.
`
`
`The MMF App is designed to be used on mobile devices such as the Apple iPhone, Android
`Phones, and Windows Phone. Each of these devices includes a global positioning satellite (GPS)
`receiver. See, e.g., https://support.mapmyfitness.com/hc/en-us/categories/200003344-Mobile-
`App-Questions The MMF App uses this “built-in GPS technology to provide users worldwide
`with the ability to map, record and share their exercise routes and workouts in an online
`database.” See, e.g., http://about.mapmyfitness.com/about/company-history/; See also, the GPS
`icon in the screenshot of the MMF app below:
`
`
`UA-1014.005
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