`WESTERN DISTRICT OF WISCONSIN
`
`SCA Hygiene Products Aktiebolag (“AB”)
`and SCA Tissue North America, LLC,
`
`Plaintiffs,
`
`v.
`
`Tarzana Enterprises, LLC,
`
`Case No. 3:16-cv-00728-wmc
`SCA’S IDENTIFICATION OF CLAIM
`TERMS AND PROPOSED
`CONSTRUCTIONS
`
`Defendant.
`Pursuant to the Court’s Pretrial Conference Order (Dkt. No. 43), Plaintiffs SCA Hygiene
`Products Aktiebolag and SCA Tissue North America, LLC (collectively “SCA”) propose that the
`following terms, phrases, or clauses found in the asserted claims of the patents at issue in this
`case may be disputed and propose the following constructions. Claim terms, phrases, or clauses
`that SCA proposes should be construed under 35 U.S.C. § 112(6) are indicated as such below.
`For any claim terms, phrases, or clauses for the asserted patents not identified below, at this time
`SCA believes that no construction is necessary for such terms, phrases, or clauses and proposes
`that they be given their plain and ordinary meanings.
`
`Patent
`
`8,597,761
`
`Claim Terms, Phrases, or
`Clauses
`“offset”
`
`9,320,372
`
`“offset”
`
`Proposed Construction
`
`An intentionally or
`deliberately designed
`distance from a specified
`point as opposed to a
`known and expected
`manufacturing variance.
`
`An intentionally or
`deliberately designed
`distance from a specified
`point as opposed to a
`known and expected
`manufacturing variance.
`
`1
`
`Relevant Asserted
`Claims
`1 (and claims
`depending
`therefrom)
`
`1 (and claims
`depending
`therefrom)
`
`Cascades
`EX1005
`
`
`
`
`
`SCA reserves the right to add claim terms, phrases, or clauses for consideration by the
`
`parties in the event that the proposed identification or construction for the claim terms, phrases,
`
`or clauses by Tarzana affects SCA’s understanding or likelihood of dispute of the patents’ terms.
`
`Further, SCA reserves the right to supplement, amend, or otherwise modify its identification or
`
`construction of claim terms, phrases, or clauses.
`
`
`
`
`
`
`
`2
`
`
`
`
`
`Dated: May 17, 2017
`
`
`
`
`
`
`
`
`
`
`
`/s/ Kevin W. Kirsch
`
`
`
`Respectfully submitted,
`
`By:
`
`Kevin W. Kirsch
`kkirsch@bakerlaw.com
`David A. Mancino
`dmancino@bakerlaw.com
`Kevin P. Flynn
`kflynn@bakerlaw.com
`BAKER & HOSTETLER LLP
`312 Walnut Street, Suite 3200
`Cincinnati, Ohio 45202-4074
`Telephone: (513) 929-3400
`Facsimile: (513) 929-0303
`
`Jared A. Brandyberry
`jbrandyberry@bakerlaw.com
`BAKER & HOSTETLER LLP
`1801 California Street, Suite 4400
`Denver, Colorado 80202-2662
`Telephone: (303) 764-4072
`Facsimile: (303) 861-7805
`
`Anthony A. Tomaselli
`aat@quarles.com
`Anita Marie Boor
`anita.boor@quarles.com
`33 East Main Street, Suite 900
`Madison, Wisconsin 53703
`Telephone: (608) 251-5000
`Facsimile: (608) 251-9166
`
`Attorneys for Plaintiff
`SCA Hygiene Products Aktiebolag and
`SCA Tissue North America, LLC
`
`
`
`
`3
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on May 17, 2017, pursuant to the agreement of the parties, I
`
`electronically served the foregoing via electronic mail to Tarzana’s counsel of record:
`
`Rudolph A. Telscher, Jr., pro hac vice
`rudy.telscher@huschblackwell.com
`Kara R. Fussner, pro hac vice
`kara.fussner@huschblackwell.com
`Daisy Manning, pro hac vice
`daisy.manning@huschblackwell.com
`HUSCH BLACKWELL LLP
`190 Carondelet Plaza, Suite 6000
`St. Louis, Missouri 63105
`Phone:
`(314) 480-1500
`Fax:
`
`(314) 480-1505
`
`Thomas P. Heneghan
`tom.heneghan@huschblackwell.com
`HUSCH BLACKWELL LLP
`33 East Main Street, Suite 300
`P.O. Box 137
`Madison, Wisconsin 53701
`Phone:
`(608) 234-6031
`Fax:
`
`(608) 258-7138
`Counsel for Defendant Tarzana Enterprises, LLC
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Kevin P. Flynn
`
`
`
`Kevin P. Flynn
`
`
`
`
`
`
`4
`
`
`
`
`
`
`
`
`
`
`
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