new allegations: emphasis plank-- partial excerpt
COUNT ONE INFRINGEMENT OF THE ’108 PATENT BY DEFENDANT 11. Plaintiff re-alleges and incorporates by reference each of the allegations set forth in paragraphs 1 through 10 above. 12. The accused products include but are not limited to Defendant’s Flash Memory Storage products including but not limited to its iNAND (eMMC) products, Compact Flash card products, microSD card products, SD card products, USB products, mSATA SSD products, SATA SSD products, and/or NAND Controller products. The primary and substantial purpose of the accused products is to write to and store data in electronic format in non-volatile flash memory. 13. Defendant has directly and indirectly infringed and is directly and indirectly infringing Claim 1 of the ’108 patent in violation of 35 U.S.C. § 271, et seq., by making, using, offering for sale, selling in the United States and/or importing into the United States without authority, the accused products identified above. Claim 1 of the ’108 patent teaches a method of memory management for a non-volatile storage medium. The method comprises several steps, which generally involves, without limitation, writing electronic data segments from volatile, temporary memory to a non-volatile, long-term storage medium by linking data segments according to a number of specified steps
