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Re: Gamco post# 431757

Monday, 11/06/2023 10:26:38 PM

Monday, November 06, 2023 10:26:38 PM

Post# of 432754
PRAYER FOR RELIEF

126. WHEREFORE, InterDigital respectfully requests that this Court enter judgment
in favor of InterDigital as follows:


(a) That Lenovo is liable for infringement, contributing to the infringement, and/or
inducing the infringement of one or more claims of the Patents-in-Suit;

(b) An award of damages adequate to compensate InterDigital for the infringement that
has occurred, pursuant to 35 U.S.C. § 284, including prejudgment and post-judgment interest;

(c) An award of enhanced damages including, without limitation, treble damages for
willful infringement
pursuant to 35 U.S.C. § 284;

(d) An accounting and/or supplemental damages for all damages occurring after any
discovery cutoff and through the Court’s decision regarding the imposition of a permanent
injunction
;


(e) An award of attorneys’ fees based on this being an exceptional case pursuant to 35
U.S.C. § 285, including prejudgment interest on such fees;

(f) Enter a permanent injunction against all Lenovo products found to infringe the
Patents-in-Suit;


(g) Award, in lieu of an injunction, a compulsory forward royalty;

(h) Costs and expenses in this action; and

(i) An award of any further relief that this Court deems just and proper.

"Intellectuals solve problems; geniuses prevent them." - Albert Einstein

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