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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
e.Digital Corporation,
Plaintiff,
v.
iSmart Alarm, Inc. dba iSmartAlarm
Defendant.
Case No.: 3:15-cv-05793-JST
AMENDED JOINT CASE
MANAGEMENT STATEMENT AND
[PROPOSED] ORDER
CMC Date: August 3, 2016
Time: 2:00 p.m.
Ctrm: 9, 19th Floor
Judge: Hon. Jon S. Tigar
The parties to the above-entitled action jointly submit this Amended Joint Case
Management Statement and [Proposed] Order (“Amended JCMS”) pursuant to the Standing
Order for All Judges of the Northern District of California, dated July 1, 2011, Civil Local Rule
16-9, and the Court’s July 8, 2016 Order Terminating Motion for Stay (ECF No. 55). This
Amended JCMS is substantially the same as the Joint Case Management Statement filed on
March 16, 2016 (Docket No. 34) and the previous Amended JCMS filed April 1, 2016 (ECF No.
43) with the exception of the parties’ proposed dates, which have been adjusted to reflect the
termination of the stay and the setting of a new case management conference.
I. JURISDICTION & SERVICE
This is a civil action for infringement of five patents arising under the laws of the United
States relating to patents, 35 U.S.C. § 101, et seq., including, without limitation, 35 U.S.C. §§
271, 281. This court has subject matter jurisdiction over this case for patent infringement under
28 U.S.C. §§ 1331 and 1338(a) and pursuant to the patent laws of the United States of America,
35 U.S.C. § 101, et seq. All parties have been served in this matter. There are no outstanding
issues regarding jurisdiction and venue.
II. FACTS
On December 17, 2015, Plaintiff e.Digital Corporation (“Plaintiff” or e.Digital”) filed a
complaint for patent infringement against Defendant iSmart Alarm, Inc. (“Defendant” or
“iSmart”) in the Northern District of California. (ECF No. 1). e.Digital asserts the following five
patents against iSmart (collectively “the Asserted Patents”):
(1) United States Patent No. 8,306,514, entitled “System and Method for Managing
Mobile Communications” (“the ’514 patent”);
(2) United States Patent No. 8,311,522, entitled “System and Method for Managing
Mobile Communications” (“the ’522 patent”);
(3) United States Patent No. 8,311,524, entitled “System and Method for Managing
Mobile Communications” (“the ’524 patent”);
(4) United States Patent No. 9,002,331, entitled “System and Method for Managing
Mobile Communications” (“the ’331 patent”); and/or,

AMENDED JOINT CASE MANAGEMENT STATEMENT CASE NO. 3:15-CV-05793-JST
AND [PROPOSED] ORDER
3
(5) United States Patent No. 9,178,983, also entitled “System and Method for
Managing Mobile Communications” (“the ’983 patent”).
The accused products include but are not limited to iSmart’s sensor-based products and
systems, which include, without limitation, the Cube One, Motion Sensor, iCamera, iCamera
KEEP, Contact Sensor, Smart Switch, and Remote Tag, together with Defendant’s server, mobile
app and/or web-based services for remote monitoring and communication. e.Digital alleges that
these products and certain functions of the iSmart devices infringe upon the Asserted Patents.
iSmart filed an answer on February 18, 2016. (ECF No. 23).
III. LEGAL ISSUES
The principal legal issues that the Parties dispute are:
(1) The proper construction of the terms in the asserted claims of the Asserted Patents;
(2) Whether iSmart infringed, directly or indirectly, one or more claims of the
Asserted Patents under 35 U.S.C. § 271;
(3) Whether the claims of the Asserted Patents are invalid under 35 U.S.C. §§ 101,
102, 103, and/or 112;
(4) Whether e.Digital’s claims for relief and prayer for damages are barred by the
equitable doctrines of laches, waiver, and/or estoppel.
(5) If liability is established, to what damages e.Digital is entitled and whether such
damages are limited by 35 U.S.C. § 287 and, if so, to what extent;
(6) If liability is established, whether iSmart should be permanently enjoined from
infringement of the Asserted Patents;
(7) If liability and damages are established, to what extent e.Digital is entitled to
recover enhanced damages; and
(8) Whether either Party is entitled to recover costs or attorneys’ fees associated with
this lawsuit.
IV. MOTIONS
The parties intend to file motions for summary judgment on infringement/noninfringement
and patent validity/invalidity at an appropriate time in the case. iSmart filed a Motion for Stay

AMENDED JOINT CASE MANAGEMENT STATEMENT CASE NO. 3:15-CV-05793-JST
AND [PROPOSED] ORDER
4
Pending Inter Partes Review (“Motion”) (ECF No. 35) on March 17, 2016, and continued the
hearing to June 2, 2016 by filing and serving an amended notice of Motion on April 1, 2016. The
Court vacated the hearing on the motion (ECF No. 50) and, on July 8, 2016, terminated the
motion as moot (ECF No. 55).
V. AMENDMENT OF PLEADINGS
At this time, the Parties do not anticipate amending the pleadings, but believe that it is too
early to determine whether amendments may become necessary.
VI. EVIDENCE PRESERVATION
The Parties reviewed the ESI Guidelines and met and conferred regarding the reasonable
and proportionate steps necessary to preserve evidence relevant to the issues reasonably evident in
this action. The Parties have taken appropriate steps to preserve any and all evidence that may be
of relevance to the issues in this action, and which should be preserved under the proportionality
standard of Rule 26(b)(1) of the Federal Rules of Civil Procedure (“FRCP”).
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