Joint Appendix One

Case _>: 10-cv-07678-JFW -DTB
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Document 65-1 Filed 10/07/11 Page 14 of 36 Page ID
#:1291
Nanoptix's Alleged Uncontroverted Response in Opposition
Facts
37. The VIM printer set forth in tile
October 18th letter with price quotations
is the same Coca-Cola printer referred to
by Mr. Meyerhofer in his first and
second declarations to the PTO.
38. The October 18th letter from Mr.
Meyerhofer stated that "I am sending
you a revised quotation that addresses
the evolution of the CCUSA printer.
This is the same printer as before, but
includes the added options that were
requested (note that we have assigned a
new part number to the printer)." The
added options were 65ram media size, a
manual paper cutter/tear operation, a
real-time clock calendar and a
24VAC@4.5A input power handling
capability.
39. The October 18th letter included
higher prices for production unit quantity
($402.50 to $457.50) and phase l
prototypes ($23,500) compared to the
April 25th letter, but the same price
($850) for phase two prototype units.
The price changes reflected the
additional features requested by Coca-
Cola.
-A0400-
-14-
Rounds Decl. 22, Meyerhofer Tr.
36:21-37:15, 44:8-22.
Disputed. The "VM" printer is not also
referred to as the CCUSA printer. The
cited exhibit refers to PSA-66-CC
prototype printers, which were never
built. (M. Meyerhofer Dep. Tr. 128:16-
129:4.)
Rounds Decl. 1.5, Exhibit 16 at p. 143.
Undisputed.
Rounds Decl. 15, Exhibit 16 at pp.
144-45. Rounds Decl. 12, Exhibit 11
at pp. 137-38; Rounds Decl. 15,
Exhibit 16 at p. 143.
Undisputed as to the two documents
reflecting different dollar eanottnts.
Disputed to the extent it suggests the
printers referred to in the October 18 _
and April 25 th docmnents are the same
printer.
FLVEURELOG[C'S S"i_IT OF ISSUES OF/vlATERIAL FACT IN
OPP TO NANOPT]X_S MOTION
2:10-CV-0767g-JFW-DTB
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