EXHIBIT 5 

Case 6:20-cv-00245-ADA Document 48-3 Filed 11/09/21 Page 1 of 8
1

From:

Sent:

To:

Cc:

Subject:

Lilian, 

For the reasons outlined in our September 10, 2021 letter and those you mention below, we confirm that Caddo 

withdraws its infringement allegations regarding the redesigned website for the ‘880 and ‘127 patents. 

Best, 

Veronica Schad <vschad@devlinlawfirm.com>

Wednesday, September 22, 2021 10:59 AM

Mao, Lillian J.; Alex Chan; Timothy Devlin

bshelton; coburn; Frost, Claudia; Vikhyat Kaushal; Jensen, Travis

RE: Caddo v. Microchip - Plaintiffs Final Infringement Contentions

The information contained in this communication is confidential and is intended only for the use of the intended addressee. It is the 

property of Devlin Law Firm LLC, and may contain information subject to attorney-client privilege and/or may constitute inside 

information. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be 

unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail 

to correspondence@devlinlawfirm.com, and destroy this communication and all copies thereof, including all attachments.

From: Mao, Lillian J. <lmao@orrick.com> 

Sent: Monday, September 13, 2021 2:56 PM 

To: Veronica Schad <vschad@devlinlawfirm.com>; Alex Chan <achan@devlinlawfirm.com>; Timothy Devlin 

<tdevlin@devlinlawfirm.com> 

Cc: bshelton <bshelton@sheltoncoburn.com>; coburn <coburn@sheltoncoburn.com>; Frost, Claudia 

<cfrost@orrick.com>; Vikhyat Kaushal <vkaushal@devlinlawfirm.com>; Jensen, Travis <tjensen@orrick.com> 

Subject: RE: Caddo v. Microchip - Plaintiffs Final Infringement Contentions 

Veronica, 

Thank you for the letter last Friday and today’s call regarding Caddo’s infringement contentions. 

As discussed on the call, we’re asking Caddo to confirm in writing that it is withdrawing its infringement 

allegations regarding the redesigned website for the ’880 and ‘127 patents. All of the asserted independent 

claims for those two patents recite displaying items “upon provisional selection” of an active link. The 

specification makes clear that “provisional selection” is synonymous with “rolling over.” See ’127 Patent, 4:46-

50 (“The user browses by ‘rolling-over’ (provisionally selecting) an element with a pointing device...”). Caddo 

appears to make identical DOE arguments for both the “provisional selection” and “rolling over” 

limitations. Compare, e.g., FIC Ex. E at 18-19 with id. at 29. Thus, given that Caddo withdrew “its DoE 

infringement allegations for the ‘roll[ed/ing] over’ limitations” (9/10/2021 Letter at 7), please confirm it is also 

withdrawing the DOE allegations for the “provisional selection” limitations. 

Case 6:20-cv-00245-ADA Document 48-3 Filed 11/09/21 Page 2 of 8
2

We will follow up separately by letter regarding the other issue discussed today, which relates to the ’301 and 

’836 patents. 

Best, 

Lillian 

Lillian J. Mao

Senior Associate

Orrick

Silicon Valley

T +1-650-614-7410 

lmao@orrick.com 

From: Veronica Schad <vschad@devlinlawfirm.com> 

Sent: Thursday, September 2, 2021 7:54 AM 

To: Jensen, Travis <tjensen@orrick.com>; Alex Chan <achan@devlinlawfirm.com>; Timothy Devlin 

<tdevlin@devlinlawfirm.com> 

Cc: bshelton <bshelton@sheltoncoburn.com>; coburn <coburn@sheltoncoburn.com>; Frost, Claudia 

<cfrost@orrick.com>; Vikhyat Kaushal <vkaushal@devlinlawfirm.com>; Mao, Lillian J. <lmao@orrick.com> 

Subject: RE: Caddo v. Microchip - Plaintiffs Final Infringement Contentions 

Travis, 

Caddo is available to meet and confer next Friday (09/10) from noon-5PM EST. If you are available during these times, 

please circulate a dial-in. 

Best, 

The information contained in this communication is confidential and is intended only for the use of the intended addressee. It is the 

property of Devlin Law Firm LLC, and may contain information subject to attorney-client privilege and/or may constitute inside 

information. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be 

unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail 

to correspondence@devlinlawfirm.com, and destroy this communication and all copies thereof, including all attachments.

From: Jensen, Travis <tjensen@orrick.com> 

Sent: Wednesday, September 1, 2021 2:21 PM 

To: Veronica Schad <vschad@devlinlawfirm.com>; Alex Chan <achan@devlinlawfirm.com>; Timothy Devlin 

<tdevlin@devlinlawfirm.com> 

Cc: bshelton <bshelton@sheltoncoburn.com>; coburn <coburn@sheltoncoburn.com>; Frost, Claudia 

<cfrost@orrick.com>; Vikhyat Kaushal <vkaushal@devlinlawfirm.com>; Mao, Lillian J. <lmao@orrick.com> 

Subject: RE: Caddo v. Microchip - Plaintiffs Final Infringement Contentions 

Veronica et al., 

Case 6:20-cv-00245-ADA Document 48-3 Filed 11/09/21 Page 3 of 8
3

Please provide your availability to meet and confer this Friday or on Tuesday and Wednesday of next week. Thanks, 

Travis 

From: Veronica Schad <vschad@devlinlawfirm.com> 

Sent: Wednesday, August 18, 2021 1:22 PM 

To: Jensen, Travis <tjensen@orrick.com>; Alex Chan <achan@devlinlawfirm.com>; Timothy Devlin 

<tdevlin@devlinlawfirm.com> 

Cc: bshelton <bshelton@sheltoncoburn.com>; coburn <coburn@sheltoncoburn.com>; Frost, Claudia 

<cfrost@orrick.com>; Vikhyat Kaushal <vkaushal@devlinlawfirm.com> 

Subject: RE: Caddo v. Microchip - Plaintiffs Final Infringement Contentions 

Travis, 

Caddo is reviewing Microchip’s letter, and disagrees with Microchip’s characterizations. Caddo will provide a 

substantive response shortly. 

Best, 

The information contained in this communication is confidential and is intended only for the use of the intended addressee. It is the 

property of Devlin Law Firm LLC, and may contain information subject to attorney-client privilege and/or may constitute inside 

information. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be 

unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail 

to correspondence@devlinlawfirm.com, and destroy this communication and all copies thereof, including all attachments.

From: Jensen, Travis <tjensen@orrick.com> 

Sent: Friday, August 13, 2021 1:52 PM 

To: Veronica Schad <vschad@devlinlawfirm.com>; Alex Chan <achan@devlinlawfirm.com>; Timothy Devlin 

<tdevlin@devlinlawfirm.com> 

Cc: bshelton <bshelton@sheltoncoburn.com>; coburn <coburn@sheltoncoburn.com>; Frost, Claudia 

<cfrost@orrick.com>; Vikhyat Kaushal <vkaushal@devlinlawfirm.com> 

Subject: RE: Caddo v. Microchip - Plaintiffs Final Infringement Contentions 

Counsel, 

Please see the attached correspondence. Thanks, Travis 

From: Veronica Schad <vschad@devlinlawfirm.com> 

Sent: Thursday, August 5, 2021 10:18 AM 

To: Jensen, Travis <tjensen@orrick.com>; Alex Chan <achan@devlinlawfirm.com>; Timothy Devlin 

<tdevlin@devlinlawfirm.com> 

Cc: bshelton <bshelton@sheltoncoburn.com>; coburn <coburn@sheltoncoburn.com>; Frost, Claudia 

<cfrost@orrick.com>; Vikhyat Kaushal <vkaushal@devlinlawfirm.com> 

Subject: RE: Caddo v. Microchip - Plaintiffs Final Infringement Contentions 

Counsel, 

Case 6:20-cv-00245-ADA Document 48-3 Filed 11/09/21 Page 4 of 8
4

Pursuant to our meet and confer last Friday, please see the attached letter. 

Best, 

The information contained in this communication is confidential and is intended only for the use of the intended addressee. It is the 

property of Devlin Law Firm LLC, and may contain information subject to attorney-client privilege and/or may constitute inside 

information. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be 

unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail 

to correspondence@devlinlawfirm.com, and destroy this communication and all copies thereof, including all attachments.

From: Veronica Schad 

Sent: Tuesday, July 27, 2021 11:58 AM 

To: Jensen, Travis <tjensen@orrick.com>; Alex Chan <achan@devlinlawfirm.com>; Timothy Devlin 

<tdevlin@devlinlawfirm.com> 

Cc: bshelton <bshelton@sheltoncoburn.com>; coburn <coburn@sheltoncoburn.com>; Frost, Claudia 

<cfrost@orrick.com> 

Subject: RE: Caddo v. Microchip - Plaintiffs Final Infringement Contentions 

Travis, 

We are available for a meet and confer on Friday between 1-4PM CT. 

Best, 

The information contained in this communication is confidential and is intended only for the use of the intended addressee. It is the 

property of Devlin Law Firm LLC, and may contain information subject to attorney-client privilege and/or may constitute inside 

information. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be 

unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail 

to correspondence@devlinlawfirm.com, and destroy this communication and all copies thereof, including all attachments.

From: Jensen, Travis <tjensen@orrick.com> 

Sent: Monday, July 26, 2021 6:53 PM 

To: Veronica Schad <vschad@devlinlawfirm.com>; Alex Chan <achan@devlinlawfirm.com>; Timothy Devlin 

<tdevlin@devlinlawfirm.com> 

Cc: bshelton <bshelton@sheltoncoburn.com>; coburn <coburn@sheltoncoburn.com>; Frost, Claudia 

<cfrost@orrick.com> 

Subject: RE: Caddo v. Microchip - Plaintiffs Final Infringement Contentions 

Hi Veronica, 

Case 6:20-cv-00245-ADA Document 48-3 Filed 11/09/21 Page 5 of 8
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It has been nearly two weeks since your message below and Caddo has provided no substantive response. Please 

provide your availability to meet and confer this Thursday and Friday regarding the issues raised in my July 9 

letter. Thanks, Travis 

From: Veronica Schad <vschad@devlinlawfirm.com> 

Sent: Tuesday, July 13, 2021 1:03 PM 

To: Jensen, Travis <tjensen@orrick.com>; Alex Chan <achan@devlinlawfirm.com>; Timothy Devlin 

<tdevlin@devlinlawfirm.com> 

Cc: bshelton <bshelton@sheltoncoburn.com>; coburn <coburn@sheltoncoburn.com>; Frost, Claudia 

<cfrost@orrick.com> 

Subject: RE: Caddo v. Microchip - Plaintiffs Final Infringement Contentions 

Travis, 

Caddo disagrees with the mischaracterizations in Microchip’s letter. We will respond in full shortly. 

Best, 

The information contained in this communication is confidential and is intended only for the use of the intended addressee. It is the 

property of Devlin Law Firm LLC, and may contain information subject to attorney-client privilege and/or may constitute inside 

information. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be 

unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail 

to correspondence@devlinlawfirm.com, and destroy this communication and all copies thereof, including all attachments.

From: Jensen, Travis <tjensen@orrick.com> 

Sent: Friday, July 9, 2021 11:43 AM 

To: Veronica Schad <vschad@devlinlawfirm.com>; Alex Chan <achan@devlinlawfirm.com>; Timothy Devlin 

<tdevlin@devlinlawfirm.com> 

Cc: bshelton <bshelton@sheltoncoburn.com>; coburn <coburn@sheltoncoburn.com>; Frost, Claudia 

<cfrost@orrick.com> 

Subject: Caddo v. Microchip - Plaintiffs Final Infringement Contentions 

Counsel, 

Please see the attached correspondence regarding Plaintiffs’ Final Infringement Contentions in the Microchip 

case. Thanks, Travis 

Travis M. Jensen

Partner, IP Litigation

Orrick

Silicon Valley

T 650-614-7458 

tjensen@orrick.com

Case 6:20-cv-00245-ADA Document 48-3 Filed 11/09/21 Page 6 of 8
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the error by return e-mail and please delete this message from your system. Thank you in advance for your cooperation. 

For more information about Orrick, please visit http://www.orrick.com. 

In the course of our business relationship, we may collect, store and transfer information about you. Please see our privacy policy at 

https://www.orrick.com/Privacy-Policy to learn about how we use this information. 

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the error by return e-mail and please delete this message from your system. Thank you in advance for your cooperation. 

For more information about Orrick, please visit http://www.orrick.com. 

In the course of our business relationship, we may collect, store and transfer information about you. Please see our privacy policy at 

https://www.orrick.com/Privacy-Policy to learn about how we use this information. 

NOTICE TO RECIPIENT | This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you 

received this e-mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of 

the error by return e-mail and please delete this message from your system. Thank you in advance for your cooperation. 

For more information about Orrick, please visit http://www.orrick.com. 

In the course of our business relationship, we may collect, store and transfer information about you. Please see our privacy policy at 

https://www.orrick.com/Privacy-Policy to learn about how we use this information. 

NOTICE TO RECIPIENT | This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you 

received this e-mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of 

the error by return e-mail and please delete this message from your system. Thank you in advance for your cooperation. 

For more information about Orrick, please visit http://www.orrick.com. 

In the course of our business relationship, we may collect, store and transfer information about you. Please see our privacy policy at 

https://www.orrick.com/Privacy-Policy to learn about how we use this information. 

NOTICE TO RECIPIENT | This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you 

received this e-mail in error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of 

the error by return e-mail and please delete this message from your system. Thank you in advance for your cooperation. 

Case 6:20-cv-00245-ADA Document 48-3 Filed 11/09/21 Page 7 of 8
7

For more information about Orrick, please visit http://www.orrick.com. 

In the course of our business relationship, we may collect, store and transfer information about you. Please see our privacy policy at 

https://www.orrick.com/Privacy-Policy to learn about how we use this information. 

Case 6:20-cv-00245-ADA Document 48-3 Filed 11/09/21 Page 8 of 8