In the United States District Court for the 

Northern District of Illinois 

Eastern Division

SRAM Corporation, ) 

 Plaintiff ) 

 v. ) 

AD-II Engineering, Inc., ) 

 Defendant. ) Civil Action No. 00-CV-6675 

________________________) Civil Action No. 01-CV-62 

 ) (Consolidated) 

AD-II Engineering, Inc., ) 

 Plaintiff, ) Judge Robert W. Gettleman 

 v. ) 

SRAM Corporation, ) 

 Defendant. ) 

DEFENDANT AD-II ENGINEERING, INC.’S 

MOTION FOR ENTRY OF FINAL JUDGMENT 

Defendant AD-II Engineering, Inc. (“AD-II”) hereby moves for entry of final judgment 

in its favor based upon the decision of the United States Court of Appeals for the Federal Circuit. 

SRAM Corp. v. AD-II Engineering, Inc., No. 2009-1170, 367 Fed.Appx. 150, 2010 WL 743885 

(Fed. Cir. Feb. 26, 2010). The Federal Circuit reversed this Court’s December 16, 2008 order of 

final summary judgment of liability in favor of SRAM Corporation (for which SRAM, LLC has 

been substituted). See also Exhibit A (first page of Federal Circuit Judgment in appeal No. 

2009-1170). 

 In this Court’s Order of December 16, 2008 (Ex. B), this Court “stay[ed] the issue of an 

accounting (including assessment of damages and willful infringement) until the appeal of the 

summary judgment order of liability is concluded.” See also the minute entry of the same date 

(Ex. C) (“The Court stays the issue of an accounting until the appeal of the summary judgment 

order of liability is concluded”). 

Case: 1:00-cv-06675 Document #: 387 Filed: 08/02/10 Page 1 of 3 PageID #:3524
Based upon the Federal Circuit’s decision, final judgment should now be entered in favor 

of AD-II Engineering, Inc., and against SRAM, LLC. AD-II submits a proposed form of the 

Final Judgment (Ex. D). 

Counsel for AD-II contacted counsel for SRAM, LLC concerning this motion and 

proposed Final Judgment but has not received a response. 

Dated: August 2, 2010 

/s/ James T. Malysiak 

James T. Malysiak 

Richard P. Campbell 

Jenner & Block LLP 

353 N. Clark Street 

Chicago, Illinois 60654-3456 

Telephone: 312-923-2813 

Facsimile: 312-923-2913 

Michael T. Brady 

Miller & Chevalier Chartered 

655 Fifteenth Street, N.W., Suite 900 

Washington, D.C. 20005-5701 

Telephone: (202) 626-5800 

Facsimile: (202) 628-0858 

Attorneys for AD-II Engineering, Inc. 

2

Case: 1:00-cv-06675 Document #: 387 Filed: 08/02/10 Page 2 of 3 PageID #:3525
CERTIFICATE OF SERVICE

The undersigned counsel for AD-II Engineering, Inc. hereby certifies that on August 2, 

2010, a true and correct copy of the foregoing AD-II Engineering, Inc.’s Motion for Entry of 

Final Judgment and Exhibits A through D were filed with the Court and served electronically by 

the Court’s CM/ECF System to all registered users as listed below: 

Robert E. Browne 

Dexter G. Benoit 

Neal, Gerber & Eisenberg LLP 

2 North LaSalle Street 

Chicago, Illinois 60602 

Telephone: 312-269-8000 

Facsimile: 312-269-1747 

(Via ECF) 

Richard B. Walsh, Jr. 

Frank B. Janoski 

Keith J. Grady 

Michael J. Hickey 

Lewis, Rice & Fingersh, L.C. 

500 North Broadway 

Suite 2000 

St. Louis, Missouri 63102 

Telephone: 314-444-7600 

Facsimile: 314-241-6056 

(Via ECF) 

/s/ James T. Malysiak

One of the Attorneys for 

AD-II Engineering, Inc. 

3

Case: 1:00-cv-06675 Document #: 387 Filed: 08/02/10 Page 3 of 3 PageID #:3526