With the Invalidity Contentions, the party opposing a claim of patent infringement must produce or make
available for inspection and copying:
a. Source code, specifications, schematics, flow charts, artwork, formulas, or other documentation
sufficient to show the operation of any aspects or elements of any Accused Instrumentality identified
by the patent claimant in its Patent L.R. 3.1.c chart; and
b. A copy of each item of prior art identified pursuant to Patent L.R. 3.3.a which does not appear in the
file history of the patent(s) at issue. To the extent any such item is not in English, an English
translation of the portion(s) relied upon must be produced.
