CHANCERY DIVISION

PATENTS COURT

B ETWE E N:

MOTOROLA MOBILITY LLC (a company incorporated in the state of Delaware, USA)

Claimant - and-

BRITISH TELECOMMUNICATIONS PLC

Defendant

PARTICULARS OF CLAIM

1. The Claimant, a company incorporated and existing under the laws of the state of

Delaware, USA, acquired title to EP (UK) 1 088 446 B1 entitled "Dynamic Security for

Digital Television Receivers" (the "'Patent"), a copy of which is attached as Annex A, by

virtue of the following transactions related thereto:

(i) General Instrument Corporation assigned all right, title and interest in the

Patent to General Instrument Holdings, Inc. on 25 January 2013; and

(ii) General Instrument Holdings, Inc. assigned all right, title and interest in the

Patent to the Claimant on 25 January 2013.

These assignments are currently being registered at the UK Intellectual Property Office

and a copy of the registration documentation is attached as Annex B.

2. The Defendant is a company registered in the United Kingdom, which provides, inter

alia, telecommunication and home entertainment products and services under the 'BT'

brand. The Defendant is, for example, responsible for the provision of the BT Vision

Service (as defined in the Particulars of Infringement).

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3. The Patent is and has at all material times been in force.

4. The Defendant has carried out and/or threatens to carry out the acts referred to in the

Particulars of Infringement served herewith. In the premises the Defendant has infringed

and/or threatens to infringe the Patent.

5. By reason of the matters aforesaid the Claimant has suffered loss and damage.

6. Further, unless restrained by this Honourable Court, the Defendant threatens and

intends to carry out, continue and repeat the acts complained of herein whereby the

Claimant will suffer further loss and damage.

7. The Claimant is not at present aware of all of the Defendant's acts of infringeme~t but

will seek relief in respect of all such acts at trial.

8. The Claimant is entitled to and claims interest upon all sums found due to it herein

pursuant to section 35A of the Senior Courts Act 1981 and/or the Court's equitable

jurisdiction, at such a rate and for such a period as the Court considers appropriate.

AND THE CLAIMANT CLAIMS:

1) A declaration that the Patent has been infringed by the Defendant.

2) An injunction to restrain the Defendant (whether acting through its directors, officers,

servants, agents and/or howsoever otherwise) from doing, procuring and/or authorising

any acts that howsoever infringe the Patent.

3) An order for delivery up, or, at the Claimant's election, destruction upon oath, of all

material in the possession, power, custody or control of the Defendant, the keeping,

disposal or use of which would be in breach of the foregoing injunction.

4) An order that the judgment of this Honourable Court in this action, alternatively a brief

summary of it and/or its effect, be published and advertised at the expense of the

Defendant pursuant to Article 15 of Directive 2004/48/EC on the enforcement of

intellectual property and the Civil Procedure Rules Practice Direction 63 paragraph 26.2.

2 625331

5) An inquiry as to damages, or, at the Claimant's election, an account of profits (such an

inquiry or account to take into account the effect of the Intellectual Property Enforcement

Regulations 2006) in respect of each and every act of infringement of the Patent.

6) An order for payment by the Defendant of all sums found due to the Claimant together

with interest pursuant to section 35A of the Senior Courts Act 1981 and/or under the

equitable jurisdiction of the Court.

7) Costs together with interest thereon.

8) Further or other relief.

STATEMENT OF TRUTH

AN DREW L YKIARDOPOULOS

POWELL GILBERT LLP

The Claimant believes that the facts stated in these Particulars of Claim are true. I am

authorised by the Claimant to sign this Statement.

Signed

Full Name

J)V 'Al~ .J'L0 .~.Q" .. ~ ........ ' ..................... .

ZOE MARIANNE BUTLER

Position PARTNER

Date ... 13 .. . &b.~ .M. r~ .......... . Name of Claimant's solicitors firm: Powell Gilbert LLP

Served on the Defendant on the day of February 2013 by Powell Gilbert LLP of 85 Fleet

Street, London, EC4Y 1AE, solicitors for the Claimant.

Ref: ZBITW/MOT1.5

625331 3

625331

Claim No. HP13 AOO Co 1..0

IN THE HIGH COURT OF JUSTICE

CHANCERY DIVISION

PATENTS COURT

BETWEEN:

MOTOROLA MOBILITY LLC

(a company incorporated in the state of Delaware, USA)

Claimant

- and-

BRITISH TELECOMMUNICATIONS PLC

Defendant

PARTICULARS OF CLAIM

Powell Gilbert LLP 85 Fleet Street

London EC4Y 1AE

Tel. 02030408000 Fax. 02030408001

OX: 358 London/Chancery Lane Ref: ZBITW/MOT1.5 ·

Solicitors for the Claimant

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