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).

1086639
 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.

AN DREW LYKIARDOPOULOS
POWELL GILBERT LLP

STATEMENT OF TRUTH

The Claimant believes that the facts stated in these Particulars of Claim are true. I am
authorised by the Claimant to sign this Statement.

J)V 'Al~ .J'L0

Signed .~ .Q"..~ ........ '..................... .
Full Name ZOE MARIANNE BUTLER
Position PARTNER
Date 3...&b.~ . M. r~
... 1 .......... .
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

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

4
625331