End User Programming" Used to Generate Such Results
Defendant's motion to compel plaintiff to disclose how it configured the accused products to produce alleged infringement was granted. "[Defendant] complains that neither the screenshots provided, not [plaintiff's] infringement contentions and citations to various portions of [defendant's] source code, disclose the particular configurations of the accused products that [plaintiff] alleges infringe. . . . Forcing [defendant] to 'guess' as to what infringement [plaintiff] alleges by its screenshots, regardless of whether [plaintiff] provided sufficient detail as to other infringement contentions, violates the principles of both Rule 26 and Pat. L.R. 3-1. . . . Because [plaintiff's] screenshots here merely show the result of the accused  process, the specific allegedly infringing product configurations and additional end use programming -- conditions that are at least arguably 'material to patentability' -- are required to properly put [defendant] on notice."
Vasudevan Software, Inc. v. International Business Machines Corporation, et. al., 5-09-cv-05897 (CAND June 15, 2011, Order) (Grewal, M.J.)