Within
fourteen (14) days after service of the Initial Non-Infringement and Invalidity
Contentions under LPR 2.3, each party claiming patent infringement shall
serve upon all parties its “Initial Response to Non-Infringement and Invalidity Contentions.”
(a) With respect to invalidity issues, the
initial response shall contain a chart, responsive to
the chart required by LPR 2.3(b)(3), that states as to each identified element in
each asserted claim, to the extent then known, whether the party admits to the
identity of elements in the prior art and, if not, the reason for such denial.
(b) In response to denials of infringement, if the party asserting infringement intends to rely upon Doctrine of Equivalents, such party must include an initial explanation of each function, way, and result that is equivalent and why any differences are not substantial, to the extent not previously provided in response to LPR 2.2(d)