Blackberry pointed Maliki in the right direction Looks like Blackberry pointed Malikie in the right direction on where to start the lawsuits 37. Defendant has been on notice of the ’847 Patent and a specific factual basis for its infringement of the ’847 Patent since at least on or about August 25, 2016. On information and belief, Defendant did not take any action to stop its infringement. 43. Defendant has been on notice of the ’397 Patent and a specific factual basis for its infringement of the ’397 Patent since at least on or about July 28, 2020. On information and belief, Defendant has not taken any action to stop its infringement 51. Defendant has been on notice of the ’147 Patent family since August 25, 2016. On information and belief, Defendant did not take any action to stop its infringement