RE: Vino Driver - J A Kemp Ref: K41139GB JGL/CKS [JAK-DMS.FID7490692]

[Mike Lothian]

Dear Mr So

Vino Driver - Your Ref: K41139GB JGL/CKS

I acknowledge receipt of your letter of 14 October 2026 and the copies
of GB2484736 and GB2485613.

I am an individual hobbyist developer and I am not legally
represented. I set out my position briefly below. I do not accept that
any act of mine infringes either patent, and all my rights are
reserved

1. Domicile

I am domiciled in Scotland, not England and Wales. Under Schedule 4 to
the Civil Jurisdiction and Judgments Act 1982, a person domiciled in
Scotland is to be sued in Scotland. I would therefore expect any
proceedings your client may contemplate against me to be brought in
the Court of Session, and I would contest any attempt to bring them
elsewhere

2. Validity

Your letter states that it is irrelevant whether the inventions are
"easy" or familiar so long as the patents remain in force. I do not
agree. Invalidity is a complete defence to an infringement claim
(section 74(1)(a) of the Patents Act 1977), and any claim would be met
with a counterclaim for revocation under section 72

The UK IPO's own Section 17 search reports are instructive:

- GB1017882.0 (GB2484736), search dated 22 February 2011: seven
documents (EP1975916, US2009/074052, EP0653727, WO99/57908,
JP2002135593, US7197190 and US2008/049041) were each cited as category
X against claims 1-4 and 6-9 as filed.

- GB1019766.3 (GB2485613), search dated 22 March 2011: six documents
(EP0847203, US2006/0130103, WO98/26606, EP0782345, US2008/0298463 and
US6088395) were each cited as category X against every claim as filed,
claims 1-10.

In both cases the independent claims as filed contained no network or
transport limitation. The claims were granted only after being amended
to add delivery of the display data over a "general-purpose data
network" (and, for GB2485613, a "transport protocol" with an
"unpackaging" step). That added feature was not new. The patents' own
description admits that connecting an additional display to a computer
over USB was already common practice. It was also disclosed well
before the 2010 filing dates, for example in the RFB/VNC protocol
specification (January 1998), which delivers position-tagged
rectangular framebuffer updates over "any reliable transport". Prior
art not considered during prosecution also discloses the
compressed-frame-buffer and Haar-coded tile features, including
US5835082 (priority 1994) and US6272180 (priority 1997). I have a
fuller analysis and will rely on it if necessary

I would add that the methods claimed are performed by the display
control device itself, i.e. your client's own DisplayLink hardware,
purchased lawfully by its users

3. Open Invention Network

Synaptics Incorporated is an OIN licensee, and I am also an OIN
licensee (since 17/08/2026). I understand your client takes the
position that the OIN licence does not extend to the DisplayLink
patents. The OIN licence defines "Affiliate" as any person that "now
or in the future" is a Subsidiary of the licensee, and "Your Patents"
as patents under which the licensee "or any of Your Affiliates" has at
any time during the Capture Period the right to grant licences.
DisplayLink became part of Synaptics in July 2020. Please identify the
specific provision, or any Limitation Election made by your client
(with its date), on which your client relies to exclude these patents

Finally, I note your letter makes no specific request of me other than
acknowledgment of receipt. If your client has a specific proposal, I
remain open to discussing a sensible resolution, as I have said to
your client previously

Yours sincerely

Mike Lothian


On Wed, 14 Oct 2026 at 11:22, Clive So <cso@xxxxxxxxxx> wrote:
>
> Dear Mr Lothian
>
>
>
> Copies of the two patents mentioned in my letter below were missing – these are now attached.
>
>
>
> Yours sincerely
>
>
>
> Clive So
>
>
>
> Clive So
> Partner, European and UK Patent Attorney
> UPC Representative
> For J A Kemp LLP
>
>
>
> DD: +44 20 3077 8659
> T: +44 20 3077 8600
> E: cso@xxxxxxxxxx
> W:jakemp.com J A Kemp LLP
> 80 Turnmill Street
> London
> EC1M 5QU
>
>
>
>
> From: Clive So
> Sent: 14 October 2026 11:16
> To: 'mike@xxxxxxxxxxxxxx' <mike@xxxxxxxxxxxxxx>
> Cc: 'chiaki.ishii@xxxxxxxxxxxxxxxx' <chiaki.ishii@xxxxxxxxxxxxxxxx>; 'ipdocs@xxxxxxxxxxxxx' <ipdocs@xxxxxxxxxxxxx>; 'yiming.shen@xxxxxxxxxxxxx' <yiming.shen@xxxxxxxxxxxxx>; 'Andrew.Bateman@xxxxxxxxxxxxx' <Andrew.Bateman@xxxxxxxxxxxxx>; John Leeming <jleeming@xxxxxxxxxx>
> Subject: Vino Driver - J A Kemp Ref: K41139GB JGL/CKS [JAK-DMS.FID7490692]
>
>
>
> Dear Mr Lothian
>
>
>
> Vino Driver
>
> Our Ref: K41139GB JGL/CKS
>
> Please find attached our letter concerning your Vino Driver project.
>
>
>
> Kindly acknowledge receipt.
>
>
> Yours sincerely
>
>
>
> Clive So
>
> J A Kemp LLP is a Limited Liability Partnership, registered in England and Wales (registered number OC427581) and regulated by IPReg. Our registered office is at 80 Turnmill Street, London EC1M 5QU, UK. Our use of the word ‘partner’ refers to a member of J A Kemp LLP. This email and any earlier email in this chain, including any attachments, are confidential and may be subject to legal professional privilege. We do not authorise reading, copying or use by anyone other than the intended recipient. If you have received any emails from J A Kemp in error, please do not copy or disclose them but email us immediately at mail@xxxxxxxxxx or telephone us on + 44 20 3077 8600.
>
>

Attachment: GB2484736.pdf
Description: Adobe PDF document

Attachment: Letter to Mr Lothian K41139GB JGL CKS.pdf
Description: Adobe PDF document

Attachment: GB2485613.pdf
Description: Adobe PDF document

Attachment: Cease and Desist Follow-Up Notice_Mike Lothian_10-05-2026.pdf
Description: Adobe PDF document

Attachment: Lothian-Synaptics correspondence Jul-Oct 2026.pdf
Description: Adobe PDF document

Attachment: Cease and Desist Notice_Mike Lothian_08-17-2026 (1).pdf
Description: Adobe PDF document