Case 8:17-cv-00981-JVS-JCG Document 57-1 Filed 02/26/18 Page 1 of 4 Page ID #:987
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`LATHAM & WATKINS LLP
` Bradley A. Hyde (Bar No. 301145)
`bradley.hyde@lw.com
`650 Town Center Drive – 20th Floor
`Costa Mesa, California 92626
`Telephone: (714) 540-1235
`Facsimile: (714) 755-8290
`
`LATHAM & WATKINS LLP
` Charles H. Sanders (pro hac vice)
`charles.sanders@lw.com
` Anant K. Saraswat (pro hac vice)
`anant.saraswat@lw.com
`200 Clarendon Street
`Boston, Massachusetts 02116
`Telephone: (617) 948-6000
`Facsimile: (617) 948-6001
`
`LATHAM & WATKINS LLP
` Lesley Hamming (pro hac vice)
`lesley.hamming@lw.com
`330 N. Wabash Avenue, Suite 2800
`Chicago, Illinois 60611
`Telephone: (312) 876-7700
`Facsimile: (312) 993-9767
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`Attorneys for Defendants SEOUL
`SEMICONDUCTOR CO., LTD and
`SEOUL SEMICONDUCTOR, INC.
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`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`SOUTHERN DIVISION
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` CASE NO. 8:17-CV-00981-JVS-JCG
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`DECLARATION OF ANANT K. SARASWAT
`IN SUPPORT OF DEFENDANTS’ MOTION
`TO STAY PENDING INTER PARTES REVIEW
`
`Judge: Honorable James V. Selna
`Date: March 26, 2018
`Time: 1:30 pm
`Courtroom: 10C
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`Plaintiff,
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` DOCUMENT SECURITY SYSTEMS,
`INC.,
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`v.
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`SEOUL SEMICONDUCTOR CO.,
`LTD. and SEOUL
`SEMICONDUCTOR, INC.,
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`
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`Defendants.
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`AT T ORNEYS AT L AW
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`CASE NO. 8:17-cv-00981-JVS-JCG
`DECL. OF A. SARASWAT ISO SEOUL’S MOTION
`TO STAY PENDING INTER PARTES REVIEW
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`Case 8:17-cv-00981-JVS-JCG Document 57-1 Filed 02/26/18 Page 2 of 4 Page ID #:988
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`I, Anant K. Saraswat, declare as follows:
`I am an attorney at the law firm of Latham &Watkins LLP and am
`1.
`counsel of record for Seoul Semiconductor Co., Ltd. (“SSC”) and Seoul
`Semiconductor, Inc. (“SSI”) (collectively, “Seoul” or “Defendants”) in this matter.
`I submit this declaration in support of Defendants’ Motion to Stay
`2.
`Pending Inter Partes Review.
`This declaration is based on my personal knowledge of the facts stated
`3.
`below and, if called upon as a witness, I would testify competently to them based
`on such personal knowledge.
`Document Security Systems, Inc. (“DSS”) has only produced the
`4.
`patents and their file histories thus far in discovery; Seoul has produced the prior
`art cited in its invalidity contentions, served on February 5, 2018, as well as some
`of DSS’s publically-available financial documents.
`DSS served its first set of interrogatories and requests for production
`5.
`on January 24; Seoul served the same on DSS on February 2. The parties have not
`yet negotiated a protective order.
`Neither party has noticed or taken any depositions.
`6.
`7.
`Attached hereto as Exhibit A is a true and correct copy of DSS’s
`Disclosure Of Asserted Claims And Infringement Contentions.
`Attached hereto as Exhibit B is a true and correct copy of DSS’s 2017
`8.
`Third Quarter 10-Q Report.
`Attached hereto as Exhibit C is a true and correct copy of DSS’s
`9.
`Proceeds Investment Agreement.
`10. Attached hereto as Exhibit D is a true and correct copy of the
`Decision to Institute Inter Partes Review in SK Hynix Inc.’s IPR Petition against
`DSS Technology challenging 1-12 of U.S. Patent No. 6,784,552.
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`CASE NO. 8:17-cv-00981-JVS-JCG
`DECL. OF A. SARASWAT ISO SEOUL’S MOTION
`TO STAY PENDING INTER PARTES REVIEW
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`Case 8:17-cv-00981-JVS-JCG Document 57-1 Filed 02/26/18 Page 3 of 4 Page ID #:989
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`11. Attached hereto as Exhibit E is a true and correct copy of SK Hynix
`and DSS Technology’s Joint Motion to Terminate Inter Partes Review of claims
`1-12 of U.S. Patent No. 6,784,552.
`12. Attached hereto as Exhibit F is a true and correct copy of the Final
`Written Decision in Apple, Inc.’s (“Apple’s”) IPR petition against DSS
`Technology Management, Inc. (“DSS Technology”) challenging claims 1-4 of U.S.
`Patent No. 6,128,290.
` Attached hereto as Exhibit G is a true and correct copy of the Final
`13.
`Written Decision in Apple’s IPR petition against DSS Technology challenging
`claims 6, 7, 9, and 10 of U.S. Patent No. 6,128,290.
`14. Attached hereto as Exhibit H is a true and correct copy of the Final
`Written Decision in Intel Corporation’s and Qualcomm Incorporated’s IPR petition
`against DSS Technology challenging claims 8-12 of U.S. Patent No. 6,784,552.
`15. Attached hereto as Exhibit I is a true and correct copy of the Final
`Written Decision in Intel Corporation’s and Qualcomm Incorporated’s IPR petition
`against DSS Technology challenging claims 1-7 of U.S. Patent No. 6,784,552.
`16. Attached hereto as Exhibit J is a true and correct copy of the Final
`Written Decision in Intel Corporation’s and Qualcomm Incorporated’s IPR petition
`against DSS Technology challenging claims 7-12, 15, and 17 of U.S. Patent No.
`5,965,924.
`17. Attached hereto as Exhibit K is a true and correct copy of the Final
`Written Decision in Intel Corporation’s and Qualcomm Incorporated’s IPR petition
`against DSS Technology challenging claims 1-6, 13, 14, and 16 of U.S. Patent No.
`5,965,924.
`18. Attached hereto as Exhibit L is a true and correct copy of the Final
`Written Decision in Samsung Electronics Co., Ltd.’s IPR petition against DSS
`Technology challenging claims 1-12 of U.S. Patent No. 6,784,552.
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`CASE NO. 8:17-cv-00981-JVS-JCG
`DECL. OF A. SARASWAT ISO SEOUL’S MOTION
`TO STAY PENDING INTER PARTES REVIEW
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`Case 8:17-cv-00981-JVS-JCG Document 57-1 Filed 02/26/18 Page 4 of 4 Page ID #:990
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`19. Attached hereto as Exhibit M is a true and correct copy of Judge
`Schroeder’s Order Granting Stay of Intel Litigation.
`20. Attached hereto as Exhibit N is a true and correct copy of Judge
`Gilstrap’s Order Granting Stay of Qualcomm Litigation.
`21. Attached hereto as Exhibit O is a true and correct copy of Seoul’s IPR
`petition against Document Security Systems, Inc. (“DSS”) challenging claims 1-9
`of U.S. Patent No. 6,949,771, filed on December 3, 2017.
`22. Attached hetero as Exhibit P is a true and correct copy of Seoul’s IPR
`petition against DSS challenging claims 1-3 of U.S. Patent No. 7,256,486, filed on
`December 21, 2017.
`23. Attached hereto as Exhibit Q is a true and correct copy of Seoul’s IPR
`petition against DSS challenging claims 1, 6, 7, 8, 15 and 17 of U.S. Patent No.
`7,524,087, filed on January 25, 2018.
`24. Attached hereto as Exhibit R is a true and accurate copy of Judge
`Carney’s Order Granting Stay in Boston Sci. Corp. v. Edwards Lifesciences Corp.,
`No. SACV 16-00730-CJC (GJSx) (C.D. Cal Sept. 8, 2017).
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`I declare under penalty of perjury under the laws of the United States that
`the foregoing is true and correct. Executed this 26th day of February, 2018.
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`Anant K. Saraswat (pro hac vice)
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`CASE NO. 8:17-cv-00981-JVS-JCG
`DECL. OF A. SARASWAT ISO SEOUL’S MOTION
`TO STAY PENDING INTER PARTES REVIEW
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