Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 1 of 15 PageID #: 19812
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`Plaintiff,
`
`v.
`
`SOFTVIEW LLC,
`
`
`
`
`
`APPLE INC.; AT&T MOBILITY LLC;
`DELL INC.; HTC CORP.; HTC AMERICA,
`INC.; HUAWEI TECHNOLOGIES CO.,
`LTD.; FUTUREWEI TECHNOLOGIES,
`INC.; KYOCERA CORP.; KYOCERA
`WIRELESS CORP.; LG ELECTRONICS,
`INC.; LG ELECTRONICS USA, INC.; LG
`ELECTRONICS MOBILECOMM U.S.A.,
`INC.; MOTOROLA MOBILITY LLC;
`SAMSUNG ELECTRONICS CO., LTD.;
`SAMSUNG ELECTRONICS AMERICA,
`INC.; and SAMSUNG
`TELECOMMUNICATIONS AMERICA,
`LLC
`
`
`
`Defendants.
`
`
`
`
`
` Civil Action No. 10-389-LPS
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`(CONSOLIDATED)
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`MOVING DEFENDANTS’ REPLY IN SUPPORT OF MOTION TO STAY PENDING
`INTER PARTES REVIEW BY THE PATENT TRIAL AND APPEAL BOARD
`
`The issue presented by this motion is whether the potential resolution of this entire
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`litigation—or at a minimum, the significant simplification of the issues involved—warrants the
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`ten-month delay that would result from a stay pending the outcome of inter partes reviews.
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`Accordingly, the circumstances presented here are entirely different from the facts underlying
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`previous motions to stay pending the outcome of inter partes and ex parte reexaminations,
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`notwithstanding SoftView’s efforts to conflate the two situations. In particular, in the context of
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`the previous motion to stay, the Court recognized that 14 of the 20 patent claims asserted in this
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`litigation stood confirmed by the Patent Office in the reexaminations. D.I. 439 (Mem. Op. re
`
`SoftView Exhibit 2078-1
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`

`

`Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 2 of 15 PageID #: 19813
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`Mots. to Stay and Mots. to Dismiss) at 5. In contrast, the Patent Office has now found it
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`reasonably likely that every single patent claim asserted against all Defendants will be found
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`unpatentable in the inter partes reviews. Given this key distinction (among others)—which
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`SoftView ignores in its Opposition brief—the decision whether to stay this case is no longer, as
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`the Court previously acknowledged, a “close call.” Instead, all of the facts point in favor of a
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`stay. D.I. 369 (Hr’g Tr.) at 73:11-15.
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`ARGUMENT
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`A.
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`A Stay May Resolve This Litigation in Its Entirety and Would at Least
`Simplify the Issues while Conserving Party and Court Resources.
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`The pending inter partes reviews have placed at issue the validity of all 20 claims
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`asserted in this litigation and therefore may resolve the case in its entirety. As noted, this is a
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`key distinction from the earlier reexaminations that prompted the Defendants’ previous motion to
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`stay, in which only 6 of the 20 asserted patent claims stood rejected. D.I. 439 at 5. The potential
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`efficiency benefits of a stay are far greater here than they were in the context of the earlier
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`reexaminations, as there is now the reasonable likelihood that all further litigation over these
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`patents will be ended.
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`The inter partes reviews also present a greater likelihood that the patent claims will be
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`invalidated than did the earlier reexaminations. The PTAB has found a “reasonable likelihood”
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`that all claims asserted in this litigation will be found unpatentable based on, for example,
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`combinations of the Zaurus and Pad++ prior art references. See, e.g., Ex. A at 27 (“[W]e agree
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`that Petitioner has demonstrated a reasonable likelihood of prevailing in its challenge to claims 1,
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`33, 36, 43, 118, 149, 183, 252, and 283 based on the combination of Zaurus [sic] and Pad++.”).
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`The “reasonable likelihood” standard is a higher bar to clear than the standard applied to inter
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`partes reexaminations. See, e.g., Universal Elecs., Inc. v. Universal Remote Control, Inc.,
`
`SoftView Exhibit 2078-2
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`

`

`Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 3 of 15 PageID #: 19814
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`SACV 12-0329 (AG), 2013 WL 1876459, at *4 (C.D. Cal. May 2, 2013). Indeed, in Universal
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`Elecs., the court found that this difference between inter partes review and reexamination
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`proceedings weighed in favor of a stay when—unlike in this case—the petition for inter partes
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`review had not even yet been granted.1
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`SoftView attempts to diminish the importance of the PTAB’s finding under the “more
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`restrictive standard” applied to inter partes review proceedings by invoking statistics purporting
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`to show that the percentage of inter partes review petitions granted is the same as the percentage
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`of requests for inter partes reexaminations granted. Pl.’s Opp. (D.I. 995) at 4. These statistics
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`do not show that the same standard is being applied to the two sets of proceedings, however. In
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`particular, the statistics do not take into account other differences in the circumstances
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`surrounding the two sets of proceedings, such as the fact that parties with less meritorious
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`invalidity arguments are less likely to subject themselves to the more rigorous (and expensive)
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`process involved in an inter partes review, when perhaps they would have previously decided to
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`initiate the reexamination process. Nor is there any merit to SoftView’s reliance on Everlight
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`Elecs. Co. v. Nichia Corp., 4:12-cv-11758 (GAD) (MKM) (E.D. Mich. Apr. 30, 2013). See D.I.
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`995 Ex. 2. The statistics in Everlight—for which the court cited no source—purportedly referred
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`to “both the new and old reexamination procedures.” Slip op. at 16 (emphasis added). Thus,
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`these statistics not only fail to reflect the rate at which claims will be rejected in inter partes
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`review—as no inter partes review has yet reached a final decision—but they may even include
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`1 SoftView argues that “reasonable likelihood” does not mean the same thing as “more likely
`than not.” See Pl.’s Opp. at 3-4. The Moving Defendants need not show, however, that it is
`“more likely than not” that the claims will be invalidated in order to demonstrate that there are
`significant efficiency benefits to be gained from a stay.
`
`SoftView Exhibit 2078-3
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`

`

`Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 4 of 15 PageID #: 19815
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`ex parte reexaminations, which are wholly different, non-adversarial proceedings.2
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`Nonetheless, if the Court is to use reexaminations as a guide, the Universal Elecs. case is
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`more apt, as it does cite a source for its statistics and expressly does not include ex parte
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`reexaminations. See 2013 WL 1876459, at *7. In particular, Universal Elecs. states that 89% of
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`inter partes reexaminations have resulted in claim cancellation or amendment. Id. Given that
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`patent owners amend claims in reexamination generally to avoid rejection, it stands to reason
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`that, had amendment not been available in those 89% of cases, essentially all of them would have
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`led to claim cancellation. See id. Here, given that SoftView has pledged not to amend its
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`claims,3 these statistics suggest that SoftView’s claims have at least an 89% chance of being
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`cancelled. See id. In sum, a stay is appropriate now because all asserted claims have been found
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`likely unpatentable under a new, more difficult to satisfy standard than that for inter partes
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`reexamination.
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`Finally, a stay pending a ruling in the inter partes review would simplify the issues
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`before the Court regardless of the outcome. Specifically, should the Court grant the requested
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`stay (D.I. 981), the Moving Defendants would agree to be bound to the PTAB’s determinations
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`as to the specific prior art combinations actually considered by the PTAB during the review,4
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`2 Everlight also purports to rely on situations where claims are amended in reexamination. Slip
`op. at 16. Here, however, SoftView has pledged not to amend its claims in inter partes review.
`Pl.’s Opp. at 5.
`3 SoftView has committed not to amend its asserted patent claims, regardless of the outcome of
`this motion. As SoftView acknowledges, it agreed not to amend its claims “during the course of
`the Apple Inc. reexamination proceedings.” Pl.’s Opp. at 5. Those reexamination proceedings,
`which were stayed pending the outcome of the Kyocera inter partes review proceedings, have
`not yet reached conclusion.
`4 Not merely identified, or identified as cumulative.
`
`SoftView Exhibit 2078-4
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`

`

`Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 5 of 15 PageID #: 19816
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`after institution of the inter partes review proceedings.5 Thus, regardless of the outcome, the
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`inter partes review will result in a significant narrowing of the issues for, e.g., expert discovery
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`and trial. SoftView argues that even if certain invalidity arguments are thus resolved before the
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`PTAB, other defenses would still be available to the Moving Defendants. However, even if the
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`outcome of the inter partes review cannot completely resolve the case in SoftView’s favor, any
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`remaining issues will be significantly diminished. The inter partes reviews will at a minimum
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`greatly simplify the case that is now before the Court.
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`B.
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`The Stage of the Litigation Favors a Stay.
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`The PTAB is required by statute to rule on Kyocera’s petitions no later than March 29,
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`2014. See 35 U.S.C. § 316(a)(11). There is no reason to believe it will not do so. While
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`Motorola has filed its own petitions and motions for joinder, Motorola has not raised any new
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`issues before the PTAB that would result in a delay. See Ex. B (Motorola’s Mot. for Joinder as
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`to the ’353 Patent) at 4; Ex. C (Motorola’s Mot. for Joinder as to the ’926 Patent) at 4. Nor is
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`there any basis on which to assume that the statutory deadline will be extended. As an initial
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`matter, the PTAB appears to be taking seriously the Congressional mandate to complete inter
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`partes review proceedings as quickly as possible and within the presumptive twelve-month
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`timeframe set by Congress, which intended inter partes review to be a faster and more cost-
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`effective forum than district courts to resolve disputes regarding patent validity. See Ex. D,
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`PTAB’s Order Authorizing Third Party Apple, Inc. to File Mot. for Joinder, Apr. 24, 2013, at 4
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`(upon Apple Inc.’s request for leave to submit motions to join Kyocera’s inter partes review
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`proceedings here (which Apple ultimately decided not to submit), ordering that, “in view of the
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`5 Motorola, of course, having filed its own IPR petition, will be bound by the estoppel provisions
`of 35 U.S.C. §315(e)(2), once a final written decision is issued.
`
`SoftView Exhibit 2078-5
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`

`

`Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 6 of 15 PageID #: 19817
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`time and cost considerations, . . . Apple’s Motions for Joinder should specifically address how
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`briefing and/or discovery may be simplified to minimize schedule impact.”); Ex. E, 157 Cong.
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`Rec. S1376 (daily ed. Mar. 8, 2011) (statement of Sen. Kyl) (“Currently, inter partes
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`reexaminations usually last for 3 to 5 years. Because of procedural reforms made by the present
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`bill to inter partes proceedings, the Patent Office is confident that it will be able to complete
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`these proceedings within one year.”); Ex. F, id. at S952 (daily ed. Feb. 28, 2011) (statement of
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`Sen. Grassley) (“These new [inter partes review] procedures would also provide faster, less
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`costly alternatives [than existing inter partes proceedings] to civil litigation to challenge
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`patents.”). Further, in this case, the review will likely be completed in less time than would
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`normally be required because SoftView has now committed not to amend its claims in the inter
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`partes reviews. Pl.’s Opp. at 5. SoftView’s commitment eliminates any need for the round of
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`briefing that is normally associated with such amendments—a step that would exist in the typical
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`inter partes review. The anticipated length of the stay that Moving Defendants now seek is far
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`shorter than in previous motions to stay, which, according to this Court, called for a stay that
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`“would likely last several years.” D.I. 439 at 7.
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`As this Court has previously recognized, the stage of litigation is not considered in a
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`vacuum. Id. Rather, it is evaluated in light of the other proceeding prompting the request for a
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`stay. Id. In this case, when considered in light of the necessarily short duration of the inter
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`partes review, the stage of litigation weighs in favor of granting a stay. No trial date has been set
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`for any Defendant, and no claim construction ruling has been issued by the Court. Expert
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`discovery—one of the most significant expenses in patent litigation—has not commenced. And
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`as explained above, the PTAB will rule on Kyocera’s petitions within the next ten months, or
`
`SoftView Exhibit 2078-6
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`

`

`Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 7 of 15 PageID #: 19818
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`less.6
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`This is not a situation in which the Moving Defendants are trying to delay a case on the
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`eve of trial, nor in which they are trying to impose a multi-year delay. Rather, the timing of the
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`grant of Kyocera’s inter partes review petitions coincides with an ideal point in the case—
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`between the close of fact discovery and the beginning of expert reports and expert discovery—to
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`institute a stay.
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`C.
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`SoftView Would not be Unfairly Prejudiced by a Stay.
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`SoftView has identified no prejudice that would result from this ten-month stay that
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`outweighs the cost and efficiency benefits outlined above. Should SoftView’s asserted patent
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`claims survive the inter partes reviews, SoftView will be free to continue to pursue this
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`litigation, after a minimal delay. SoftView is not seeking an injunction in this case, so any delay
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`would at most put off by ten months SoftView’s efforts to secure any money judgment. Courts
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`have routinely held that a postponed potential payday does not constitute prejudice. See, e.g.,
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`Sorensen ex rel. Sorensen Research and Dev. Trust v. Black & Decker Corp., No. 06-cv-152,
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`2007 WL 2696590 (S.D. Cal. Sept. 10, 2007) (concluding that “Plaintiff’s cognizable claims of
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`prejudice if a stay should be entered basically boil down to his inconvenience in delaying final
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`collection of any monetary award of royalties, assuming he ultimately wins” and rejecting that
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`argument because the plaintiff’s claim would be restricted to monetary damages “which, with the
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`addition of prejudgment interest, are fully capable of compensating Plaintiff”); Broad.
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`Innovation, L.L.C. v. Charter Commc’ns, Inc., No. 03-cv-2223, 2006 WL 1897165 (D. Colo.
`
`6 Although SoftView asserts that “it will take several years at minimum” to complete the appeal
`process for the inter partes review proceedings, Pl.’s Opp. at 2, Moving Defendants are seeking
`a stay only through the PTAB’s ruling, not any subsequent appeals. Depending on the outcome
`of the PTAB’s decision, the Court may consider whether it would be appropriate to further stay
`the case at that time.
`
`SoftView Exhibit 2078-7
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`

`

`Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 8 of 15 PageID #: 19819
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`July 11, 2006) (“[The undue prejudice] factor is best summarized by one question: do the
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`Plaintiffs have an adequate remedy at law? Because they do, this factor weighs heavily in favor
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`o[f] staying the case. The Plaintiffs seek only monetary damages and for that reason, have an
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`adequate remedy at law should they prevail on the merits.”).
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`SoftView’s abstract speculation of prejudice from “fading memories” of witnesses who
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`have or will have been deposed by the time of the stay runs counter to one of the primary
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`rationales for the taking of depositions in the first place—namely, that there is often a period of
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`years between discovery and trial, and depositions preserve memories before they fade so that
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`the testimony can be used to impeach or to refresh recollections at trial. Further, SoftView is
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`highly unlikely to rely on the sort of testimony that would be diminished by fading memories.
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`This is a patent case, in which eyewitness testimony and undocumented contemporaneous
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`impressions will be of little to no importance. Fact discovery is essentially complete, and the
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`necessary witness testimony is locked in through depositions. A ten-month stay would not result
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`in any prejudice to SoftView’s ability to present evidence at trial.
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`SoftView also suggests that it will be prejudiced because Kyocera has engaged in
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`“tactical” maneuvering by failing to seek reexamination at an earlier time, rather than waiting for
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`the availability of the newly created inter partes review process. Yet, as SoftView admits,
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`Kyocera filed its inter partes review petitions less than three weeks after the first opportunity to
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`do so, and as Kyocera explained in its Reply brief in support of its motion to stay, SoftView is in
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`no position to criticize Kyocera for waiting to take advantage of the more expeditious inter
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`partes review process when it was SoftView itself that argued to this Court that reexaminations
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`take too long to reach a final decision. D.I. 975 at 7.
`
`Finally, mere delay does not amount to prejudice, and the passage of time does not cause
`
`SoftView Exhibit 2078-8
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`

`

`Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 9 of 15 PageID #: 19820
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`any prejudice on its own. Universal Elecs., 2013 WL 1876459, at *5. Indeed, although
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`SoftView relies heavily on the Universal Elecs. case in its brief, that case actually highlights the
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`lack of prejudice here, as the court in Universal Elecs. found that any unfair prejudice the
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`plaintiff there would suffer was based entirely on the fact that the parties were competitors. Id.
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`at *6. In this case, SoftView does not compete with any of the Defendants, and will not suffer
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`any special harm based on a stay.7 On the contrary, the same relief that is available now in this
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`case will be available to SoftView at the end of the stay—should anything be left for trial.
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`CONCLUSION
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`There is a reasonable likelihood that the inter partes reviews will resolve this case in its
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`entirety. Moreover, the current stage of litigation is an appropriate place for a ten-month stay,
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`which would be merely a brief pause in the context of this litigation. There is no unfair prejudice
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`to SoftView that would result from a stay. Consequently, the Moving Defendants respectfully
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`request that their Motion to Stay be granted.
`
`7 Although SoftView now laments the expense and duration of this litigation, they are a product
`of SoftView’s own decisions about how many defendants to sue and when to amend its
`complaint. For example, SoftView did not even seek to amend its complaint to add HTC as a
`defendant until two years after the date SoftView alleges it inquired whether HTC was interested
`in licensing SoftView’s technology.
`
`SoftView Exhibit 2078-9
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`

`

`Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 10 of 15 PageID #: 19821
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`DATED: May 28, 2013
`
`
`
`
`/s/ Adam W. Poff
`Adam W. Poff (No. 3990)
`Monté T. Squire (No. 4764)
`Young Conaway Stargatt & Taylor, LLP
`Rodney Square
`1000 North King Street
`Wilmington, DE 19801
`302-571-6600
`302-571-1253
`apoff@ycst.com
`msquire@ycst.com
`
`OF COUNSEL:
`Christine Saunders Haskett
`Michael K. Plimack
`Covington & Burling LLP
`One Front Street
`San Francisco, CA 94111-5356
`415-591-6000 (phone)
`415-591-6091 (fax)
`chaskett@cov.com
`mplimack@cov.com
`
`Attorneys for Defendants Samsung
`Electronics Co., Ltd., Samsung Electronics
`America, and Samsung
`Telecommunications America, LLC
`
`
`
`
`/s/ Richard L. Horwitz
`Richard L. Horwitz (#2246)
`David E. Moore (#3983)
`POTTER ANDERSON & CORROON
`LLP
`Hercules Plaza 6th Floor
`1313 N. Market Street
`Wilmington, DE 19899
`Tel: (302) 984-6000
`rhorwitz@potteranderson.com
`dmoore@potteranderson.com
`
`SoftView Exhibit 2078-10
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`

`

`Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 11 of 15 PageID #: 19822
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`OF COUNSEL:
`Josh A. Krevitt
`H. Mark Lyon
`Stuart M. Rosenberg
`GIBSON DUNN & CRUTCHER LLP
`200 Park Avenue
`New York, NY 10166-0193
`Tel: (212) 351-2490
`
`Attorneys for Defendants Apple Inc.
`
`
`
`
`
`
`/s/ John W. Shaw
`John W. Shaw (No. 3362)
`Karen E. Keller (No. 4489)
`SHAW KELLER LLP
`300 Delaware Avenue
`Suite 1120
`Wilmington, DE 19801
`(302) 559-9623
`jshaw@shawkeller.com
`
`Attorneys for Defendants HTC Corp. and
`HTC America, Inc.
`
`OF COUNSEL:
`
`KEKER & VAN NEST LLP
`Leo L. Lam
`Ashok Ramani
`Justina K. Sessions
`633 Battery Street
`San Francisco, CA 94111-1809
`(415) 391-5400
`
`
`
`
`/s/ Gregory E. Stuhlman
`Gregory E. Stuhlman (#4765)
`Eve H. Ormerod (#5369)
`GREENBERG TRAURIG, LLP
`The Nemours Building
`1007 North Orange Street, Suite 1200
`Wilmington, DE 19801
`(302) 661-7000
`stuhlmang@gtlaw.com
`ormerode@gtlaw.com
`
`SoftView Exhibit 2078-11
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`

`

`Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 12 of 15 PageID #: 19823
`
`Attorneys for Defendants LG Electronics,
`Inc., LG Electronics USA, Inc. and LG
`Electronics Mobilecomm U.S.A., Inc.
`
`OF COUNSEL:
`
`Herbert H. Finn
`Eric J. Maiers
`Barry R. Horwitz
`GREENBERG TRAURIG, LLP
`77 W. Wacker Dr., Suite 3100
`Chicago, IL 60601
`(312) 456-8400
`finnh@gtlaw.com
`maierse@gtlaw.com
`horwitzb@gtlaw.com
`
`
`
`
`/s/ Jack B. Blumenfeld
`Jack B. Blumenfeld (#1014)
`MORRIS, NICHOLS, ARSHT & TUNNELL
`LLP
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899
`(302) 658-9200
`jblumenfeld@mnat.com
`
`Attorneys for Defendant Motorola
`Mobility LLC
`
`OF COUNSEL:
`
`William H. Boice
`Candice C. Decaire
`Alyson L. Wooten
`KILPATRICK TOWNSEND & STOCKTON LLP
`1100 Peachtree Street, NE
`Suite 2800
`Atlanta, Georgia 30309
`404-815-6500
`bboice@kilpatricktownsend.com
`cdecaire@kilpatricktownsend.com
`awooten@kilpatricktownsend.com
`
`SoftView Exhibit 2078-12
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`

`

`Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 13 of 15 PageID #: 19824
`
`John C. Alemanni
`KILPATRICK TOWNSEND & STOCKTON LLP
`1001 West Fourth Street
`Winston-Salem, North Carolina 27101
`336-607-7300
`jalemanni@kilpatricktownsend.com
`
`
`
`
`/s/ Jack B. Blumenfeld
`Jack B. Blumenfeld (#1014)
`Rodger D. Smith II (#3778)
`MORRIS, NICHOLS, ARSHT &TUNNELL
`LLP
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899
`(302) 658-9200
`jblumenfeld@mnat.com
`rsmith@mnat.com
`
`Attorneys for AT&T Mobility LLC
`
`OF COUNSEL:
`
`Daniel S. Young
`Laura K. Mullendore
`KILPATRICK TOWNSEND & STOCKTON LLP
`1400 Wewatta Street, Suite 600
`Denver, CO 80202
`(303) 571-4000
`
`
`
`SoftView Exhibit 2078-13
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`

`

`Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 14 of 15 PageID #: 19825
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`CERTIFICATE OF SERVICE
`
`I, Adam W. Poff, Esquire, hereby certify that on May 28, 2013, I caused to be
`
`electronically filed a copy of the foregoing document with the Clerk of the Court using CM/ECF,
`
`which will send notification that such filing is available for viewing and downloading to the
`
`following counsel of record:
`
`Steven L. Caponi, Esquire
`Blank Rome LLP
`1201 N. Market Street, Suite 800
`Wilmington, DE 19801
`caponi@blankrome.com
`
`Attorneys for Plaintiff
`
`I further certify that on May 28, 2013, I caused a copy of the foregoing
`
`
`document to be served by e-mail on the above-listed counsel and on the following:
`
`Morgan Chu, Esquire
`Samuel K. Lu, Esquire
`Amir Naini, Esquire
`Erin E. McCracken, Esquire
`Andrew Ferguson, Esquire
`Elizabeth Iglesias, Esquire
`Alan J. Heinrich, Esquire
`Dominik Slusarczyk, Esquire
`Zachary Davidson, Esquire
`Aarti Wilson, Esquire
`Gunnar B. Gundersen, Esquire
`James Milkey, Esquire
`Justin Klaeb, Esquire
`Lina Somait, Esquire
`Amy Proctor, Esquire
`Colin Roth, Esquire
`Thomas Jackman
`Michael Tamkin
`Irell & Manella LLP
`1800 Avenue of the Stars
`Suite 900
`Los Angeles, CA 90067
`
`
`SoftView Exhibit 2078-14
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`

`

`Case 1:10-cv-00389-LPS Document 1010 Filed 05/28/13 Page 15 of 15 PageID #: 19826
`
`Laura Evans, Esquire
`Patrick M. McGill, Esquire
`Irell & Manella LLP
`840 Newport Center Drive, Suite 400
`Newport Beach, CA 92660
`
`
`Softview-apple@irell.com
`
`Attorneys for Plaintiff
`
`YOUNG CONAWAY STARGATT
` & TAYLOR, LLP
`
`
`
`
`
` /s/ Adam W. Poff
`Adam W. Poff (No. 3990)
`Monté T. Squire (No. 4764)
`Rodney Square
`1000 North King Street
`Wilmington, DE 19801
`apoff@ycst.com
`msquire@ycst.com
`
`Attorneys for Defendants Samsung Electronics Co.,
`Ltd., Samsung Electronics America, Inc. and
`Samsung Telecommunications America, LLC
`
`
`
`
`
`
`
`
`SoftView Exhibit 2078-15
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
`
`