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Trials@uspto.gov
`Tel: 571.272.7822
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`LKQ CORPORATION
`Petitioner
`
`v.
`
`Patent of CLEARLAMP, LLC
`Patent Owner
`
`Case No. IPR2013-00020
`Patent 7,297,364
`
`
`
`PATENT OWNER’S RESPONSE TO PETITIONERS’ OBSERVATIONS
`ON TESTIMONY OF MR. A. HARVEY BELL IV
`
`
`
`

`
`Case IPR 2013-00020
`Patent No. 7,297,364
`
`Patent Owner Clearlamp, LLC hereby responds to Petitioner LKQ
`
`Corporation’s “Observations on Testimony of Mr. A. Harvey Bell IV” (Paper No.
`
`61, submitted November 19, 2013).
`
`
`
`Each of LKQ’s 11 enumerated observations are based on testimony that
`
`LKQ elicited from Professor A. Harvey Bell, IV (one of Clearlamp’s technical
`
`experts) during Mr. Bell’s second deposition in this proceeding. See Ex. 1034
`
`(deposition transcript on which LKQ’s observations are based). After Clearlamp
`
`cited to Mr. Bell’s declaration (Ex. 2004) in its reply brief on its motion to amend,
`
`the Board granted LKQ leave to re-depose Mr. Bell, but only on paragraphs 54, 55,
`
`and 79 of his declaration. See Order dated Nov. 6, 2013 (Paper No. 56).
`
`Clearlamp notes that LKQ’s observations are not geared towards Clearlamp’s
`
`motion to amend, or LKQ’s response thereto. Instead, they track the arguments
`
`LKQ makes in support of its motion to exclude portions of Mr. Bell’s declaration
`
`concerning testing reflected in paragraphs 54 and 55 of Mr. Bell’s declaration.
`
`Compare LKQ’s Motion to Exclude (Paper No. 58) at 2–3 and LKQ’s
`
`Observations (Paper No. 61) at 1–9.
`
`
`
`1
`
`
`
`
`
`

`
`Dated: December 3, 2013
`
`Case IPR 2013-00020
`Patent No. 7,297,364
`
`Respectfully submitted by
`
`/Matthew L. Cutler /
`MATTHEW L. CUTLER, Reg. No. 43574
`BRYAN K. WHEELOCK, Reg. No. 31441
`DOUGLAS A. ROBINSON, Reg. No. 59703
`HARNESS, DICKEY & PIERCE, PLC
`7700 Bonhomme Ave., Suite 400
`St. Louis, MO 63105
`Telephone: (314) 726-7500
`Facsimile: (314) 726-7501
`mcutler@hdp.com
`bwheelock@hdp.com
`drobinson@hdp.com
`
`Attorneys for Patent Owner, Clearlamp, LLC
`
`
`
`
`2
`
`

`
`Case IPR 2013-00020
`Patent No. 7,297,364
`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
`
`It is hereby certified that on this 3rd day of December, 2013, a copy of the
`
`foregoing document was served via electronic mail upon the following:
`
`Alan L. Barry
`Jason A. Engel
`Benjamin E. Weed
`Viren S. Soni
`K&L Gates LLP
`70 West Madison Street, Suite 3100
`Chicago, Illinois 60602
`Phone: (312) 372-1121
`Fax: (312) 827-8000
`alan.barry@klgates.com
`jason.engel@klgates.com
`benjamin.weed@klgates.com
`viren.soni@klgates.com
`
`Attorneys for Petitioner, LKQ Corporation
`
`
`/Matthew L. Cutler /
`
`
`
`
`
`
`
`3

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