`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CHIMEI INNOLUX CORPORATION
`
`Petitioner
`
`V.
`
`PATENT OF SEMICONDUCTOR ENERGY LABORATORY CO., LTD.
`I
`Patent Owner
`
`CASE |PR2013—00038
`
`PATENT 7,956,978
`
`PATENT OWNER’S LISTING OF ANTICIPATED MOTIONS FOR
`
`DISCUSSION IN INITIAL CONFERENCE CALL
`
`
`
`An initial conference call is scheduled in this matter for April 23, 2013 at 2
`
`PM EST. Pursuant to the Oflz‘ce Patent Trial Practice Guide (OPTPG), 77 Fed.
`
`Reg, 48765 (Aug. 14, 2012), Patent Owner submits this initial listing of motions it
`
`may bring during this trial. Patent Owner reserves its right to seek authorization to
`
`bring additional motions, or to decide not to bring motions as indicated, as
`
`circumstances may warrant.
`
`1. Motion to Amend the Claims
`
`On April 4, 2013, Patent Owner filed a Request for Rehearing on the Board’s
`
`Decision to institute inter partes review, which is currently pending. Depending on
`
`Patent Owner’s continuing evaluation of the Board’s Decision, and upon the
`
`Board’s decision on Patent Owner’s Request for Rehearing, Patent Owner may
`
`move to amend or propose substitute claims pursuant to 37 CPR. § 42.121 for one
`
`or more of the claims of US. Patent 7,956,978 for which a trial has been granted.
`
`2. Motion to Take Discovery Relating to the Identification of
`Real Parties—In—Interest Under 35 U.S.C. § 312(a)(2)
`
`Depending on the Board’s decision on Patent Owner’s Request
`
`for
`
`Rehearing, Patent Owner may move to take additional discovery1 regarding the
`
`identification of real parties-in—interest with respect to the current Petition. The
`
`1 This includes, potentially, a reasonable number of requests for production,
`interrogatories, requests for admission, and depositions of persons knowledgeable of
`the relevant facts.
`
`2
`
`
`
`identification of the real parties-in—interest in the Petition is required under 35
`
`U.S.C.
`
`§ 312(a)(2). More specifically,
`
`the additional discovery may seek
`
`information concerning the involvement of Chimei Innolux Corporation, Chi Mei
`
`Optoelectronics USA, Inc., Acer America Corporation, VieWSonic Corporation,
`
`VIZIO, Inc., and Westinghouse Digital, LLC, in the preparation and filing of the
`
`current Petition.
`
`Dated: April 18, 2013
`
`Respectfully submitted,
`
`Eric J. Robinson
`
`Sean C. Flood
`
`ROBINSON INTELLECTUAL PROPERTY
`
`LAW OFFICE, PC.
`
`3975 Fair Ridge Drive,
`Suite 20 North
`
`Fairfax, Virginia 22033
`(571) 434—6789
`
`Attorneys for Patent Owner
`
`
`
`CERTIFICATE OF SERVICE
`
`I certify that the foregoing LISTING OF ANTICIPATED MOTIONS was
`
`served on the Petitioner by Federal Express Standard Overnight at the following
`
`addresses on April 18, 2013.
`
`Scott A. McKeown
`
`Oblon, Spivak, McClelland, Maier & Neustadt, L.L.P.
`1940 Duke Street
`
`Alexandria, VA 22314
`
`Gregory S. Cordrey
`Jeffer Mangels Butler & Mitchell LLP
`3 Park Plaza, Suite 1100
`
`Irvine, CA 92614-2592
`
`Stanley Gibson
`Jeffer Mangels Butler & Mitchell LLP
`3 Park Plaza, Suite 1100
`
`Irvine, CA 92614—2592
`
`1;?»
`
`
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