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`SEL EXHIBIT NO. 2003
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`CHI MEI INNOLUX CORP. v. PATENT OF SEMICONDUCTOR ENERGY
`LABORATORY CO., LTD.
`
`IPR2013-00064
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`Case 8:12-cv-00021-JST-JPR Document 104 Filed 11/29/12 Page 1 of 4 Page ID #:2143
`
`JEFFER MANGELS BUTLER & MITCHELL LLP
`STANLEY M. GIBSON (Bar No. 162329)
`sgibson@jmbm.com
`GREGORY S. CORDREY (Bar No. 190144)
`gcordrey@jmbm.com
`3 Park Plaza, Suite 1100
`Irvine, California 92614-2592
`Telephone:
`(949) 623-7200
`Facsimile:
`(949) 623-7202
`Attorneys for Defendants
`CHIMEI INNOLUX CORPORATION,
`CHIMEI OPTOELECTRONICS USA, INC.,
`ACER AMERICA CORPORATION,
`VIEWSONIC CORPORATION,
`VIZIO, INC.
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`
`SEMICONDUCTOR ENERGY
`LABORATORY CO., LTD.,
`Plaintiff,
`
`v.
`CHIMEI INNOLUX CORPORATION,
`CHI MEI OPTOELECTRONICS USA,
`INC., ACER AMERICA
`CORPORATION, VIEWSONIC
`CORPORATION, VIZIO, INC., and
`WESTINGHOUSE DIGITAL, LLC,
`Defendants.
`
`CASE NO. SACV12-0021-JST (JPRx)
`SUPPLEMENTAL DECLARATION
`OF GREGORY S. CORDREY IN
`SUPPORT OF DEFENDANTS'
`MOTION FOR STAY PENDING
`OUTCOME OF INTER PARTES
`REVIEW
`Date:
`Time:
`Place:
`
`December 21, 2012
`2:30 p.m.
`Hon. Josephine Staton Tucker
`Courtroom 10A
`411 W. 4th St. # 1-053
`Santa Ana, California
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`SUPPLEMENTAL DECLARATION OF GREGORY S. CORDREY
`IN SUPPORT OF DEFENDANTS' MOTION FOR STAY
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`Case 8:12-cv-00021-JST-JPR Document 104 Filed 11/29/12 Page 2 of 4 Page ID #:2144
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`DECLARATION OF GREGORY S. CORDREY
`I, Gregory S. Cordrey, declare and state:
`1.
`I am an attorney with Jeffer Mangels Butler & Mitchell LLP, counsel for
`Chimei Innolux Corporation, Chi Mei Optoelectronics USA, Inc., Acer America
`Corporation, ViewSonic Corporation, and VIZIO, Inc. (collectively, "Defendants"). I
`submit this supplemental declaration in support of Defendants’ Motion to Stay
`Pending Outcome of Inter Partes Review (“Motion to Stay”). The matters stated
`below are of my personal knowledge. If called as a witness, I could and would testify
`competently thereto:
`2.
`This declaration supplements my earlier declaration to provide details
`regarding the filing of the petitions for inter partes review ("IPR") of the patents-in-
`suit that have occurred subsequent to the filing of CMI's motion on October 22, 2012
`(Dkt. No. 100).
`3.
`As stated in Defendants’ Motion to Stay, Defendants filed with the U.S.
`Patent and Trademark Office (“PTO”) on October 19, 2012, the first of its petitions
`for inter partes review for U.S. Patent No. 6,404,480 (“’480 Patent”). Attached
`hereto as Exhibits 1 and 2 are true and correct copies of Defendants' petition for IPR,
`and supporting expert declaration, respectively. On October 25, 2012 the PTO issued
`a Notice of Filing Date Accorded to Petition and Notice For Setting the Time Period
`for Filing Patent Owner Preliminary Response (“Notice”). The Notice accorded the
`petition a filing date of October 19, 2012 as Case IPR2013-00028 and designated
`Administrative Patent Judge Sally C. Medley to manage the proceeding. Attached
`hereto as Exhibit 3 is a true and correct copy of the Notice issued by the PTO on
`October 25, 2012.
`4.
`On November 7, 2012, Defendants filed with the U.S. Patent and
`Trademark Office (“PTO”) its petition for IPR for U.S. Patent No. 7,956,978 (“’978
`Patent”). Attached hereto as Exhibits 4 and 5 are true and correct copies of
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`SUPPLEMENTAL DECLARATION OF GREGORY S. CORDREY
`IN SUPPORT OF DEFENDANTS' MOTION FOR STAY
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`Case 8:12-cv-00021-JST-JPR Document 104 Filed 11/29/12 Page 3 of 4 Page ID #:2145
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`Defendants' petition for IPR, and supporting expert declaration, respectively. On
`November 9, 2012 the PTO issued a Notice of Filing Date Accorded to Petition and
`Notice For Setting the Time Period for Filing Patent Owner Preliminary Response
`(“Notice”). The Notice accorded the petition a filing date of November 7, 2012 as
`Case IPR2013-00038 and designated Administrative Patent Judge Sally C. Medley to
`manage the proceeding. Attached hereto as Exhibit 6 is a true and correct copy of
`the Notice issued by the PTO on November 9, 2012.
`5.
`On November 19, 2012, Defendants filed with the U.S. Patent and
`Trademark Office (“PTO”) its petition for IPR for U.S. Patent No. 7,697,102 (“’102
`Patent”). Attached hereto as Exhibits 7 and 8 are true and correct copies of
`Defendants' petition for IPR, and supporting expert declaration, respectively. On
`November 23, 2012 the PTO issued a Notice of Filing Date Accorded to Petition and
`Notice For Setting the Time Period for Filing Patent Owner Preliminary Response
`(“Notice”). The Notice accorded the petition a filing date of November 19, 2012 as
`Case IPR2013-00060 and designated Administrative Patent Judge Sally C. Medley to
`manage the proceeding. Attached hereto as Exhibit 9 is a true and correct copy of
`the Notice issued by the PTO on November 23, 2012.
`6.
`On November 26, 2012, Defendants filed with the U.S. Patent and
`Trademark Office (“PTO”) two petitions for IPR for U.S. Patent No. 7,923,311
`(“’311 Patent”). Attached hereto as Exhibits 10 and 11 are true and correct copies of
`Defendants' first petition for IPR for the ‘311 Patent and supporting expert
`declaration, respectively. Attached hereto as Exhibits 12 and 13 are true and correct
`copies of Defendants' second petition for IPR for the ‘311 Patent and supporting
`expert declaration, respectively. On November 29, 2012 the PTO issued a Notice of
`Filing Date Accorded to Petition and Notice For Setting the Time Period for Filing
`Patent Owner Preliminary Response (“Notice”) for both of the ‘311 Patent petitions.
`The Notices accorded both of the petitions a filing date of November 26, 2012 as
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`SUPPLEMENTAL DECLARATION OF GREGORY S. CORDREY
`IN SUPPORT OF DEFENDANTS' MOTION FOR STAY
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`Case 8:12-cv-00021-JST-JPR Document 104 Filed 11/29/12 Page 4 of 4 Page ID #:2146
`
`Cases IPR2013-00064 and IPR2013-00065, and designated Administrative Patent
`Judge Sally C. Medley to manage the proceedings. Attached hereto as Exhibits 14
`and 15 are a true and correct copy of the Notices issued by the PTO on November 29,
`2012.
`
`On November 28, 2012, Defendants filed with the U.S. Patent and
`7.
`Trademark Office (“PTO”) its petition for IPR for U.S. Patent No. 7,876,413 (“’413
`Patent”). Attached hereto as Exhibits 16 and 17 are true and correct copies of
`Defendants' petition for IPR, and supporting expert declaration, respectively. As of
`today (November 29, 2012), the PTO has not issued a Notice of Filing Date Accorded
`to Petition and Notice For Setting the Time Period for Filing Patent Owner
`Preliminary Response (“Notice”). At the time the petition was filed, it was given a
`provisional a filing date of November 28, 2012 as Case IPR2013-00066.
`8.
`On November 30, 2012, Defendants filed with the U.S. Patent and
`Trademark Office (“PTO”) its petition for IPR for U.S. Patent No. 8,068,204 (“’204
`Patent”). Attached hereto as Exhibits 18 and 19 are true and correct copies of
`Defendants' petition for IPR, and supporting expert declaration, respectively. At the
`time the petition was filed, it was given a provisional a filing date of November 30,
`2012 as Case IPR2013-00068.
`I declare under penalty of perjury under the laws of the United States of
`America, that the foregoing is true and correct.
`Executed this 29th day of November, 2012, in Irvine, California.
`
`/s/ Gregory S. Cordrey
`Gregory S. Cordrey
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`SUPPLEMENTAL DECLARATION OF GREGORY S. CORDREY
`IN SUPPORT OF DEFENDANTS' MOTION FOR STAY
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