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`SEL EXHIBIT NO. 2005
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`CHI MEI INNOLUX CORP. v. PATENT OF SEMICONDUCTOR ENERGY
`LABORATORY CO., LTD.
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`IPR2013-00064
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`Case 8:12-cv-00021-JST-JPR Document 107 Filed 12/07/12 Page 1 of 2 Page ID #:3339
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`Kyle B. Fleming (California Bar No. 166386)
`RENNER, OTTO, BOISSELLE & SKLAR, LLP
`1621 Euclid Avenue
`Nineteenth Floor
`Cleveland, Ohio 44115
`Telephone:
`(216) 621-1113
`Facsimile:
`(216) 621-6165
`kfleming@rennerotto.com
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`Attorneys for defendant Westinghouse Digital, LLC
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`UNITED STATES DISTRICT COURT
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`FOR THE CENTRAL DISTRICT OF CALIFORNIA
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`SEMICONDUCTOR ENERGY
`LABORATORY CO., LTD.,
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`Plaintiff,
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`Case No. SACV 12-0021-JST (JPRx)
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`DEFENDANT WESTINGHOUSE
`DIGITAL'S NOTICE OF JOINDER
`AND AGREEMENT TO BE BOUND TO
`OUTCOME OF INTER PARTES
`REVIEW IF STAY OF PROCEEDINGS
`IS GRANTED
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`v.
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`CHIMEI INNOLUX CORPORATION,
`ET AL.,
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`Defendants.
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`NOTICE OF JOINDER AND AGREEMENT TO BE BOUND TO OUTCOME OF INTER
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`PARTES REVIEW IF STAY OF PROCEEDINGS IS GRANTED
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`Between October 19, 2012 and November 30, 2012, Chimei Innolux Corporation ("CMI")
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`filed seven requests for Inter Partes Review ("IPR") of U.S. Patent Nos. 6,404,480 (“’480
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`Patent”), 7,956,978 (“’978 Patent”), 7,697,102 (“’102 Patent”), 7,923,311 (“’311 Patent”),
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`8,068,204 (“’204 Patent”), and 7,876,413 (“’413 Patent”) (collectively the “patents-in-suit”) with
`the U.S. Patent and Trademark Office (“PTO”).1
`On October 22, 2012, Defendants CMI, Chimei Optoelectronics USA, Inc. ("CMO USA"),
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`Acer America Corporation (“Acer”), ViewSonic Corporation ("ViewSonic”), VIZIO, Inc.
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`(“VIZIO”), and (collectively, the “Defendants”) filed a Motion to Stay Litigation Pending
`Outcome of Inter Partes Review (“Motion”).2
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`1See Supplemental Cordrey Declaration in support of Motion to Stay Litigation Pending Inter Partes Review, Dkt No.
`104, and Exhibits 1-19.
`2 See Dkt. No. 100.
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`Case 8:12-cv-00021-JST-JPR Document 107 Filed 12/07/12 Page 2 of 2 Page ID #:3340
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`For the reasons set forth in Defendants’ Motion, Westinghouse Digital, LLC
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`(“Westinghouse”) hereby joins Defendants’ motion to stay.
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`Additionally, in the event that the Court grants the Motion and stays the litigation,
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`Westinghouse agrees to be bound by the PTO’s determinations on the IPRs pursuant to the
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`estoppel provisions of 35 U.S.C. § 315(e)(2).
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`Dated: 07 December 2012
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`Respectfully submitted,
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`/s/ Kyle B Fleming
`Kyle B. Fleming
`Renner, Otto, Boisselle & Sklar, LLP
`1621 Euclid Avenue
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`Nineteenth Floor
`Cleveland, Ohio 44115
`Telephone: (216) 621-1113
`Facsimile: (216) 621-6165
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`Attorneys for Westinghouse Digital, LLC.
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`CERTIFICATE OF SERVICE
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`I hereby certify that on this date a true and correct copy of the foregoing will be
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`electronically filed with the Court. Notice of this filing will be automatically sent by the Court’s
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`CM/ECF system to all counsel of record.
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`Dated: 07 December 2012
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`/s/ Kyle B. Fleming
`Kyle B. Fleming
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`2
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