`
`SEL EXHIBIT NO. 2003
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`CMI CORP. V. PATENT OF YOSHIHARU HIRAKATA and
`SHUNPEI YAMAZAKI
`
`IPR 2013-00068
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`
`
`Case 8:12-cv-00021—JST—JPR Document 104
`
`Filed 11/29/12 Page 1 of4 Page ID #22143
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`_
`
`Facsunlle:
`
`949 623-7202
`
`JEFFER MANGELS BUTLER & MITCHELL LLP
`STANLEY M. GIBSON (Bar No. 162329)
`s ’z'bson
`'mbmcom
`4
`GO Y S. CORDREY (Bar No. 190144)
`gcordre @jmbmcom
`Park 1az_a, Snlte 1100
`4
`Irvme Cahfomla 92614-2592
`Telep one:
`5
`9493 623-7200
`6 Attorne S for Defendants
`7
`CHI
`I INNOLUX CORPORATION,
`CHIMEI OPTOELECTRONICS USA, INC,
`8 ACER AMERICA CORPORATION,
`VIEWSONIC CORPORATION,
`VIZIO, INC.
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`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`
`v.
`
`Defendants.
`
`
`CASE NO. SACV12-0021—JST (JPRX)
`SUPPLEMENTAL DECLARATION
`OF GREGORY S. CORDREY 1N
`SUPPORT OF DEFENDANTS'
`MOTION FOR STAY PENDING
`OUTCOME OF INTER PARTES
`REVIEW
`-
`
`Date:
`Time:
`Place:
`
`December 21, 2012
`2:30 p.m.
`Hon. Josephine Staten Tucker
`Courtroom 10A
`411 W. 4th St. It 1-053
`, Santa Ana, Cahfornia
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`'17 CHIMEI INNOLUX CORPORATION,
`CHI MEI OPTOELECTRONICS USA,
`INC., ACER AMERICA
`CORPORATION, VIEWSONIC
`19 CORPORATION, VIZIO, INC., and
`WESTINGHOUSE DIGITAL, LLC,
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`PRINTED ON
`RECYCLEDWER mm,”
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`. ‘W
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`SUPPLEMENTAL DECLARATION OF GREGORY S. CORDREY
`IN SUPPORT OF DEFENDANTS' MOTION FOR STAY
`
`
`
`
`
`
`
`Case
`
`8:12—cv-00021-JST-JPR Document 104
`
`Filed 11/29/12 Page 2 of 4 Page ID #12144
`
`
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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 ofDefendants’ 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 ofthe 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).
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`3.
`
`As stated in Defendants’ Motion to Stay, Defendants filed with the US.
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`Patent and Trademark Office (“PTO”) on October 19, 2012, the first of its petitions
`
`for inter partes review for US. 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
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`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 ofthe Notice issued by the PTO on
`
`October 25, 2012.
`
`4.
`
`On November 7, 2012, Defendants filed with the US. Patent and
`
`Trademark Office (“PTO”) its petition for IPR for US. Patent No. 7,956,978 (“’978
`
`Patent”). Attached hereto as Exhibits 4 and 5 are true and correct copies of
`
`
`LA 9152320“
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`_ 1 -
`SUPPLEMENTAL DECLARATION OF GREGORY S. CORDREY
`IN SUPPORT OF DEFENDANTS' MOTION FOR STAY
`
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`8:12-cv—00021-JST-JPR Document 104
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`Filed 11/29/12 Page 3 of 4 Page 1D #:2145
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`Defendants' petition for IPR, and supporting expert declaration, respectively. On
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`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 ofNovember 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. _
`
`On November 19, 2012, Defendants filed with the US Patent and
`5.
`Trademark Office (“PTO”) its petition for IPR for US. 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 ofNovember 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 US. Patent and
`
`Trademark Office (“PTO”) two petitions for IPR for US Patent No. 7,923,311
`
`(“’3 11 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 ‘3 11 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 ‘3 11 Patent petitions.
`
`The Notices accorded both of the petitions a filing date ofNovember 26, 2012 as
`
`
`LA 9152320“
`
`- 2 _
`SUPPLEMENTAL DECLARATION OF GREGORY S. CORDREY
`IN SUPPORT OF DEFENDANTS' MOTION FOR STAY
`
`
`
`Case
`
`8:12-cv-00021~JST—JPR Document 104
`
`Filed 11/29/12 Page 4 of 4 Page ID #:2146
`
`Cases IPR2013-OOO64 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 ofthe Notices issued by the PTO on November 29,
`
`2012.
`
`7.
`
`On November 28, 2012, Defendants filed with the US. Patent and
`
`Trademark Office (“PTO”) its petition for IPR for US. 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 ofNovember 28, 2012 as Case IPR2013—00066.
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`8.
`
`On November 30, 2012, Defendants filed with the US. Patent and
`
`Trademark Office (”PTO”) its petition for IPR for US 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.
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`I declare under penalty of perj ury 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/ Gregng. lCordreL
`Gregory S. Cordrey
`
`LA9152320V1
`
`_ 3 _
`SUPPLEMENTAL DECLARATION OF GREGORY S. CORDREY
`IN SUPPORT OF DEFENDANTS' MOTION FOR STAY
`
`
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