Paper No.
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________
`
`XILINX, INC, Petitioner
`
`v.
`
`Patent of INTELLECTUAL VENTURES MANAGEMENT, LLC,
`Patent Owner
`
`Patent No. 5,779,334
`Issue Date: July 14, 1998
`Title: ENHANCED VIDEO PROJECTION SYSTEM
`
`_____________________
`
`Inter Partes Review No. IPR2013-00112
`
`__________________________________________________________________
`
`PETITIONER XILINX, INC.’S OPPOSITION TO MOTION TO AMEND
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________
`
`XILINX, INC, Petitioner
`
`v.
`
`Patent of INTELLECTUAL VENTURES MANAGEMENT, LLC,
`Patent Owner
`
`Patent No. 5,779,334
`Issue Date: July 14, 1998
`Title: ENHANCED VIDEO PROJECTION SYSTEM
`
`_____________________
`
`Inter Partes Review No. IPR2013-00112
`
`__________________________________________________________________
`
`PETITIONER XILINX, INC.’S OPPOSITION TO MOTION TO AMEND
`
`
`
`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
`
`TABLE OF CONTENTS
`
`I.
`
`Introduction ..................................................................................................... 1
`
`II. Relief Requested.............................................................................................. 1
`
`III. Reasons for the Requested Relief..................................................................... 1
`
`A.
`
`Patent Owner’s motion to amend should be denied for failing to
`comply with 37 C.F.R. §§ 42.121 and 42.20. ..................................... 1
`
`1.
`
`2.
`
`Patent Owner’s motion to amend should be denied for failing to
`comply with 37 C.F.R. § 42.121 and Idle Free. ....................... 2
`
`Patent Owner’s motion to amend should be denied for failing to
`meet its burden under 37 C.F.R. § 42.20.................................. 6
`
`B.
`
`Proposed claims 15 and 16 are unpatentable under 35 U.S.C. § 103(a).
`........................................................................................................... 8
`
`1.
`
`2.
`
`3.
`
`Statutory grounds for challenges.............................................. 8
`
`Claim construction................................................................... 9
`
`Unpatentability of proposed claims 15 and 16.........................10
`
`V. Conclusion......................................................................................................14
`
`–ii–
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`
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`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
`
`I.
`
`Introduction
`Pursuant to 35 U.S.C. §§ 316(a) and 326(a), Petitioner Xilinx, Inc. responds
`
`in opposition to Patent Owner’s Motion to Amend that proposes to cancel claims 3
`
`and 12 and add substitute claims 15 and 16 contingent on either claim 3 or 12
`
`being found unpatentable. As will be shown below, Patent Owner’s proposed
`
`claims fail to comply with 37 C.F.R. §§ 42.121 as clarified by the Board in Idle
`
`Free Systems, Inc. v. Bergstrom, Inc., IPR2012-00027 (P.T.A.B. Jun. 11, 2013).
`
`Patent Owner has also not met its burden in showing how the claims are patentable
`
`over the prior art of record as required by 37 C.F.R. § 42.20. Further, Patent
`
`Owner’s proposed claims are unpatentable under at least 35 U.S.C. § 103(a) over
`
`the prior art and supporting evidence provided herein.
`
`II.
`
`Relief Requested
`Petitioner asks that the Board deny Patent Owner’s motion to amend and not
`
`enter proposed claims 15 and 16 because Patent Owner failed to comply with 37
`
`C.F.R. §§ 42.121 and 42.20. In the alternative, Petitioner asks that the Board
`
`cancel proposed claims 15 and 16 because they are unpatentable under 35 U.S.C. §
`
`103(a) based on the prior art and supporting evidence provided herein.
`
`III. Reasons for the Requested Relief
`A.
`Patent Owner’s motion to amend should be denied for failing to
`comply with 37 C.F.R. §§ 42.121 and 42.20.
`Patent Owner’s motion to amend should be denied for failing to comply with
`
`37 C.F.R. §§ 42.121 as clarified by the Board in Idle Free. Patent Owner failed to
`
`–1–
`
`
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`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
`
`comply with 37 C.F.R. § 42.121 because the proposed amendments include
`
`entirely new claim limitations that are unrelated to the existing limitations. These
`
`new limitations essentially propose a new claim strategy that is not appropriate for
`
`this proceeding. Patent Owner also failed to carry its burden as required by 37
`
`C.F.R. § 42.20 by not including a claim construction for the new limitations that
`
`show how the claims are patentable over the prior art of record.
`
`1.
`
`Patent Owner’s motion to amend should be denied for
`failing to comply with 37 C.F.R. § 42.121 and Idle Free.
`
`According to 37 C.F.R. § 42.121, a motion to amend can be denied where it
`
`“does not respond to a ground of unpatentability involved in the trial” or where it
`
`“seeks to enlarge to scope of the claims of the patent or introduce new subject
`
`matter.” These rules were clarified in Idle Free based on the Board’s goal of
`
`“streamlin[ing] and converg[ing] issues at all phases of the proceeding.” Idle Free,
`
`IPR2012-00027 at *4.
`
`In Idle Free, the Board stated that “a proposed substitute claim is not
`
`responsive to an alleged ground of unpatentability of a challenged claim if it does
`
`not either include or narrow each feature of the challenged claim being replaced.”
`
`Idle Free, IPR2012-00027 at *5. In other words, each feature of a claim being
`
`replaced must be included in a proposed claim or further narrowed. Consequently,
`
`claim amendments according to a different strategy are not appropriate for inter
`
`partes review proceedings. Id. at *6. “If a patent owner desires a complete
`
`–2–
`
`
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`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
`
`remodeling of its claim structure according to a different strategy, it may do so in
`
`another type of proceeding before the Office.” Id. Thus, claim amendments such as
`
`those proposed by the Patent Owner here, that add new limitations to existing
`
`claims without narrowing any of the existing limitations, is not appropriate for this
`
`proceeding and is not responsive under 37 C.F.R. § 42.121.
`
`a)
`
`Proposed claims 15 and 16 rely on new limitations
`instead of further limiting existing limitations.
`
`Proposed claim 15 includes the limitation of claim 3 but relies on entirely
`
`new limitations for patentability instead of narrowing the existing limitations of
`
`claim 3. (Motion to Amend, Paper No. 27 at 1-2.) Proposed claim 16 also relies on
`
`entirely new limitations for patentability but does not even include any of the
`
`limitations of claim 12. (Id. at 2.) These new limitations (i.e., a second controller,
`
`and a control link) do not appear in any of the existing claims of the ’334 patent
`
`and were never presented during original prosecution. By including these new
`
`limitations and not narrowing the existing limitations, Patent Owner has failed to
`
`“either include or narrow each feature of the challenged claim being replaced,” as
`
`required by Idle Free. See Idle Free at *5.
`
`Instead, Patent Owner is attempting to show patentability of the proposed
`
`claims based on entirely new grounds, which is not appropriate for this forum. See
`
`id. at *6. The proposed claims create entirely new issues that do not “streamline
`
`and converge” the existing issues in this proceeding. For example, in responding to
`
`–3–
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`
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`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
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`the motion to amend, Petitioner has had to enter a new challenge that propose new
`
`combinations of existing and new prior art. To determine patentability of the
`
`proposed claims, the Board must review these new references and supporting
`
`evidence, construe new claim limitations, and consider additional future arguments
`
`and evidence. Hence, because the proposed amendment does not “streamline and
`
`converge” the issues, the amendment is better suited for another proceeding such
`
`as ex parte reexamination or reissue. See id. at *6.
`
`Because Patent Owner’s motion to amend proposes claims that do not
`
`narrow the existing limitations of claims 3 and 12, and instead raises entirely new
`
`grounds of patentability, the motion to amend is not “responsive to an alleged
`
`ground of unpatentability” under 37 C.F.R. § 42.121. Id. at *5. Consequently, the
`
`motion to amend should be denied.
`
`b)
`
`Patent Owner’s argument opposing the Idle Free
`decision is without merit.
`
`Patent Owner argues that the Idle Free decision “exceeds the Board’s rule,
`
`which prohibits an amendment that ‘seeks to enlarge the scope of the claims of the
`
`patent.’” (Motion to Amend, Paper No. 27 at 3.) To support this position, Patent
`
`Owner essentially advocates for the same amendment rules that are used in reissue
`
`and reexamination proceedings. (See id. at 3-8.) Patent Owner’s argument,
`
`however, fails to contemplate the specific statues and rules that control inter partes
`
`review proceedings. Because the Board’s decision in Idle Free is consistent with
`
`–4–
`
`
`
`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
`
`the statues and rules that control inter partes review proceedings, Idle Free should
`
`apply here to deny Patent Owner’s motion to amend.
`
`Patent Owner attempts to rely on the fact that 35 U.S.C. § 316(d)—allowing
`
`claim amendments in inter partes review proceedings—uses similar language to
`
`define the scope of a claim amendment as statutory provisions that allow claim
`
`amendments in reissue and reexamination proceedings. (Motion to Amend at 3-4.)
`
`The statutory provisions that control inter partes review proceedings, however,
`
`also allow the Director to proscribe regulations that “set[] forth standards and
`
`procedures for allowing the patent owner to move to amend the patent under
`
`subsection (d).” 35 U.S.C. § 316(a)(9). The Director may also “consider the effect
`
`of any such regulation on the economy, the integrity of the patent system, the
`
`efficient administration of the Office, and the ability of the Office to timely
`
`complete proceedings instituted under this chapter.” Id. § 316(b).
`
`The ruling in Idle Free that limits claim amendments is consistent with at
`
`least the Director’s statutory requirement to “consider the effect of any such
`
`regulation on . . . the ability of the Office to timely complete proceedings instituted
`
`under this chapter.” Id. § 316(b). Inter partes review proceedings must be
`
`completed within a statutorily prescribed time period. See id. § 316(a)(11).
`
`Allowing more liberal claim amendments such as those common in reissue and
`
`reexamination proceedings will only slow inter partes review proceedings and
`
`–5–
`
`
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`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
`
`increase the risk of not completing these proceeding in the time required. Allowing
`
`amendments common in reissue and reexamination proceedings also directly
`
`contradicts the Board’s goal of “streamlin[ing] and converg[ing] issues at all
`
`phases of the proceeding,” Idle Free at *4, since any number of new issues could
`
`be raised by amendment. Since the Board’s decision in Idle Free is consistent with
`
`the statutory rules governing inter partes review proceedings, its ruling should be
`
`applied here to deny Patent Owner’s motion to amend.
`
`2.
`
`Patent Owner’s motion to amend should be denied for
`failing to meet its burden under 37 C.F.R. § 42.20.
`
`Patent Owner’s motion to amend should be denied under 37 C.F.R. § 42.20
`
`for not including a claim construction that shows how the new proposed limitations
`
`are to be interpreted over the prior art. See Idle Free at *7.
`
`According to Idle Free, “a patent owner bears the burden to show
`
`entitlement to the relief requested.” Id. (citing 37 C.F.R. § 42.20(c)). In a motion to
`
`amend, the burden is “on the patent owner to show a patentable distinction of each
`
`proposed substitute claim over the prior art.” Id. To meet its burden Patent Owner
`
`must include a “construction of new claim terms, sufficient to persuade the Board
`
`that the proposed substitute claim is patentable over the prior art of record, and
`
`over prior art not of record but known to the patent owner.” Id.
`
`Patent Owner failed to provide such a construction as required by Idle Free.
`
`As a result, Patent Owner has not met its burden in showing how the proposed
`
`–6–
`
`
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`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
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`claims are patentable over the prior art of record. For example, Patent Owner
`
`argues that “Lee fails to disclose or suggest ‘a second controller’ or ‘a control link’
`
`generally or as a way to reduce the generated heat that affects characteristics of the
`
`LCD panel.” (Motion to Amend at 14.)
`
`First, Patent Owner argues that the terms “second controller” and “control
`
`link” should somehow be interpreted to require the reduction of “the generated
`
`heat that affects characteristics of the LCD panel.” (Motion to Amend at 14.)
`
`However, no language exists in the proposed claims that actually require the
`
`reduction of heat and Patent Owner has not provided any evidence showing how a
`
`person of ordinary skill in the art would understand “second controller” and
`
`“control link” to necessarily include heat reducing properties.
`
`Second, when “second controller” and “control link” are interpreted under
`
`the broadest reasonable interpretation, Lee generally teaches these limitations.
`
`(XLNX-1004 at 3:14-19, 4:10-20; XLNX-1011 at 14-28.) In fact, Patent Owner’s
`
`own expert, Mr. Smith-Gillespie, even agrees that Lee generally teaches a second
`
`controller that provides variable control of multiple light sources. (XLNX-1013 at
`
`157:16-158:5 (“Q . . . So does the Lee reference have a second controller adapted
`
`to control the individual light sources? A Yes. It is item 18, a lamp controlling
`
`circuit, lamp voltage controlling circuit. Q . . . And does controller 18 provide
`
`–7–
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`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
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`individualized variable control of each of the individual light sources? A Yes. It
`
`shows that it does.”).)
`
`Consequently, since Patent Owner argues that the claim terms include
`
`implicit limitations that are not specifically recited in the claims and offers no
`
`proposed construction or evidence explaining how a person of ordinary skill in the
`
`art would understand how these implicit limitations would be required, Patent
`
`Owner has failed to meet its burden under as required by 37 C.F.R. § 42.20 and
`
`Idle Free. Thus, Patent Owner’s motion to amend should be denied.
`
`B.
`
`Proposed claims 15 and 16 are unpatentable under 35 U.S.C. §
`103(a).
`Petitioner challenges the validity of proposed claims 15 and 16 by proposing
`
`new challenge 4:
`
`1.
`
`Statutory grounds for challenges
`
`Challenge #4: Claims 15 and 16 are obvious under 35 U.S.C. § 103(a) over
`
`U.S. Patent No. 5,264,951 to Takanashi et al. (“Takanashi”) in view of U.S.
`
`5,287,131 to Lee (“Lee”), further in view of U.S. Patent No. 5,136,397 to
`
`Miyashita (“Miyashita”). Takanashi was filed on November 23, 1992, and issued
`
`on November 23, 1993, and thus is prior art to the ’334 patent at least under 35
`
`U.S.C. § 102(b). Lee was filed on November 25, 1992, and issued on February 15,
`
`1994, and thus is prior art to the ’334 patent at least under 35 U.S.C. § 102(b).
`
`–8–
`
`
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`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
`
`Miyashita was filed December 23, 1991, and issued on August 4, 1992, and thus is
`
`prior art to the ’334 patent at least under 35 U.S.C. § 102(b).
`
`2.
`
`Claim construction
`
`Petitioner presents claim analysis in a manner that is consistent with the
`
`broadest reasonable interpretation in light of the specification. See 37 C.F.R. §
`
`42.100(b). Claim terms are given their ordinary and accustomed meaning as would
`
`be understood by one of ordinary skill in the art, unless the inventor, as a
`
`lexicographer, has set forth a special meaning for a term. Multiform Desiccants,
`
`Inc. v. Medzam, Ltd., 133 F.3d 1473, 1477 (Fed. Cir. 1998); York Prods., Inc. v.
`
`Central Tractor Farm & Family Ctr., 99 F.3d 1568, 1572 (Fed. Cir. 1996).
`
`In the ’334 patent, the inventor did not act as a lexicographer and did not
`
`provide a special meaning for any of the claim terms. Accordingly, using the
`
`broadest reasonable interpretation standard, the terms should be given their
`
`ordinary and accustomed meaning as understood by a person of ordinary skill in
`
`the art:
`
` “second controller”: one or more control circuits separate from the video
`
`controller. (Id. at ¶ 25.)
`
` “control link”: an electronic connection between the video controller and
`
`another controller. (Id. at ¶ 27.)
`
`–9–
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`
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`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
`
`3.
`
`Unpatentability of proposed claims 15 and 16
`
`The charts below show where each element of proposed claims 15 and 16 is
`
`found in the prior art relied upon.
`
`a)
`
`Challenge #4: Obviousness by Takanashi, Lee, and
`Miyashita
`
`Proposed claims 15 and 16 are obvious under 35 U.S.C. § 103(a) over
`
`Takanashi (XLNX-1002), in view of Lee (XLNX-1003), further in view of
`
`Miyashita (XLNX-1010). Takanashi teaches a video projector system that uses
`
`parallel light sources and a spatial light modulator to project images on a screen.
`
`(XLNX-1011 at ¶ 29.) Lee teaches a video projector system that uses three
`
`individual light sources and includes a controller that provides variable control of
`
`each light source. (Id. at ¶ 30.) Miyashita teaches a video projector system that
`
`includes a lamp controller that controls a light source and is connected to a video
`
`controller. (Id. at ¶ 31.)
`
`Reasons to Combine: A person of ordinary skill in the art would have found
`
`it obvious to combine a video projector system such as that of Takanashi with lamp
`
`controllers as taught by Miyashita and Lee and a control link as taught by
`
`Miyashita. Such a combination would have been nothing more than the use of
`
`known techniques taught by Lee and Miyashita to improve Takanashi’s similar
`
`video projector system in the same way. (Id. at ¶ 28-33.)
`
`–10–
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`
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`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
`
`[15.0]: The video projector system of claim 2, wherein the three color filters
`comprise one each of red, green, and blue filters, and wherein the video
`projector system further comprises:
`
`The non-underlined portion of proposed claim 15 appears in claim 2 that
`
`was previously shown to be and still is unpatentable over Takanashi in view of
`
`Lee. (See Petition, Paper No. 2 at 26-27; XLNX-1011 at 14-15.)
`
`[15.1]: a second controller adapted to control the three white-light sources; and
`
`Lee teaches a light controller adapted to control three individual parallel
`
`light sources. (XLNX-1003 at 3:14-19; XLNX-1011 at 15-16.) Miyashita teaches a
`
`light controller adapted to control a light source, (XLNX-1010 at 5:21-41, Fig. 3;
`
`XLNX-1011 at 15-16.) It would have been obvious for a person of ordinary skill in
`
`the art to combine a controller such as in Lee that controls multiple light sources
`
`and a controller as in Miyashita that controls a light source with a video projector
`
`system as taught in Takanashi. (XLNX-1011 at ¶ 29-33.)
`
`[15.2]: a control link adapted to connect the video controller to the second
`controller
`
`Miyashita teaches a control link adapted to connect a video controller to a
`
`lamp controller. (XLNX-1010 at 5:21-41; XLNX-1011 at 16-20.) The video
`
`controller in Miyashita is implemented as a microprocessor system that uses a data
`
`bus to connect the microprocessor system to additional controller circuits. (Id.) The
`
`additional controller circuits include controls for a lamp. (Id.)
`
`–11–
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`
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`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
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`[15.2.1]: to provide individualized variable control of each of the three white-
`light sources.
`
`Lee teaches control lines that connect a lamp controller to three individual
`
`light sources. (XLNX-1003 at 3:14-19; XLNX-1011 at 19-20.) The control lines
`
`are connected to the controller “so as to change the light intensity emitted from a
`
`respective light source.” (XLNX-1003 at 3:14-19.) Thus, the lamp controller and
`
`control lines of Lee provide individualized variable control of each of individual
`
`light sources. (XLNX-1003 at 3:14-19; XLNX-1011 at 19-20.)
`
`[16.0]: The video projector system of claim 11, further comprising:
`
`Proposed claim 16 depends from claim 11 that was previously shown to be
`
`and still is unpatentable over Takanashi in view of Lee. (See Petition, paper no. 2
`
`at 35-36.)
`
`[16.1]: a second controller adapted to control the source; and
`
`Lee teaches a light controller adapted to control multiple light sources.
`
`(XLNX-1003 at 3:14-19; XLNX-1011at 20-21.) Miyashita teaches a light
`
`controller adapted to control a light source, (XLNX-1010 at 5:21-41, Fig. 3;
`
`XLNX-1011 at 20-21.) It would have been obvious for a person of ordinary skill in
`
`the art to combine light controllers such as those in Lee and Miyashita with a video
`
`projector system as taught in Takanashi. (XLNX-1011 at ¶ 29-33.)
`
`[16.2]: a control link adapted to connect the video controller to the second
`controller
`
`–12–
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`
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`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
`
`Miyashita teaches a control link adapted to connect a video controller to a
`
`lamp controller. (XLNX-1010 at 5:21-41; XLNX-1011 at 23-27.) The video
`
`controller in Miyashita is implemented as a microprocessor system that uses a data
`
`bus to connect the microprocessor system to additional controller circuits. (Id.) The
`
`additional controller circuits include controls for a lamp. (Id.)
`
`[16.2.1]: to provide variable control of the source.
`
`Lee teaches control lines that connect a lamp controller to three individual
`
`light sources. (XLNX-1003 at 3:14-19; XLNX-1011 at 24-25.) The control lines
`
`are connected to the controller “so as to change the light intensity emitted from a
`
`respective light source.” (XLNX-1003 at 3:14-19.) Thus, the control lines and
`
`lamp controller provide individualized variable control of each of individual light
`
`sources. (XLNX-1003 at 3:14-19; XLNX-1011 at 24-25.)
`
`–13–
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`
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`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
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`V.
`
`Conclusion
`Patent Owner has not responded to an asserted ground of patentability as
`
`required by 37 C.F.R. 42.121and has not met its burden under 37 C.F.R. § 42.20.
`
`Further, the proposed claims are not patentable over the prior art. For the reasons
`
`set forth above, Petitioner asks that the Board deny Patent Owner’s Motion to
`
`Amend or in the alternative find proposed claims 15 and 16 unpatentable.
`
`Dated: October 21, 2013
`
`R-346701_1.docx
`
`Respectfully submitted,
`
`/David L. McCombs/
`David L. McCombs
`Registration No. 32,271
`
`HAYNES AND BOONE, LLP
`Customer No. 27683
`Telephone: 214/651-5533
`Facsimile: 214/200-0853
`Attorney Docket No.: 42299.43
`
`–14–
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`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
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`PETITIONER’S EXHIBIT LIST
`
`October 21, 2013
`
`XLNX-1001
`
`U.S. 5,779,334 to Kikinis
`
`XLNX-1002
`
`U.S. 5,264,951 to Takanashi
`
`XLNX-1003
`
`U.S. 5,287,131 to Lee
`
`XLNX-1004
`
`U.S. 5,777,796 to Burstyn
`
`XLNX-1005
`
`Declaration of A. Bruce Buckman, Ph.D. Under 37 C.F.R. §
`1.68
`
`XLNX-1006
`
`Curriculum vitae of A. Bruce Buckman, Ph.D.
`
`XLNX-1007
`
`File History of U.S. 5,779,334 to Kikinis
`
`XLNX-1008
`
`Supplemental Declaration of A. Bruce Buckman, Ph.D.
`
`XLNX-1009
`
`Excerpt from A. Bruce Buckman, Guided-Wave Photonics
`(1992)
`
`XLNX-1010
`
`U.S. Patent No. 5,136,397 to Miyashita
`
`XLNX-1011
`
`XLNX-1012
`
`XLNX-1013
`
`Declaration of A. Bruce Buckman, Ph.D. under 37 C.F.R. §
`1.68 directed to the proposed substitute claims
`
`Declaration of A. Bruce Buckman, Ph.D. under 37 C.F.R. §
`1.68 directed to reply
`
`Deposition Transcript Of Robert Smith-Gillespie Vol. 1
`(August 29, 2013)
`
`XLNX-1014
`
`Deposition Transcript Of Robert Smith-Gillespie Vol. 2
`
`XLNX-1015
`
`Excerpts from Spatial Light Modulator Technology (Uzi
`Efron ed., Marcel Dekker 1995)
`
`
`
`Opposition to Motion to Amend for Inter Partes Review of U.S. 5,779,334
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`XILINX, INC, Petitioner
`v.
`Patent of INTELLECTUAL VENTURES MANAGEMENT, LLC,
`Patent Owner
`
`Patent No. 5,779,334
`Issue Date: July 14, 1998
`Title: ENHANCED VIDEO PROJECTION SYSTEM
`Inter Partes Review No. IPR2013-00112
`_____________________
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. § 42.205, that
`service was made on the Patent Owner as detailed below.
`
`Date of service October 21, 2013
`
`Manner of service FEDERAL EXPRESS
`
`Documents served Petitioner’s Opposition to the Motion to Amendment,
`including
`Petitioner’s Exhibit List (10/21/2013); and
`Exhibits XLNX -1010 through XLNX -1015
`
`Persons served GEORGE E. QUILLIN
`FOLEY & LARDNER LLP
`3000 K STREET, N.W., SUITE 600
`WASHINGTON DC 20007-5109
`gquillin@foley.com
`
`/David L. McCombs/
`David L. McCombs
`Registration No. 32,271
`
`
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