`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`BROADCOM CORPORATION
`
`Petitioner
`
`v.
`
`TELEFONAKTIEBOLAGET L.M. ERICSSON
`
`Patent Owner
`
`____________________
`
`Case IPR2013-00602
`
`U.S. Patent Nos. 6,466,568
`
`___________________
`
`
`
`PATENT OWNER’S MOTION TO AMEND
`
`U.S. PATENT NO. 6,466,568 UNDER 37 C.F.R. § 42.121
`
`
`
`
`
`
`
`EXHIBIT NO.
`
`EXHIBIT DESCRIPTION
`
`Exhibit 1001
`
`Raith, U.S. Patent No. 6,466,568 (“the ’568 Patent”)
`
`Exhibit 1002
`
`Morley, U.S. Patent No. 5,488,610, entitled “Communication
`
`System” (“Morley”)
`
`Sharma et al., U.S. Pat. No. 5,500,859, entitled “Voice and
`
`Exhibit 1004
`
`Data Transmission System” (“Sharma”)
`
`Menand et al., U.S. Pat. No. 5,548,532, entitled “Apparatus
`
`and Method for Formulating an Interactive TV Signal”
`
`Exhibit 1005
`
`(“Menand”)
`
`Exhibit 1006
`
`Adams et al., U.S. Patent No. 5,541,662, entitled “Content
`
`Programmer Control of Video and Data Display Using
`
`Associated Data” (“Adams”)
`
`Padovani et al., U.S. Pat. No. 5,659,569, entitled “Data Burst
`
`Exhibit 1007
`
`Randomizer” (Padovani)
`
`Mouly and Pautet, “The GSM System for Mobile
`
`Exhibit 1008
`
`Communications,” 1992 (selected pages) (“GSM”)
`
`Zehavi and Viterbi, U.S. Pat. No. 5,581,575, entitled “Method
`
`and Aparatus for Transmission of Variable Rate Digital Data”
`
`Exhibit 1017
`
`(“Zehavi”)
`
`Declaration of Robert Akl, D.Sc. in support of Motion to
`
`Exhibit 2021
`
`Amend
`
`Application No. 08/725,643 (“the ’019 App.”), filed on Oct.
`
`Exhibit 2022
`
`15, 1996
`
`Raychaudhuri & Wilson, entitled “ATM-Based Transport
`
`Architecture for Multiservices Wireless Personal
`
`Exhibit 2023
`
`Communication Networks,” IEEE Journal on Selected Areas
`
`ii
`
`
`
`in Communications, Vol. 12, No. 9, October 1992
`
`(“Raychauduri”)
`
`Wagner et al., U.S. Pat. No. 5,761,292, entitled “Simultaneous
`
`Transfer of Control Information with Voice and Data Over a
`
`Exhibit 2024
`
`Public Switched Telephone Network Line” (“Wagner”)
`
`
`
`
`
`iii
`
`
`
`I. INTRODUCTION
`
`In the event that the challenged claims are found unpatentable, Patent Owner
`
`Telefonaktiebolaget L.M. Ericsson (“Ericsson”) hereby moves pursuant to the
`
`Board’s March 10, 2014 Order, Paper No. 27, and 37 C.F.R. § 42.121 to cancel
`
`claims 1-6 of U.S. Pat. No. 6,466,568 (“the ’568 Patent) and submit proposed
`
`substitute claims 8-13 in their place.
`
`II. LISTING OF PROPOSED SUBSTITUTE CLAIMS
`
`The following claim listing identifies the changes to the ’568 Patent so that
`
`the Board can identify the new limitations and deletions of limitations. See 37
`
`C.F.R. § 42.121(b); Nichia Corp. v. Emcore Corp., IPR2012-00005, Paper 68 at
`
`*50 (PTAB Feb. 11, 2014). Petitioner has used underlining to indicate text
`
`inserted in the corresponding original claim, as suggested by the Board. Toyota
`
`Motor Corp. v. Am. Vehicular Sciences LLC, IPR2013-00419, Paper 32 at *2
`
`(PTAB March 7, 2014).
`
`Proposed Claims
`
`8. (Proposed Substitute for Original Claim 1) A communication station
`
`comprising: a processor for arranging information for transmission including
`
`providing at least one first field in which payload information is disposed and
`
`providing at least one second field, separate from said first field, which includes a
`
`service type identifier which identifies transmission characteristics of a service and
`
`1
`
`
`
`a type of payload information provided in said at least one first field; and a
`
`transmitter for transmitting information received from said processor including
`
`said at least one first field and said at least one second field.
`
`9. (Proposed Substitute for Original Claim 2) The communication station of
`
`claim 18, wherein said processor is also for changing said type of payload
`
`information from a first type to a second type during a connection involving said
`
`communication station and adjusting a value of said service type identifier to
`
`correspond to the second type of information.
`
`10. (Proposed Substitute for Original Claim 3) The communication station
`
`of claim 29, wherein said first type of information is one of video, voice and data
`
`and said second type of information is different one of video, voice and data.
`
`11. (Proposed Substitute for Original Claim 4) The communication station
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`of claim 18, wherein said information is multimedia information.
`
`12. (Proposed Substitute for Original Claim 5) The communication station
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`of claim 18, wherein said communication station is a base station.
`
`13. (Proposed Substitute for Original Claim 6) The communication station
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`of claim 18, wherein said communication station is a mobile station.
`
`III. STATEMENT OF SUBSTITUTION CONTINGENCIES
`
`Under 37 C.F.R. § 42.121(a)(3), this Motion includes one proposed
`
`substitute claim for each challenged claim to be replaced. Under 37 C.F.R. §
`
`2
`
`
`
`42.121(a)(2), the amendments herein do not seek to enlarge the scope of claims 1-6
`
`of the ’568 Patent or introduce new subject matter. Proposed Substitute claims 8-
`
`13 merely add features to the claims for which they substitute and do not remove
`
`any limitation therefrom. See Synopsis, Inc. v. Mentor Graphics Corp., IPR2012-
`
`00042, Paper No. 60 at *43 (PTAB Feb. 19, 2014).
`
`Proposed substitute claims 8-13 are contingent substitute claims to replace
`
`original claims 1-6, respectively. Claim 8 adds an additional limitation to claim 1:
`
`“service type identifier which identifies transmission characteristics of a service
`
`and a type of payload information.” As discussed below, such a service type
`
`identifier is neither anticipated by or obvious in view of the prior art known to the
`
`patent owner. Claims 9-13 correspond to original claims 2-6 and recite the same
`
`subject matter, respectively, with the exception that claims 9-13 depend from claim
`
`8 rather than claim 1. Each of claims 8-13 is introduced only in the event that the
`
`corresponding original claim is determined to be unpatentable. By submitting this
`
`proposed amendment, Patent Owner does not waive its right, and expressly
`
`reserves its right, to appeal the Board’s patentability determination with respect to
`
`the original claims 1-6.
`
`3
`
`
`
`IV. SUPPORT FOR THE PROPOSED AMENDMENT -- WRITTEN DESCRIPTION
`
`A. Claim Construction for New Claim Terms
`
` Proposed
`
`substitute claim 8
`
`introduces
`
`the
`
`term “transmission
`
`characteristics.” Nichia Corp. v. Emcore Corp., IPR2012-00005, Paper 68 at 51
`
`(PTAB Feb. 11, 2014) (“A motion to amend claims must identify how the
`
`proposed substitute claims introduce new claim terms.”). The ordinary and
`
`customary meaning, as would be understood by one of skill in the art in the context
`
`of the entire disclosure of this term is: characteristics of the payload during
`
`transmission. (Ex. 2021, Akl Dec.¶ 17.) This meaning is supported by the ’568
`
`Patent, which uses the term “transmission characteristics” broadly to refer to
`
`several different characteristics of the payload when transmitted such as
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`“bandwidth” (Ex. 1001 at 2:32), transmission “rate” (id. at 2:36-37), “error
`
`protection” (id. at 2:43), “channel coding” (id. at 2:44), and “ability to tolerate
`
`delay” (id. at 2:50-51). (Id.) The ’568 specification refers to all of these
`
`individually and collectively as “transmission characteristics.” (Id. at 2:41-42 (“In
`
`addition to bandwidth considerations, other transmission characteristics may also
`
`be impacted.”); 2:52-55 (“All of these differences in transmission characteristics
`
`should be considered together when determining an optimal specification for the
`
`air interface.”)). Because the specification uses the term broadly, the term should
`
`be given the full scope of its ordinary and customary meaning, i.e., “characteristics
`
`4
`
`
`
`of the transmission of the payload.” In re Translogic Tech., Inc., 504 F.3d 1249,
`
`1257 (Fed. Cir. 2007). (Akl Dec. ¶ 17.)
`
`B. Descriptive Support for Amendment
`
`The proposed substitute claims find support in the original patent disclosure.
`
`The ’568 Patent is a divisional of application No. 08/725,643 (“the ’019 App.”),
`
`filed on Oct. 15, 1996, now Pat. No. 5,987,019. (Ex. 1001 at 1:5-6.) The
`
`specification of the ’568 patent is identical to that of the ’019 patent. The
`
`following chart shows where the descriptive support for each element of each
`
`proposed claim can be found in the ’019 App. (attached hereto as Ex. 2022) and
`
`’568 Patent:
`
`Proposed Claim
`
`Descriptive Support (Ex. 2022 (’019 App.) and
`
`Ex. 1001 (’568 Pat.))
`
`8. A communication station
`
`Figures 1 and 5 disclose a “communication
`
`comprising:
`
`station” in the form of a “base station” and a
`
`“mobile station.” (’019 App. at 6:24-7:4, FIGs. 1,
`
`5; ’568 Pat. at 4:20-32, FIGs., 1, 5).
`
`a processor for arranging
`
`The “base station” in Fig. 1 includes a processor
`
`information for transmission
`
`in the form of “a control and processing unit 130”
`
`including
`
`while “mobile station” includes a “processing unit
`
`180.” (’019 App. at 6:24-7:4, 7:29-8:7, FIG. 1;
`
`5
`
`
`
`’568 Pat. at 4:20-32, 4:64-5:8, FIG. 1) The
`
`processor arranges the information for
`
`transmission. (’019 App. at 7:5-7; ’568 Pat. at
`
`4:33-35 (“The base station 110 handles a plurality
`
`of traffic channels through a traffic channel
`
`transceiver 150, which is controlled by the control
`
`and processing unit 130.”)).
`
`providing at least one first field
`
`The processor maps the data to be transmitted in
`
`in which payload information is
`
`different fields, as shown in FIG 3. The two
`
`disposed and
`
`“DATA fields” shown in FIG. 3 “are used to
`
`transmit the ‘payload’ of the slot….” (’019 App.
`
`at FIGs. 3, 6, 7A-7B, 8A-8C, 9:2-4, ; ’568 Pat. at
`
`FIGs. 3, 6, 7A-7B, 8A-8C, 5:38-41).
`
`providing at least one second
`
`The ’568 specification also describes a “fast-out-
`
`field, separate from said first
`
`of-band channel (FOC)” field that is separate
`
`field,
`
`from the “DATA field.” (’019 App. at FIGs. 3, 6,
`
`7A-7B, 8A-8C, 11:9-12, 12:9-12, 15:21-29; ’568
`
`Pat. at FIGs. 3, 6, 7A-7B, 8A-8C, 6:56-61, 7:29-
`
`33, 9:27-38).
`
`which includes a service type
`
`The ’568 specification teaches that the “FOC may
`
`6
`
`
`
`identifier which identifies
`
`provide information relating to the same
`
`transmission characteristics of a
`
`connection as the payload or data field in that
`
`service and a type of payload
`
`time slot, e.g., a service type identifier which
`
`information provided in said at
`
`informs the mobile or base station of the type of
`
`least one first field; and
`
`information (e.g., voice, video or data) being
`
`conveyed in the payload. This information can be
`
`used by the receiving equipment to aid in
`
`processing the information conveyed in the
`
`payload, e.g., by knowing the channel coding
`
`rate.” (’019 App. at 4:23-28; ’568 Pat. at 3:11-
`
`19). Moreover, “the FOC fields may also serve
`
`the purpose of service type identifier. In this
`
`embodiment, the FOC can provide information
`
`regarding the type of service which the associated
`
`payload is currently supporting, the channel
`
`coding and/or interleaving associated therewith.”
`
`(’019 App. at 15:21-29; ’568 Pat. at 9:27-38).
`
`a transmitter for transmitting
`
`Both the “base station” and “mobile station”
`
`information received from said
`
`include a “transceiver” that is connected to the
`
`processor including said at least
`
`associated processor for transmitting the
`
`7
`
`
`
`one first field and said at least
`
`information received from the processor including
`
`one second field.
`
`the first and second fields. (’019 App. at FIGs.
`
`1,5, 7:5-15, 8:2-7; ’568 Pat. at FIGs. 1, 5, 4:33-
`
`46, 5:2-8).
`
`9. The communication station
`
`The ’568 specification teaches that “the present
`
`of claim 8, wherein said
`
`invention finds application [] in multimedia
`
`processor is also for changing
`
`communication. As described above, it is
`
`said type of payload information
`
`anticipated that future radio communications will
`
`from a first type to a second type
`
`need to support intermingled voice, data and
`
`during a connection involving
`
`video service, wherein the type of information to
`
`said communication station and
`
`be transmitted may vary rapidly, e.g., time slot by
`
`adjusting a value of said service
`
`time slot and wherein the different services may
`
`type identifier to correspond to
`
`require different levels of channel coding.” (’019
`
`the second type of information.
`
`App. at 4:21-5:2, 15:4-11, 15:21-29, 30:19-22;
`
`’568 Pat. at 3:9-22, 9:5-15, 9:27-38, 14:1-6).
`
`10. The communication
`
`(See claim 9 above; ’019 App at 30:23-25; ’568
`
`station of claim 9, wherein said
`
`Pat. at 14:7-10)
`
`first type of information is one
`
`of video, voice and data and said
`
`second type of information is
`
`8
`
`
`
`different one of video, voice and
`
`data.
`
`11. The communication
`
`(See claim 9 above; ’019 App. at 31:1-2; ’568
`
`station of claim 8, wherein said
`
`Pat. at 14:11-12)
`
`information is multimedia
`
`information.
`
`12. The communication
`
`Figures 1 and 5 disclose a “communication
`
`station of claim 8, wherein said
`
`station” in the form of a “base station.” (’019
`
`communication station is a base
`
`App. at FIGs. 1, 5, 6:24-7:4, 31:3-4; ’568 Pat. at
`
`station.
`
`FIG. 1, 5, 4:20-32, 14:13-14).
`
`13. The communication
`
`Figures 1 and 5 disclose a “communication
`
`station of claim 8, wherein said
`
`station” in the form of a “mobile station.” (’019
`
`communication station is a
`
`App. at FIGs. 1, 5, 6:24-7:4, 31:5-6; ’568 Pat. at
`
`mobile station.
`
`FIG. 1, 5, 4:20-32, 14:15-16).
`
` A
`
` person of ordinary skill in the art would conclude that the inventors were
`
`in possession of the invention claimed in substitute claims 8-13 as of Oct. 15,
`
`1996. (Akl Dec. ¶ 19.) As shown above, the original disclosure of the application
`
`relied upon reasonably conveys to a person of ordinary skill in the art that the
`
`inventor had possession of the claimed subject matter as of the filing date. See
`
`9
`
`
`
`Nichia Corp. v. Emcore Corp., IPR2012-00005, Paper 68 at 54 (PTAB Feb. 11,
`
`2014).
`
`V. SUBSTITUTE CLAIMS ARE PATENTABLE OVER THE PRIOR ART
`
`On September 20, 2013, Broadcom Corporation (“Petitioner”) filed a
`
`petition under 35 U.S.C. §§ 311-319 and 37 C.F.R. § 42.100 et seq. requesting
`
`inter partes review of U.S. Patent No. 6,466,568, proposing five grounds of
`
`rejection. On March 10, 2014, the Patent Trial and Appeal Board issued a decision
`
`instituting an inter partes review with respect two of the grounds of rejection
`
`proposed, namely that U.S. Patent 5,488,601 (“Morley”) allegedly anticipates
`
`claims 1-6 and U.S. Patent 5,541,662 (“Adams”) allegedly renders obvious claims
`
`1-6 of the ’568 patent.
`
`Substitute independent claim 8 is patentable over both Adams and Morley
`
`because neither reference teaches or suggests a “service type identifier which
`
`identifies transmission characteristics of a service and identifies a type of payload
`
`information.” Morley discloses a multiplexer that supports one voice channel and
`
`up to three data channels (Morley, 6:31-32) and creates a composite signal for
`
`transmission and reception on a single communications channel (Id. at 1:3-5).
`
`Morley discloses that the “format of the mux frame may need to change according
`
`to the particular characteristics of a call.” (Id. at 7:27-29.) Morley is silent as to
`
`the meaning of “the particular characteristics of a call” contemplates transmission
`
`10
`
`
`
`characteristics, is related to the voice and data that are being exchanged during a
`
`call, or related to something else entirely. (Akl Dec. ¶ 21.) Even assuming that
`
`changing the mux frame format relates to transmission characteristics (which it
`
`does not), Morley teaches away from transmission characteristics. Any change in
`
`format in Morley is related only to header type 0, and header type zero does not
`
`identify any “information conveyed in the payload.” (Morley, 7:1-30; Akl. Dec. ¶
`
`21.) Because the “protocol negotiates which data channels (if any) use error
`
`correction,” (Morley, 8:37-38), rather than the alleged header determining the error
`
`correction, the error correction disclosed in Morley is not associated with any
`
`alleged service type identifier (e.g., the header type). (Morley, 8:18-40; Akl. Dec.
`
`¶ 21.) Adams discloses a single service—satellite television transmission—
`
`conforming to the MPEG video transport standard. (Adams, 4:5-13; Akl. Dec. ¶
`
`21.) Because Adams only discloses MPEG encoding of satellite television
`
`transmission, Adams does not teach or suggest a service type identifier identifying
`
`transmission characteristics. (Akl. Dec. ¶ 21.)
`
`The remaining art identified by petitioner—Ex. 1004 (U.S. Pat. No.
`
`5,500,859) (“Sharma”), Ex. 1005 (U.S. Pat. No. 5,548,532) (“Menand”), Ex. 1007
`
`(U.S. Pat. 5,659,569) (“Padovani”), Ex. 1017 (U.S. Pat. No. 5,581,575)
`
`(“Zehavi”), and Ex. 1018 (“GSM”)—also fail to teach or disclose a service type
`
`identifier which identifies transmission characteristics of a service. (Akl Dec. ¶
`
`11
`
`
`
`22.) Although Menand, which Patent Owner believes to be the closest prior art,
`
`discloses a service identifier for audio packets and video packets (Menand,
`
`Abstract), Menand only discloses a single service—transmission of a satellite
`
`broadcast signal that includes video, audio, and interactive signals (Menand, 1:5-
`
`9). (Akl Dec. ¶ 22.) Menand does not disclose a “service type identifier” because
`
`the transmission of only one service does not teach or suggest a service type
`
`identifier to a person of ordinary skill in the art. (Akl Dec. ¶ 22.) The disclosed
`
`MPEG protocol for compressing the video and audio information in Menand is not
`
`a transmission characteristic identified by a service type identifier because one of
`
`ordinary skill in the art would understand MPEG compression to be an inherent
`
`property of the encoded satellite signal disclosed in Menand. (Akl. Dec. ¶ 22.)
`
`Nor does Menand teach or suggest that MPEG is associated with an identifier that
`
`also identifies payload information. Accordingly, Menand does not teach or
`
`disclose amended claim 8. (Akl. Dec. ¶ 22.)
`
`Rather than teaching transmission characteristics, Sharma teaches a single
`
`connection speed for data transfer of DATA, VOICE, or QUALIFIED packets, and
`
`consequently does not teach or suggest amended claim 8. (Sharma, 19:28-32,
`
`Table 1; Akl Dec. ¶ 23.) Like Sharma, Padovani teaches a single connection for
`
`the transmission of voice data (primary data), non-voice data (second data), and
`
`control data (signalling traffic (Padovani at Figs. 2a-2e, 4:24-30)). Padovani
`
`12
`
`
`
`further teaches the use of pseudorandom codes to encode (or randomize) data
`
`before transmission for privacy and security purposes (Padovani at 14:14-19), and
`
`therefore does not teach or suggest transmission characteristics. (Akl Dec. ¶ 23.)
`
`Zehavi discloses a system for transmitting variable rate data such as speech,
`
`video, facsimile, modem, or other digital data at a constant data rate through the
`
`inclusion of variable replication count so that the data is transmitted at a constant
`
`data rate. (Zehavi, Abstract, 4:30-54, 5:27-30; Akl Dec. ¶ 24.) Zehavi relates to
`
`transmitting at a constant rate data having a variable rate, and thus does not teach
`
`or suggest transmission characteristics of information in the payload as required by
`
`amended claim 9. (Akl. Decl. ¶ 24.) Zehavi addresses the generation of various
`
`bit rates, but it does not teach or suggest formatting a frame or linking transmission
`
`characteristics to a service type identifier. Linking various data rates to an
`
`identifier of transmission characteristics would thwart the purpose of Zehavi.
`
`Zehavi is directed toward a system that modifies the bit rate based on the current
`
`analysis of the data to be transmitted, and the receiver in Zehavi would not need to
`
`receive an identifier of transmission characteristics. Zehavi does not teach or
`
`suggest how a person of ordinary skill in the art would link various data rates to an
`
`identifier of transmission characteristics as claimed by substitute independent
`
`claim 8. (Akl Dec. ¶ 24.) GSM only discloses GSM radio communication in
`
`13
`
`
`
`general, and therefore does not teach or suggest a service type identifier or the
`
`remaining limitations of amended claim 8. (Akl Dec. ¶ 24.)
`
`The substitute claims are patentable over the prior art, including Menand,
`
`which the Patent Owner believes is the closest known prior art. (Akl Dec. ¶ 25.)
`
`The prior art does not teach or suggest a service type as claimed in substitute claim
`
`8. Raychaudhuri (Ex. 2023 (IEEE J. on Selected Areas in Comm., Vol. 12, No. 8,
`
`Oct. 1992)) discloses a service type field that identifies transmission characteristics
`
`(“Service Type” in Table 1; Fig. 7; p. 1407), but does not identify information
`
`conveyed in the payload (Table 1). (Akl Dec. ¶ 25.) Rather, Raychaudhuri
`
`discloses various applications (which may have various data types), each of which
`
`are associated with multiple service types. (Raychaudhuri at Table 1). Wagner
`
`(Ex. 2024 (U.S. Pat. No. 5,761,292)) discloses performing different modulations
`
`on two different channels (Figs. 2, 3, 2:33-40, 5:45-50) using a transmit switch
`
`(9:9-16), but does not disclose any transmission characteristics or service type
`
`identifiers. (Akl Dec. ¶ 25.)
`
`Furthermore, one of ordinary skill in the art would not combine the service
`
`type field in Raychaudhuri with a header or identifier field in Menand, Adams, or
`
`Morley, because the service type field in Raychaudhuri is associated with more
`
`than one type of data, but the header or identifier fields in Menand, Adams, or
`
`Morley are associated with only one type of data. (Menand at Abstract, 1:5-8;
`
`14
`
`
`
`Morley at 7:1-17; Adams at Fig. 5; Akl Decl. ¶ 26.) The service type fields in
`
`Raychaudhuri are associated with multiple types of data to reduce the number of
`
`such identifiers.
`
` (Akl Dec. ¶ 26.)
`
`
`
` Merging a unique identifier in
`
`Menand/Morley/Adams with non-unique identifier of Raychaudhuri would thwart
`
`the purposes of all three prior art references. (Akl Dec. ¶ 26.)
`
`Dependent claims are nonobvious if the independent claim from which they
`
`depend is nonobvious. In re Fine, 5 USPQ2d 1596, 1600 (Fed. Cir. 1988). New
`
`dependent claims 9-13 are dependent upon independent claim 8 which defines an
`
`unobvious apparatus which is patentable over the prior art. Thus, the proposed new
`
`dependent claims are likewise patentable over the prior art.
`
`Patent Owner believes the substitute claims 8-13 are patentable over the
`
`known prior art, including the closest known prior art (Manand). Because the
`
`’558 patent was the first invention to conceive of “a service type identifier which
`
`identifies transmission characteristics of a service and a type of payload
`
`information,” a person of ordinary skill in the art would not expect the prior art to
`
`teach or suggest substitute claims 8-13. (Akl Dec. ¶ 27.)
`
`VI. CONCLUSION
`
`For the reasons described above, Patent Owner moves to amend the
`
`challenged claims in the event the Board concludes that the challenged claims are
`
`unpatentable.
`
`15
`
`
`
`Respectfully submitted,
`
`
`
`
`
` /s/ Peter J. Ayers
`Peter J. Ayers
`Registration No. 38,374
`LEE & HAYES, PLLC
`Customer No. 12-0769
`Phone: (512) 505-8162
`Facsimile: (509) 944-4693
`Attorney Docket No.: E034-0003IPR
`
`
`Dated: June 11, 2014
`
`
`
`
`
`16
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on June 11, 2014, I caused a true and correct
`
`copy of the following materials:
`
` PATENT OWNER’S MOTION TO AMEND U.S. PATENT
`
`6,466,568 UNDER 37 CFR § 42.121
`
` Exhibits 2021-2024
`
` Table of Exhibits
`
`to be served on Lead and Back-Up Counsel for Broadcom Corporation by sending
`
`the same electronically to the service address provided in Broadcom’s Mandatory
`
`Notices:
`
`Dominic E. Massa, Lead Counsel
`Michael A. Diener, Back-up Counsel
`Wilmer Cutler Pickering Hale and Dorr, LLP
`60 State Street
`Boston, MA 02109
`WH-External-Broadcom-IPR2013-602@wilmerhale.com
`dominic.massa@wilmerhale.com
`
`michael.diener@wilmerhale.com
`
`
`LEE & HAYES PLLC
`
` /s/ Peter J. Ayers
`
`
`
`
`
`Peter J. Ayers, Reg. No. 38,374
`
`
`
`17
`
`
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