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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`BROADCOM CORPORATION
`Petitioner
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`v.
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`WI-FI ONE, LLC
`Patent Owner
`____________________
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`Case IPR2013-00636
`Patent 6,424,625
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`PATENT OWNER’S MOTION FOR OBSERVATIONS ON CROSS
`EXAMINATION OF PETITIONER’S REPLY DECLARANT HARRY
`BIMS
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`Case IPR2013-00636
`Patent 6,424,625
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`Pursuant to the Board’s November 11, 2014 e-mail Order, Patent Owner
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`submits the following observations on the October 17, 2014 cross-examination of
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`petitioner’s reply declarant Harry Bims (Exhibit 2029):
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`Observation #1. In Exhibit No. 2029, from page 79, line 10 to page 80, line
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`15 and from page 85, line 7 to page 87, line 4, Dr. Bims testified that he did not
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`review the AX.25 specification that he used as a basis for his opinion about the
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`control field 80 in Garrabrant. This testimony is relevant to the arguments on page
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`9 of Petitioner’s Reply to Patent Owner’s Response (Paper No. 45) and the
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`testimony on ¶ 4 of Reply Declaration of Harry Bims, Ph.D. (Exhibit No. 1022),
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`where Broadcom and Dr. Bims allege that Garrabrant (Exhibit No. 1002) discloses
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`a control message (RNR) that sends a “lost” message to command a receiver to
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`receive the next packet and move the receive window.
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`Observation #2. In Exhibit No. 2029, from page 65, line 18 to page 68, line
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`8, and in Exhibit No. 1022 ¶ 4, Dr. Bims testified that Garrabrant (Exhibit No.
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`1002) discloses a “lost” message command. This testimony is inconsistent with Dr.
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`Bim’s testimony at page 25, line 21 to page 26, line 2 of Exhibit 2028 in which Dr.
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`Bim’s testified that Garrabrant does not disclose a “lost” message command.
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`PATENT OWNER’S OBSERVATIONS ON
`CROSS EXAMINATION
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`2
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`LEE & HAYES PLLC
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` /Peter J. Ayers/
`Peter J. Ayers, Reg. No. 38,374
`John Shumaker, Reg. No. 52,223
`LEE & HAYES, PLLC
`13809 Research Blvd., Suite 405
`Austin, TX 78750
`Phone: (512) 605-8162
`Fax: (509) 944-4693
`peter@leehayes.com
`jshumaker@leehayes.com
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`J. Christopher Lynch, Reg. No. 34,216
`LEE & HAYES, PLLC
`601 W. Riverside Ave., Suite 1400
`Spokane, WA 99201
`Telephone: 509.324.9256
`Fax: 509.323.8979
`chris@leehayes.com
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`Counsel for Patent Owner
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`Case IPR2013-00636
`Patent 6,424,625
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`PATENT OWNER’S OBSERVATIONS ON
`CROSS EXAMINATION
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`3
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`Case IPR2013-00636
`Patent 6,424,625
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that on November 12, 2014 the foregoing
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`PATENT OWNER’S OBSERVATIONS ON CROSS EXAMINATION was
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`served on Lead and Back-up Counsel for Broadcom Corporation by sending the
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`same via electronic mail to the address provided by Broadcom:
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`Dominic E. Massa, Lead Counsel
`Michael A. Diener, Back-up Counsel
`Wilmer Cutler Pickering Hale and Dorr, LLP
`60 State Street
`Boston, MA 02109
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`LEE & HAYES PLLC
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` /Peter J. Ayers/
`Peter J. Ayers
`Reg. No. 38,374
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`PATENT OWNER’S OBSERVATIONS ON
`CROSS EXAMINATION
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`4