`U.S. Patent No. 7,151,027
`
`
`
`
`
`
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` Attorney Docket No.
` 110900-0004-656
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`___________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________________________
`
`MACRONIX INTERNATIONAL CO., LTD., MACRONIX ASIA LIMITED,
`MACRONIX (HONG KONG) CO., LTD. and MACRONIX AMERICA, INC.
`Petitioners
`
`v.
`
`SPANSION LLC
`Patent Owner
`
`___________________________________
`
`Case No. IPR2014-00108
`Patent Number 7,151,027
`
`Before Honorable DEBRA K. STEPHENS, JUSTIN T. ARBES, and
`RICHARD E. RICE, Administrative Patent Judges.
`
`
`
`PATENT OWNER’S UNOPPOSED MOTION TO EXPUNGE AND
`REPLACE PATENT OWNER’S RESPONSE AND SUPPORTING
`DECLARATION WITH CORRECTED COPIES
`
`
`
`
`
`
`
`
`IPR2014-00108
`U.S. Patent No. 7,151,027
`
`
`
`Patent Owner Spansion LLC submits this Unopposed Motion to Expunge and
`
`
`
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` Attorney Docket No.
` 110900-0004-656
`
`Replace Patent Owner’s Response and Related Exhibit with Corrected Copies
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`pursuant to the authorization given on August 15, 2014 by Maria Vignone, Paralegal
`
`Operations Manager. (No fee is believed to be required for consideration of this
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`motion. The Office is authorized to charge any fee deficiency, or credit any
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`overpayment, to Deposit Acct. No. 06-1075.)
`
`Facts Relevant to this Motion
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`1. On July 21, 2014, counsel for Patent Owner filed Patent Owner’s Response
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`(Paper 24) and supporting declaration of Shukri Souri, Ph.D. (Exhibit 2002) in
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`the above-captioned matter through the Patent Review Processing System
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`(PRPS).
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`2. Patent Owner has become aware of several typographical errors in Patent
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`Owner’s Response and the supporting declaration. Patent Owner has
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`identified these errors and proposed corrections to counsel for Petitioner, who
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`has confirmed that Petitioner does not object to Patent Owner’s filing of
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`substitute papers making these corrections.
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`Relief Requested
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`By this motion, Patent Owner respectfully requests that the Board permit
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`Patent Owner to submit corrected copies of the Patent Owner’s Response (Paper 24)
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`
`
`1
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`
`
`IPR2014-00108
`U.S. Patent No. 7,151,027
`
`and supporting declaration (Exhibit 2002) in the above captioned proceeding, and
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` Attorney Docket No.
` 110900-0004-656
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`
`
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`that the Board, for avoidance of confusion, thereafter expunge the originals. Counsel
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`for Petitioners has indicated that Petitioners do not oppose the relief sought in this
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`motion.
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`
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`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`
`August 22, 2014
`
`
`
`By: /J. Steven Baughman/
`Gabrielle E. Higgins (Backup Counsel)
`J. Steven Baughman (Lead Counsel)
`Reg. No. 38,916
`Reg. No. 47,414
`ROPES & GRAY LLP
`ROPES & GRAY LLP
`1900 University Avenue – Suite 600
`One Metro Center, 700 12th St. – Ste. 900
`East Palo Alto, CA 94303
`Washington, DC 20005-3948
`P: 650-617-4000 /F: 650-617-4090
`P: 202-508-4606 / F: 202-383-8371
`steven.baughman@ropesgray.com
`gabrielle.higgins@ropesgray.com
`
`Mailing address for all PTAB correspondence: ROPES & GRAY LLP
`IPRM – Floor 43, Prudential Tower, 800 Boylston Street, Boston, MA 02199-3600
`
`Attorneys for Patent Owner, Spansion LLC
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`
`
`
`
`
`
`2
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`
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`IPR2014-00108
`U.S. Patent No. 7,151,027
`
`
`
`
`
` Attorney Docket No.
` 110900-0004-656
`
`CERTIFICATE OF SERVICE
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`
`
`The undersigned hereby certifies that a copy of the following documents has
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`been served in its entirety by filing aforementioned documents through the Patent
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`Review Processing System, as well as by causing the aforementioned documents to be
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`electronically mailed, pursuant to the Petitioner and Patent Owner’s agreement, to the
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`following attorneys of record for the Petitioner listed below:
`
`1.
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`Patent Owner’s Unopposed Motion to Expunge and Replace Patent
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`Owner’s Response and Supporting Declaration with Corrected Copies.
`
`
`Petitioner’s
`Counsel of Record:
`
`
`
`
`Michael M. Murray (mmurray@winston.com)
`Michael J. Scheer (mscheer@winston.com)
`Bryan N. DeMatteo (bdematteo@winston.com)
`WINSTON & STRAWN LLP
`200 Park Ave.
`New York, NY 10166
`Andrew R. Sommer (ASommer@winston.com)
`Vivian S. Kuo (VKuo@winston.com)
`WINSTON & STRAWN LLP
`1700 K Street, N.W.
`Washington, DC 20006-3817
`
`
`Dated:
`
`August 22, 2014
`
`/Jordan M. Rossen/
`
`
`
`
`
`ROPES & GRAY LLP
`
`3
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