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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
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`
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________________________
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`
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`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD. and
`TSMC NORTH AMERICA CORP
`Petitioner
`
`v.
`
`ZOND, INC.
`Patent Owner
`
`Case IPR2014-00781
`
`
`
`
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`U.S. PATENT NO. 7,147,759
`
`CLAIMS 20, 21, 34-36, 38, 39, 47 AND 49
`
`__________________________________________________________________
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`
`
`UPDATED MANDATORY NOTICE BY PETITIONER
`UNDER 35 U.S.C. §§ 311-319 AND 37 C.F.R. §§ 42.8, 42.100 ET. SEQ.
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`
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`
`
`
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`Updated Mandatory Notice by Petitioner
`IPR2014-00781
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`
`
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`Petitioner updates the following mandatory disclosures, pursuant to 37
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`C.F.R. §42.8, to add TSMC North America Corp. as a real party-in-interest. No
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`other sections are changed.
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`REAL PARTY-IN-INTEREST
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`Taiwan Semiconductor Manufacturing Company, Ltd. and TSMC North
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`America Corp. are the real parties-in-interest.
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`RELATED MATTERS
`
`This section has not changed.
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`Zond has asserted U.S. Patent No. 7,147,759 (“’759 Patent”) against
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`numerous parties in the District of Massachusetts, 1:13-cv-11570-RGS (Zond v.
`
`Intel); 1:13-cv-11577-DPW (Zond v. AMD, Inc., et al); 1:13-cv-11581-DJC (Zond
`
`v. Toshiba Am. Elec. Comp. Inc.); 1:13-cv-11591-RGS (Zond v. SK Hynix, Inc.);
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`1:13-cv-11625-NMG (Zond v. Renesas Elec. Corp.) ; 1:13-cv-11634-WGY (Zond
`
`v. Fujitsu, et al.)1; and 1:13-cv-11567-DJC (Zond v. Gillette, Co.) (Ex.
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`1235). Petitioner is also filing additional Petitions for Inter Partes review in
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`several patents related2 to the ’759 Patent.
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`
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`1 The Petitioner is a co-defendant with Fujitsu in this lawsuit.
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`2 The related patents, e.g., name the same alleged inventor.
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`
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`1
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`
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`Updated Mandatory Notice by Petitioner
`IPR2014-00781
`
`
`
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`The claims of the present petition are presently the subject of a substantially
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`similar petition for inter partes review styled Intel Corporation v. Zond, Inc.,
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`which was filed March 6, 2014 and assigned Case No. IPR2014-00445. Petitioner
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`will seek joinder with that inter partes review under 35 U.S.C. § 315(c), 37 C.F.R.
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`§§ 42.22 and 42.122(b).
`
`LEAD AND BACKUP COUNSEL
`
`This section has not changed.
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`Lead Counsel: David L. McCombs (Registration No. 32,271)
`
`Backup Counsel: David M. O’Dell (Registration No. 42,044)
`
`Backup Counsel: Richard C. Kim (Registration No. 40,046)
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`SERVICE INFORMATION
`
`This section has not changed.
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`E-mail:
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`david.mccombs.ipr@haynesboone.com
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`
`
`
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`
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`
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`david.odell.ipr@haynesboone.com
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`rckim@duanemorris.com
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`Post and hand delivery: David L. McCombs
`
`
`
`Haynes and Boone, LLP
`
`
`
`2323 Victory Avenue, Suite 700
`
`
`
`Dallas, TX 75219
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`Telephone: 214-651-5533
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`
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`Fax: 214-200-0853
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`Counsel agrees to service by email.
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`
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`2
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`Dated: May 23, 2014
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`Updated Mandatory Notice by Petitioner
`IPR2014-00781
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`
`
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`
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`Respectfully submitted,
`
`By: /David McCombs/
`
`David L. McCombs
`
`Registration No. 32,271
`Counsel for Patent Owner
`
`
`
`
`3
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`
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`Updated Mandatory Notice by Petitioner
`IPR2014-00781
`
`
`
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`
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`
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________________________
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.
`Petitioner
`
`v.
`
`ZOND, INC.
`Patent Owner
`
`Case IPR2014-00781
`
`U.S. PATENT NO. 7,147,759
`
`CLAIMS 20, 21, 34-36, 38, 39, 47 AND 49
`
`_____________________
`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned hereby certifies that service was made on Petitioner’s
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`counsel of record as detailed below.
`
`
`Date of service May 23, 2014
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`Manner of service Express Mail
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`Documents served UPDATED MANDATORY NOTICE BY PETITIONER
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`Persons Served Rauschenbach Patent Law Group, LLC
`P.O. BOX 849
`Franconia, NH 03580
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`
`
`
`
`
`
`/David McCombs/
`David L. McCombs
`Registration No. 32,271
`
`
`
`4
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