INNOVATIVE DISPLAY TECHNOLOGIES LLC’s
`EXHIBIT 2001
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`LG DISPLAY CO., LTD.
`Petitioner
`
`v.
`
`INNOVATIVE DISPLAY TECHNOLOGIES LLC
`Patent Owner
`
`Case IPR2014-01362
`U.S. Patent No. 7,384,177
`
`

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`Page 1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________________________
` LG DISPLAY CO., LTD.
` Petitioner
` v.
` INNOVATIVE DISPLAY TECHNOLOGIES LLC
` Patent Owner
`_________________________________________
` Case IPR2014-01357
` U.S. Patent No. 6,755,547
`_________________________________________
`
` Teleconference
` New York, New York
`
` December 2, 2014
` 11:00 a.m.
`
` Transcript of the Proceedings
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`www.veritext.com
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`Page 2
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`A P P E A R A N C E S:
`
`Presiding:
` The Honorable Thomas L. Giannetti
` Administrative Law Judge
`
`On behalf of Petitioner:
` ROBERT G. PLUTA, ESQ.
` AMANDA K. STREFF, ESQ.
` JAMIE B. BEABER, ESQ.
` Mayer Brown LLP
` 71 S. Wacker Drive
` Chicago, Illinois 60606
`
`On behalf of the Patent Owner:
` JUSTIN B. KIMBLE, ESQ.
` T. WILLIAM KENNEDY, ESQ.
` JEFFREY R. BRAGALONE, ESQ.
` Bragalone Conroy PC
` Chase Tower
` 2200 Ross Avenue
` Suite 4500 W
` Dallas, Texas 75201-7924
`
`ALSO PRESENT:
` Judge Bunting
` Judge Powell
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`212-279-9424
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`VERITEXT REPORTING COMPANY
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`Page 3
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` -Proceeding-
` HON. GIANNETTI: This is a call
` in two proceedings before the patent
` trial and appeal board IPR2014-01357
` and 2014-01362 both of which involve
` the same parties that I will give to
` you, LG Display Co. Limited as
` petitioner had Innovative Display
` Technologies LLC as patent owner.
` Let's do a roll call here. Who
` is appearing today for the petitioner?
` MR. PLUTA: Thank you, Your
` Honor. Robert Pluta, Mayer Brown on
` behalf of LG Display and with me is
` Amanda Streff and Jamie Beaber.
` HON. GIANNATI: Okay. That
` second name was what?
` MR. PLUTA: S T R E F F.
` HON. GIANNATI: All right.
` And for the patent owner, who is
` appearing?
` MR. KIMBLE: Your Honor, you
` have Justin Kimble and Jeff Bragalone
` and Bill Kennedy.
` HON. GIANNETTI: All right. So,
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`Page 4
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` -Proceeding-
` Mr. Bragalone, there's a pro hac
` petition pending. Will you be
` participating in the presentation this
` morning?
` MR. BRAGALONE: Your Honor, this
` is Mr. Bragalone. Mr. Kimble will
` take the lead.
` HON. GIANNETTI: Okay. We have
` your petition for pro hac and we'll
` act on that promptly. If it does
` become necessary for you to
` participate, I'm sure that petitioner
` does not have an objection to that.
` Do you have an objection,
` Mr. Pluta?
` MR. PLUTA: No, Your Honor. And
` I guess I'd ask for the same courtesy
` to be extended to Mr. Beaber as well.
` HON. GIANNETTI: Okay, that is
` fine. This call was requested by the
` patent owner I believe and so I will
` give you the floor. Mr. Kimble,
` please tell me why you asked for this
` conference.
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`Page 5
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` -Proceeding-
` MR. KIMBLE: Yes, Your Honor.
` So what we are asking for is
` permission to file a motion for
` additional discovery in the two
` matters that you identified. We think
` that this additional discovery will be
` in the interest of justice and the
` reason is because we think that this
` discovery, this limited discovery will
` show that the petitioner LG Display
` was in privity with Dell and HP and,
` therefore, was barred from filing
` these two IPRs under 35 U.S.C. 315(b).
` Yes, Your Honor?
` HON. GIANNETTI: You can
` continue, go ahead.
` MR. KIMBLE: So Dell and HP are
` defendants in two related litigation
` matters and those cases were filed or
` were served on Dell and HP
` respectfully on July 3, 2013 and,
` therefore, their deadline to file IPR
` petitions was a year later, of course,
` July 3, 2014.
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`Page 6
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` -Proceeding-
` The technology at issue in the
` Dell and HP cases relates to liquid
` crystal display modules, and LG
` Display supplies those modules to Dell
` and HP. LG Display filed their -- let
` me take another step back. There are
` seven patents at issue in the
` underlying litigation. LG Display
` filed IPR petitions on five of those
` patterns two days prior to the bar
` date July 1, 2014. And then two
` months later, they filed the two IPRs
` that we are discussing with you today.
` LG Display, Dell and HP are all
` represented by the same counsel
` including the three attorneys that are
` on the phone with us today. And so we
` believe that some limited additional
` discovery will show that LG Display
` was in control of the underlying
` litigation, that it supplies the
` infringing technology to Dell and HP,
` that it perhaps indemnifies Dell and
` HP and, therefore, was barred from
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`Page 7
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` -Proceeding-
` filing the two IPRs that we are
` discussing with you today.
` HON. GIANNETTI: Okay. Let me
` just ask you, Mr. Kimble, you are not
` contending that Dell or HP is
` controlling the IPRs; is that correct?
` MR. KIMBLE: Correct.
` HON. GIANNETTI: And so those
` are the barred parties, right, Dell
` and HP you contend are barred, but
` they are not controlling the IPRs, are
` they?
` MR. KIMBLE: No. They are
` barring and also parties are in
` privity with them. And so we believe
` that LG Display is in privity with
` them and is controlling the litigation
` and, therefore, it was barred.
` HON. GIANNETTI: So you contend
` that by suing customers of LG Display
` your client creates a bar for their
` supplier; is that your theory?
` MR. KIMBLE: Not only that but
` on these facts we think that is the
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`Page 8
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` -Proceeding-
` case and the reason is because of the
` level of control that their supplier
` LG Display has over the litigation
` which is evidenced by their shared
` counsel. And we think that some
` additional limited discovery will show
` that perhaps there are indemnification
` agreements and will show the level of
` control that LG Display has over those
` litigation matters.
` HON. GIANNETTI: But they will
` not show any control by Dell or HP
` over the IPRs, correct?
` MR. KIMBLE: I suspect not. I
` suspect it is the opposite. I mean I
` don't necessarily know that but our
` suspicion is that it is LG Display in
` control.
` HON. GIANNETTI: In any event,
` that is not your theory; is that
` correct?
` MR. KIMBLE: That's correct.
` HON. GIANNETTI: All right.
` Let's hear from the petitioner, Mr.
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`Page 9
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` -Proceeding-
` Pluta, or, Ms. Streff? Or, Mr.
` Beaber, you are going to be making the
` presentation; is that right?
` MR. PLUTA: This is Robert
` Pluta. I will be making the
` presentation.
` HON. GIANNETTI: Okay, Mr.
` Pluta. Do you agree with the facts at
` least stated by the patent owner on
` the dates and whose has been served
` and that factual presentation?
` MR. PLUTA: No, I don't, Your
` Honor. What I didn't hear from
` Mr. Kimble is what date at which he
` contends, even if true, that LG
` Display became in privity with Dell
` and HP. There's no control over Dell
` and HP for the Dell and HP litigation
` by LG Display either now or prior to
` filing any of the petitions in these
` cases.
` HON. GIANNETTI: Are you
` contending that LG Display is not
` indemnifying Dell or HP?
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`Page 10
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` -Proceeding-
` MR. PLUTA: I am sorry. What,
` Your Honor?
` HON. GIANNETTI: Is there an
` indemnification relationship between
` Dell and HP and LG Display?
` MR. PLUTA: There is an
` indemnification agreement between Dell
` and HP, but there is also presumably
` other indemnification agreements with
` other suppliers. LG Display could not
` have controlled and does not control
` the Dell and HP litigation
` particularly where patent owner in
` that case is accusing products
` directed at liquid crystal module
` suppliers other than LG Display.
` In their preliminary response to
` the 547 patent petition, patent owner
` conveniently cherry picks two accused
` products from Dell and HP that contain
` parts supplied by LG Display but omits
` the fact that there are over 300
` products or so at issue in that case.
` And based on their infringement
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`Page 11
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` -Proceeding-
` contentions which are public, liquid
` crystal modules from LG Display only
` account for about a third of those
` liquid crystal modules in the accused
` products. So the notion of control by
` Dell and HP by LG Display is total
` speculation. And I didn't hear any
` evidence and patent owner did not
` provide any in its preliminary
` response with respect to the 547
` patent that shows there's more than a
` mere possibility that the sought after
` discovery exists. It just doesn't
` make sense that Dell and HP would turn
` over control of the litigation just
` for one supplier particularly where
` there may be multiple suppliers for
` each of those parties.
` Another important fact I think
` omitted by patent owner was that
` patent owner has sued LG Display in
` the District of Delaware in a case
` filed on December 31, 2013 that
` includes eight patents including the
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`Page 12
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` -Proceeding-
` 547 and the 177 patent. LG Display is
` the only supplier that patent owner
` has sued that stands to reason LG
` Display would want to file its own
` IPRs.
` The timing of the IPRs in this
` case has nothing to do with the Dell
` and HP case. Rather they have
` everything to do with the Delaware
` case. LG Display filed all the IPRs
` prior to the scheduling conference in
` that case and indicated to the judge
` in that case that it intends to move
` for a stay once some of these IPRs get
` transaction. So the conspiracy theory
` that LG Display is somehow controlling
` HP and Dell litigation is just not
` true.
` And the fact that counsel here
` represents HP and Dell in the HP and
` Dell litigation is irrelevant. We
` litigated against Mr. Kimble's firm
` before. We have litigated against
` Mr. Kimble's firm regarding the same
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`Page 13
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` -Proceeding-
` technology before. We were ahead on
` the technology and the prior art
` having worked up and filed the IPRs.
` It's reasonable to believe that Dell
` and HP wanted to hire us because of
` these facts, not because of some sort
` of control by LG Display.
` HON. GIANNETTI: Mr. Kimble,
` getting back to you, I would like to
` hear your response on the issue of
` what provoked these IPRs. The
` petitioner says they were a result of
` a suit that you filed against LG
` Display. Does that sound reasonable
` to you?
` MR. KIMBLE: Well, I think that
` is an interesting point. And it's
` interesting to focus on the timing of
` LG Display's filing of the IPRs. LG
` Display was not served in the other
` litigation that Mr. Pluta referenced
` for another five or six months after
` the suits were filed against Dell and
` HP; however, LG Display filed the five
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`Page 14
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` -Proceeding-
` IPRs two days before the deadline for
` Dell and HP to file the IPRs. This
` suggests that LG Display and its
` counsel which it shares, as Mr. Pluta
` said, with Dell and HP knew or were
` concerned at least that they were in
` privity and that there was a bar for
` them to file those IPRs.
` HON. GIANNETTI: Maybe they were
` just being careful.
` MR. KIMBLE: It's possible, Your
` Honor, but it's not only that fact.
` You also have the fact that LG Display
` indemnifies, as Mr. Pluta said, Dell
` and HP in the underlying litigation.
` HON. GIANNETTI: But that
` doesn't mean they control, does it?
` MR. KIMBLE: No, sir, but it is
` a factor. It's a factor and their
` activities in the litigation show that
` they control it. LG Display's counsel
` is managing these litigation matters
` for Dell and HP, taking the
` depositions, handling the hearings and
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`Page 15
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` -Proceeding-
` so forth. So we think that the timing
` of the first IPR filings, the
` indemnification, the shared counsel
` all show or suggest strongly that LG
` Display controls the litigation and is
` in privity to. And keep in mind what
` we are asking for is just the
` permission to file a motion and seek
` the discovery and seek limited
` discovery that we think will show
` this.
` HON. GIANNETTI: But even if you
` were able to prove that they control
` the litigation which I think may not
` pan out for you, how are you showing
` that the barred parties are
` controlling the IPR, that the
` situation where the IPR is filed by a
` party that is not barred and its
` contention is that a barred party is
` controlling the IPR? How are you
` going to show that? It sounds like to
` me that you are not going to be able
` to do that and that is not even your
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`Page 16
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` -Proceeding-
` theory.
` MR. BRAGALONE: Your Honor, this
` is Mr. Bragalone. I just want to make
` one other point here that we think is
` very telling. Mr. Pluta argues that
` in fact LG has not been in control of
` the litigation and is not making the
` decision, but the exact opposite
` representation was made to Judge Olsen
` in connection with the mediations in
` this case. We were explicitly told
` that Dell and HP both could not make
` decisions regarding resolution of the
` underlying litigation through Dell and
` HP unless LG and its counsel were
` available and present at the
` mediation. In fact, we had one
` mediation postponed and another
` mediation cancelled just so LG's
` counsel would be able to attend that
` mediation because in fact we believe
` they are controlling and in control of
` that litigation.
` HON. GIANNETTI: Mr. Bragalone,
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`Page 17
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` -Proceeding-
` you are not answering my question. I
` am focusing on this IPR. The issue is
` whether a party is barred from filing
` this IPR and the question is who is
` controlling the IPR. From what I am
` hearing, there's no dispute that it's
` being controlled by a party that is
` not barred, LG Display. So, I don't
` see where you are going with this.
` MR. KIMBLE: Your Honor, this is
` Justin Kimble. I want to answer your
` question directly.
` THE HEARING OFFICER: Maybe if
` the issue were estoppel in the
` district court your analysis would
` have some merit, but I don't see how
` your analysis tells us who is
` controlling this IPR whether a barred
` party is in fact controlling this IPR
` and the IPR should be terminated. I
` don't see how you get there from what
` you told me.
` MR. KIMBLE: So where we start
` with that is 35 U.S.C. 315(b) and it
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`Page 18
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` -Proceeding-
` says that the barred parties include
` the petitioner, real
` party-in-interest, or privy of the
` petitioner.
` HON. GIANNETTI: And the
` practice guide talks about control
` being a major factor in that
` consideration and that is something
` that is not part of your theory here.
` MR. KIMBLE: Well, our theory is
` that LG Display controls the
` litigation and, therefore, they are in
` privity with Dell and HP and,
` therefore, the bar includes not just
` Dell and HP but LG Display as well.
` HON. GIANNETTI: Okay. Anything
` further from the petitioner?
` MR. PLUTA: No.
` MR. KIMBLE: Your Honor, just to
` make one more statement just real
` quickly. This is a quote from an IPR
` in another proceeding that says
` IPR2013-00601, paper number 23 at page
` eight and it says "The normal rule
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`Page 19
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` -Proceeding-
` that privity requires a finding of
` active control of the trial."
` HON. GIANNETTI: I don't have
` that paper in front of me, but which
` trial are they talking about? I will
` have to take a look at that, but what
` trial are they talking about?
` MR. KIMBLE: Your Honor, this is
` Justin Kimble. My understanding is
` that is talking about the district
` court litigation.
` HON. GIANNETTI: We'll have to
` take a look at that.
` MR. KIMBLE: It is, Your Honor,
` I'm looking at it.
` HON. GIANNETTI: I think there's
` an issue here that I would like the
` panel to think about and discuss. I
` think I have your positions, Counsel,
` unless either of you have something to
` add, we will take your request under
` advisement.
` MR. PLUTA: Your Honor, this is
` Robert Pluta, just to rebut a couple
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`Page 20
`
` -Proceeding-
` of points that were made by Mr. Kimble
` and Mr. Bragalone. First starting
` with Mr. Kimble's contention of the
` timing of the first five IPRs. If we
` were in privity, LG Display was in
` privity with Dell and HP, why would we
` have only filed five at that time and
` not against all the patents? That is
` very consistent with what I had stated
` before that our concern was the
` Delaware case, not the Dell and HP
` case down in Texas.
` And second to Mr. Bragalone's
` point about the mediation, Mr.
` Bragalone put no timing on his
` argument. In fact, the mediation
` postdated all the petitions in this
` case and other suppliers were invited
` to those mediations and just chose not
` to attend. So I don't see how that
` fact alone would show control by LG
` display of the HP and Dell litigation.
` THE HEARING OFFICER: Anything
` further from the patent owner side?
`
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`Page 21
`
` -Proceeding-
` MR. KIMBLE: No, Your Honor.
` HON. GIANNETTI: All right. We
` have your positions now. The panel
` will consider this and get back to you
` with a decision probably in the form
` of a written order in the next few
` days. Thank you very much and we are
` adjourned.
` MR. KIMBLE: Thank you, Your
` Honor.
` MR. PLUTA: Thank you, Your
` Honor.
` [Time noted: 11:19 a.m.]
`
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`Page 22
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` CERTIFICATION
`
` I, Lisa Sansone, a Notary Public for
`and within the State of New York, do
`hereby certify:
` That the within transcript is a true
`and accurate translation of my
`stenographic notes.
` I further certify that I am not
`related to any of the parties to this
`action by blood or marriage, and that I am
`in no way interested in the outcome of
`this matter.
` IN WITNESS WHEREOF, I have hereunto
`set my hand this 3rd day of December, 2014.
`
` _____________________
` LISA SANSONE
`
`12
`
`34
`
`5
`6
`7
`8
`9
`10
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`
`[1 - dell]
`
`1
`
`1 6:12
`11:00 1:19
`11:19 21:14
`177 12:2
`
`2
`
`2 1:18
`2013 5:22 11:24
`2014 1:18 5:25 6:12
`22:16
`2014-01362 3:5
`2200 2:16
`23 18:24
`
`3
`3 5:22,25
`300 10:23
`31 11:24
`315 5:14 17:25
`35 5:14 17:25
`3rd 22:16
`4
`4500 2:17
`5
`547 10:19 11:11
`12:2
`
`6
`6,755,547 1:13
`60606 2:11
`7
`
`71 2:11
`75201-7924 2:17
`a
`a.m. 1:19 21:14
`able 15:14,24 16:21
`account 11:4
`accurate 22:8
`accused 10:20 11:5
`accusing 10:15
`act 4:11
`action 22:12
`
`active 19:3
`activities 14:21
`add 19:22
`additional 5:5,7
`6:19 8:7
`adjourned 21:9
`administrative 2:6
`advisement 19:23
`agree 9:9
`agreement 10:8
`agreements 8:9
`10:10
`ahead 5:17 13:2
`amanda 2:9 3:15
`analysis 17:16,18
`answer 17:12
`answering 17:2
`appeal 1:4 3:4
`appearing 3:11,21
`argues 16:6
`argument 20:17
`art 13:3
`asked 4:24
`asking 5:3 15:8
`attend 16:21 20:21
`attorneys 6:17
`available 16:17
`avenue 2:16
`b
`b 2:10,14 5:14 17:25
`back 6:7 13:10 21:5
`bar 6:11 7:22 14:8
`18:15
`barred 5:13 6:25
`7:10,11,19 15:17,20
`15:21 17:4,9,19
`18:2
`barring 7:15
`based 10:25
`beaber 2:10 3:15
`4:19 9:3
`behalf 2:8,13 3:14
`believe 4:22 6:19
`7:16 13:5 16:22
`
`bill 3:24
`blood 22:12
`board 1:4 3:4
`bragalone 2:15,15
`3:23 4:2,6,7 16:3,4
`16:25 20:3,16
`bragalone's 20:14
`brown 2:10 3:13
`bunting 2:21
`c
`
`c 2:2
`call 3:2,10 4:21
`cancelled 16:20
`careful 14:11
`case 1:12 8:2 10:15
`10:24 11:23 12:8,9
`12:11,13,14 16:12
`20:12,13,19
`cases 5:20 6:3 9:22
`certification 22:2
`certify 22:6,10
`chase 2:16
`cherry 10:20
`chicago 2:11
`chose 20:20
`client 7:22
`concern 20:11
`concerned 14:7
`conference 4:25
`12:12
`connection 16:11
`conroy 2:15
`consider 21:5
`consideration 18:9
`consistent 20:10
`conspiracy 12:16
`contain 10:21
`contend 7:11,20
`contending 7:6 9:24
`contends 9:16
`contention 15:21
`20:4
`contentions 11:2
`
`Page 1
`
`continue 5:17
`control 6:21 8:3,10
`8:13,19 9:18 10:12
`11:6,16 13:8 14:18
`14:22 15:14 16:7,23
`18:7 19:3 20:22
`controlled 10:12
`17:8
`controlling 7:7,12
`7:18 12:17 15:18,22
`16:23 17:6,19,20
`controls 15:6 18:12
`conveniently 10:20
`correct 7:7,8 8:14
`8:22,23
`counsel 6:16 8:6
`12:20 14:5,22 15:4
`16:16,21 19:20
`couple 19:25
`course 5:24
`court 17:16 19:12
`courtesy 4:18
`creates 7:22
`crystal 6:4 10:16
`11:3,5
`customers 7:21
`d
`dallas 2:17
`date 6:12 9:15
`dates 9:11
`day 22:16
`days 6:11 14:2 21:8
`deadline 5:23 14:2
`december 1:18
`11:24 22:16
`decision 16:9 21:6
`decisions 16:14
`defendants 5:19
`delaware 11:23
`12:10 20:12
`dell 5:12,18,21 6:3,5
`6:15,23,24 7:6,10
`8:13 9:17,18,19,25
`10:6,8,13,21 11:7
`
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`
`[dell - kennedy]
`
`11:15 12:8,18,21,22
`13:5,24 14:3,6,15
`14:24 16:13,15
`18:14,16 20:7,12,23
`depositions 14:25
`directed 10:16
`directly 17:13
`discovery 5:5,7,10
`5:10 6:20 8:7 11:14
`15:10,11
`discuss 19:19
`discussing 6:14 7:3
`display 1:6,9 3:7,8
`3:14 5:11 6:4,5,6,9
`6:15,20 7:17,21 8:4
`8:10,18 9:17,20,24
`10:6,11,17,22 11:3
`11:7,22 12:2,5,11
`12:17 13:8,15,21,25
`14:4,14 15:6 17:9
`18:12,16 20:6,23
`display's 13:20
`14:22
`dispute 17:7
`district 11:23 17:16
`19:11
`drive 2:11
`e
`e 2:2,2 3:18
`eight 11:25 18:25
`either 9:20 19:21
`esq 2:9,9,10,14,14
`2:15
`estoppel 17:15
`event 8:20
`evidence 11:9
`evidenced 8:5
`exact 16:9
`exists 11:14
`explicitly 16:12
`extended 4:19
`
`f
`
`f 3:18,18
`fact 10:23 11:20
`12:20 14:13,14 16:7
`16:18,22 17:20
`20:17,22
`factor 14:20,20 18:8
`facts 7:25 9:9 13:7
`factual 9:12
`file 5:4,23 12:5 14:3
`14:9 15:9
`filed 5:20 6:6,10,13
`11:24 12:11 13:4,14
`13:24,25 15:19 20:8
`filing 5:13 7:2 9:21
`13:20 17:4
`filings 15:3
`finding 19:2
`fine 4:21
`firm 12:23,25
`first 15:3 20:3,5
`five 6:10 13:23,25
`20:5,8
`floor 4:23
`focus 13:19
`focusing 17:3
`form 21:6
`forth 15:2
`front 19:5
`further 18:18 20:25
`22:10
`
`g
`
`g 2:9
`getting 13:10
`giannati 3:16,19
`giannetti 2:5 3:2,25
`4:9,20 5:16 7:4,9,20
`8:12,20,24 9:8,23
`10:4 13:9 14:10,17
`15:13 16:25 18:6,17
`19:4,13,17 21:3
`give 3:6 4:23
`go 5:17
`
`going 9:3 15:23,24
`17:10
`guess 4:18
`guide 18:7
`h
`hac 4:2,10
`hand 22:16
`handling 14:25
`hear 8:25 9:14 11:8
`13:11
`hearing 17:7,14
`20:24
`hearings 14:25
`hereunto 22:15
`hire 13:6
`hon 3:2,16,19,25 4:9
`4:20 5:16 7:4,9,20
`8:12,20,24 9:8,23
`10:4 13:9 14:10,17
`15:13 16:25 18:6,17
`19:4,13,17 21:3
`honor 3:13,22 4:6
`4:17 5:2,15 9:14
`10:3 14:13 16:3
`17:11 18:20 19:9,15
`19:24 21:2,11,13
`honorable 2:5
`hp 5:12,18,21 6:3,6
`6:15,23,25 7:6,11
`8:13 9:18,19,19,25
`10:6,9,13,21 11:7
`11:15 12:9,18,21,21
`13:6,25 14:3,6,16
`14:24 16:13,16
`18:14,16 20:7,12,23
`i
`identified 5:6
`illinois 2:11
`important 11:20
`include 18:2
`includes 11:25
`18:15
`including 6:17
`11:25
`
`Page 2
`
`indemnification 8:8
`10:5,8,10 15:4
`indemnifies 6:24
`14:15
`indemnifying 9:25
`indicated 12:13
`infringement 10:25
`infringing 6:23
`innovative 1:9 3:8
`intends 12:14
`interest 5:8 18:4
`interested 22:13
`interesting 13:18,19
`invited 20:19
`involve 3:5
`ipr 5:23 6:10 15:3
`15:18,19,22 17:3,5
`17:6,19,20,21 18:22
`ipr2013-00601
`18:24
`ipr2014-01357 1:12
`3:4
`iprs 5:14 6:13 7:2,7
`7:12 8:14 12:6,7,11
`12:15 13:4,12,20
`14:2,3,9 20:5
`irrelevant 12:22
`issue 6:2,8 10:24
`13:11 17:3,15 19:18
`j
`jamie 2:10 3:15
`jeff 3:23
`jeffrey 2:15
`judge 2:6,21,21
`12:13 16:10
`july 5:22,25 6:12
`justice 5:8
`justin 2:14 3:23
`17:12 19:10
`k
`
`k 2:9
`keep 15:7
`kennedy 2:14 3:24
`
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`
`[kimble - proceeding]
`
`kimble 2:14 3:22,23
`4:7,23 5:2,18 7:5,8
`7:14,24 8:15,23
`9:15 13:9,17 14:12
`14:19 17:11,12,24
`18:11,20 19:9,10,15
`20:2 21:2,10
`kimble's 12:23,25
`20:4
`knew 14:6
`know 8:17
`l
`
`l 2:5
`law 2:6
`lead 4:8
`level 8:3,9
`lg 1:6 3:7,14 5:11
`6:4,6,9,15,20 7:17
`7:21 8:4,10,18 9:16
`9:20,24 10:6,11,17
`10:22 11:3,7,22
`12:2,4,11,17 13:8
`13:14,20,20,25 14:4
`14:14,22 15:5 16:7
`16:16 17:9 18:12,16
`20:6,22
`lg's 16:20
`limited 3:7 5:10
`6:19 8:7 15:10
`liquid 6:3 10:16
`11:2,5
`lisa 22:4,21
`litigated 12:23,24
`litigation 5:19 6:9
`6:22 7:18 8:4,11
`9:19 10:13 11:16
`12:18,22 13:22
`14:16,21,23 15:6,15
`16:8,15,24 18:13
`19:12 20:23
`llc 1:9 3:9
`llp 2:10
`look 19:7,14
`
`looking 19:16
`m
`major 18:8
`making 9:3,6 16:8
`managing 14:23
`marriage 22:12
`matter 22:14
`matters 5:6,20 8:11
`14:23
`mayer 2:10 3:13
`mean 8:16 14:18
`mediation 16:18,19
`16:20,22 20:15,17
`mediations 16:11
`20:20
`mere 11:13
`merit 17:17
`mind 15:7
`module 10:16
`modules 6:4,5 11:3
`11:5
`months 6:13 13:23
`morning 4:5
`motion 5:4 15:9
`move 12:14
`multiple 11:18
`n
`
`n 2:2
`name 3:17
`necessarily 8:17
`necessary 4:12
`new 1:17,17 22:5
`normal 18:25
`notary 22:4
`noted 21:14
`notes 22:9
`notion 11:6
`number 18:24
`o
`objection 4:14,15
`office 1:2
`officer 17:14 20:24
`
`okay 3:16 4:9,20 7:4
`9:8 18:17
`olsen 16:10
`omits 10:22
`omitted 11:21
`once 12:15
`opposite 8:16 16:9
`order 21:7
`outcome 22:13
`owner 1:10 2:13 3:9
`3:20 4:22 9:10
`10:14,19 11:9,21,22
`12:3 20:25
`p
`
`p 2:2,2
`page 18:24
`pan 15:16
`panel 19:19 21:4
`paper 18:24 19:5
`part 18:10
`participate 4:13
`participating 4:4
`particularly 10:14
`11:17
`parties 3:6 7:10,15
`11:19 15:17 18:2
`22:11
`parts 10:22
`party 15:20,21 17:4
`17:8,20 18:4
`patent 1:2,4,10,13
`2:13 3:3,9,20 4:22
`9:10 10:14,19,19
`11:9,12,21,22 12:2
`12:3 20:25
`patents 6:8 11:25
`20:9
`patterns 6:11
`pc 2:15
`pending 4:3
`permission 5:4 15:9
`petition 4:3,10
`10:19
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`Page 3
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`petitioner 1:7 2:8
`3:8,11 4:13 5:11
`8:25 13:13 18:3,5
`18:18
`petitions 5:24 6:10
`9:21 20:18
`phone 6:18
`picks 10:20
`please 4:24
`pluta 2:9 3:12,13,18
`4:16,17 9:2,5,6,9,13
`10:2,7 13:22 14:5
`14:15 16:6 18:19
`19:24,25 21:12
`point 13:18 16:5
`20:15
`points 20:2
`positions 19:20 21:4
`possibility 11:13
`possible 14:12
`postdated 20:18
`postponed 16:19
`powell 2:21
`practice 18:7
`preliminary 10:18
`11:10
`present 2:20 16:17
`presentation 4:4 9:4
`9:7,12
`presiding 2:4
`presumably 10:9
`prior 6:11 9:20
`12:12 13:3
`privity 5:12 7:16,17
`9:17 14:8 15:7
`18:14 19:2 20:6,7
`privy 18:4
`pro 4:2,10
`probably 21:6
`proceeding 3:1 4:1
`5:1 6:1 7:1 8:1 9:1
`10:1 11:1 12:1 13:1
`14:1 15:1 16:1 17:1
`18:1,23 19:1 20:1
`21:1
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`
`[proceedings - worked]
`
`proceedings 1:21
`3:3
`products 10:15,21
`10:24 11:6
`promptly 4:11
`prove 15:14
`provide 11:10
`provoked 13:12
`public 11:2 22:4
`put 20:16
`q
`question 17:2,5,13
`quickly 18:22
`quote 18:22
`r
`r 2:2,15 3:18
`real 18:3,21
`reason 5:9 8:2 12:4
`reasonable 13:5,15
`rebut 19:25
`referenced 13:22
`regarding 12:25
`16:14
`related 5:19 22:11
`relates 6:3
`relationship 10:5
`representation
`16:10
`represented 6:16
`represents 12:21
`request 19:22
`requested 4:21
`requires 19:2
`resolution 16:14
`respect 11:11
`respectfully 5:22
`response 10:18
`11:11 13:11
`result 13:13
`right 3:19,25 7:10
`8:24 9:4 21:3
`robert 2:9 3:13 9:5
`19:25
`
`roll 3:10
`ross 2:16
`rule 18:25
`s
`s 2:2,11 3:18
`sansone 22:4,21
`says 13:13 18:2,23
`18:25
`scheduling 12:12
`second 3:17 20:14
`see 17:10,17,22
`20:21
`seek 15:9,10
`sense 11:15
`served 5:21 9:11
`13:21
`set 22:16
`seven 6:8
`shared 8:5 15:4
`shares 14:5
`show 5:11 6:20 8:7,9
`8:13 14:21 15:5,11
`15:23 20:22
`showing 15:16
`shows 11:12
`side 20:25
`sir 14:19
`situation 15:19
`six 13:23
`sorry 10:2
`sort 13:7
`sought 11:13
`sound 13:15
`sounds 15:23
`speculation 11:8
`stands 12:4
`start 17:24
`starting 20:3
`state 22:5
`stated 9:10 20:10
`statement 18:21
`states 1:2
`stay 12:15
`
`stenographic 22:9
`step 6:7
`streff 2:9 3:15 9:2
`strongly 15:5
`sued 11:22 12:4
`suggest 15:5
`suggests 14:4
`suing 7:21
`suit 13:14
`suite 2:17
`suits 13:24
`supplied 10:22
`supplier 7:23 8:3
`11:17 12:3
`suppliers 10:11,17
`11:18 20:19
`supplies 6:5,22
`sure 4:13
`suspect 8:15,16
`suspicion 8:18
`t
`t 2:14 3:18
`take 4:8 6:7 19:7,14
`19:22
`talking 19:6,8,11
`talks 18:7
`technologies 1:9 3:9
`technology 6:2,23
`13:2,3
`teleconference 1:17
`tell 4:24
`telling 16:6
`tells 17:18
`terminated 17:21
`texas 2:17 20:13
`thank 3:12 21:8,10
`21:12
`theory 7:23 8:21
`12:16 16:2 18:10,11
`think 5:6,9 7:25 8:6
`11:20 13:17 15:2,11
`15:15 16:5 19:17,19
`19:20
`
`Page 4
`
`third 11:4
`thomas 2:5
`three 6:17
`time 20:8 21:14
`timing 12:7 13:19
`15:2 20:5,16
`today 3:11 6:14,18
`7:3
`told 16:12 17:23
`total 11:7
`tower 2:16
`trademark 1:2
`transaction 12:16
`transcript 1:21 22:7
`translation 22:8
`trial 1:4 3:4 19:3,6,8
`true 9:16 12:19 22:7
`turn 11:15
`two 3:3 5:5,14,19
`6:11,12,13 7:2
`10:20 14:2
`u
`
`u.s. 1:13
`u.s.c. 5:14 17:25
`underlying 6:9,21
`14:16 16:15
`understanding
`19:10
`united 1:2
`v
`
`v 1:8
`
`w
`
`w 2:17
`wacker 2:11
`want 12:5 16:4
`17:12
`wanted 13:6
`way 22:13
`whereof 22:15
`william