` IPR Nos. 2014-(1482, 1494)
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
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`TSMC NORTH AMERICA CORP.,
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`FUJITSU SEMICODUCTOR LIMITED AND
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`FUJITSU SEMICONDUCTOR AMERICA, INC.
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`Petitioners
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`v.
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`ZOND, LLC
`Patent Owner
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`U.S. Patent No. 6,896,775
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`_____________________
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` Inter Partes Review Case Nos:
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`IPR Nos. 2014-(1482, 1494)
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`_________________
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`PATENT OWNER’s OPPOSITION TO MOTION FOR JOINDER
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`Patent No. 6,896,775
`IPR Nos. 2014-(1482, 1494)
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`ARGUMENT
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`Zond LLC (“Zond”) has not yet filed a Preliminary Response in this
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`matter and therefore reserves to the right to oppose joinder on any grounds
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`raised in its Preliminary Response. However, Zond notes here that the terms
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`of Joinder proposed in Petitioner’s motion are potentially ambiguous as to the
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`page limitations of the proposed consolidated filings. Zond therefore proposes,
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`without waiving any objections it may raise in its preliminary response, that
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`the terms of any joinder clearly state that the consolidated filings will be made
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`in accordance with the Board's established rules regarding page limits for a
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`single party:
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`PROPOSED ORDER
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`For purposes of this Proposed Order, the term “Joined Petitioners” shall
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`refer to all parties who are joined in the Lead Petitioner’s IPR, including Lead
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`Petitioner and all entities subsequently joined in any proceeding resulting from
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`the Lead Petitioner’s petition. The term “Copied IPR” shall refer to a petition
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`that is a copy of Lead Petitioner’s petition.
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`ZOND proposes joinder under the following conditions:
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` If review is instituted on any ground in the Lead Petitioner’s IPR,
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`each Copied IPR will be instituted on the same grounds and will
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`Patent No. 6,896,775
`IPR Nos. 2014-(1482, 1494)
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`be joined with the Lead Petitioner’s IPR. Grounds not instituted in
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`the Lead Petitioner’s IPR will be similarly denied in the Copied
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`IPR.
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` The scheduling order for the Lead Petitioner’s IPR will apply in
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`the joined proceeding.
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` Throughout the proceeding, the Joined Petitioners will file papers
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`as consolidated filings, except for motions that do not involve the
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`other parties, in accordance with the Board's established rules
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`regarding page limits for one party. So long as any Joined
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`Petitioners continue to participate in the joined proceeding, all
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`such remaining Joined Petitioners will continue to file their papers
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`as consolidated filings and will be responsible for completing all
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`consolidated filings.
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` The Joined Petitioners will designate an attorney to conduct the
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`cross examination of any given witness produced by Zond, and the
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`redirect of any given witness produced by the Joined Petitioners,
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`within the timeframe normally allotted by the rules for one party.
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`The Joined Petitioners will not receive any separate cross-
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`examination or redirect time.
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`Patent No. 6,896,775
`IPR Nos. 2014-(1482, 1494)
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` Zond will conduct any cross examination of any given witness
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`jointly produced by Joined Petitioners and the redirect of any
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`given witness produced by Zond within the timeframe normally
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`allotted by the rules for one cross-examination or redirect
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`examination.1
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`Date: September 26, 2014
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` Respectfully submitted,
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`/Bruce Barker/
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`Bruce Barker
`Reg. No. 33,291
`Chao Hadidi Stark & Barker LLP
`176 East Main Street, Suite 6
`Westborough, MA 01581
`(508) 366-3800
`bbarker@chsblaw.com
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`1 Lastly, Zond also respectfully asks to reserve the right to request even further
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`consolidation after the Board’s decisions on whether to institute review in response
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`to the various Lead Petitioner petitions on the same patent.
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`3
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`Patent No. 6,896,775
`IPR Nos. 2014-(1482, 1494)
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing Patent Owner’
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`Revised Opposition to Motion for Joinder was served via email on September
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`26, 2014, on the attorneys for all Petitioners:
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`David L. McCombs
`David M. O’Dell
`HAYNES AND BOONE, LLP.
`2323 VICTORY AVENUE SUITE 700
`DALLAS TEXAS 75219
`TELEPHONE: (214) 651-5533
`FAX: (214) 200-0853
`EMAIL: David.McCombs@haynesboone.com
`david.odell@haynesboone.com
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`/Bruce Barker/
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`Bruce Barker
`Reg. No. 33,291
`Chao Hadidi Stark & Barker LLP
`176 East Main Street, Suite 6
`Westborough, MA 01581
` (508) 366-3800
`bbarker@chsblaw.com
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`4
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