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IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`BLACKBERRY CORP. and BLACKBERRY LTD.,
`Petitioners,
`
`v.
`
`ZIPIT WIRELESS INC.,
`Patent Owner.
`_______________
`
`Case IPR2014-01507
`Patent U.S. 7,292,870
`______________
`
`
`
`NOTICE OF SUPPLEMENTAL EVIDENCE
`UNDER 37 C.F.R. § 42.64(b)(2)
`
`
`
`In response to Patent Owner’s Objections Under 37 C.F.R. § 42.64(b)(1) to
`
`
`
`
`
`Evidence Submitted With Petitioner’s Reply, served on September 17, 2015,
`
`Petitioner submits the following items of supplemental evidence, pursuant to 37
`
`C.F.R. § 42.64(b)(2):
`
`
`
`Exhibit 1038 – Declaration of Jodi L. Gregory with exhibits, pertaining to
`
`previously submitted Exhibit 1037;
`
`1
`
`BLACKBERRY EX. 1042, pg. 1
`Blackberry v. Zipit
`IPR2014-01507
`
`

`
`Exhibit 1039 – Declaration of Dr. Rupert C. P. Lee of the British Library,
`
`Case IPR2014-01507
`Notice of Supplemental Evidence
`
`
`
`
`pertaining to previously submitted Exhibits 1018 and 1019; and
`
`Exhibit 1040 – Declaration of Jane Forster of Bournemouth University,
`
`pertaining to previously submitted Exhibits 1022, 1031 and 1032; and
`
`Exhibit 1041 – Declaration of John F. Presper, pertaining to previously
`
`submitted Exhibits 1014 and 1020.
`
`
`
`
`
`Respectfully submitted,
`Blackberry Corp. and
`BlackBerry Ltd.,
`Petitioners
`
`
`By: /Robert C. Mattson/
`Robert C. Mattson
`Registration No. 42,850
`OBLON, McCLELLAND,
`MAIER &, NEUSTADT, L.L.P.
`
`
`
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`
`
`2
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`
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`
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`
`
`
`
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`
`
`
`
`
`Customer Number
`
`
`
` 22850
`
`
`
`
`
`
`Tel: (703) 413-3000
`Fax: (703) 413 -2220
`(OMMN 07/09)
`
`
`
`BLACKBERRY EX. 1042, pg. 2
`Blackberry v. Zipit
`IPR2014-01507
`
`

`
`Case IPR2014-01507
`Notice of Supplemental Evidence
`
`
`EXHIBIT APPENDIX
`
` Description
`U.S. Patent No. 7,292,870 to Heredia et al.
`Excerpts from the prosecution history of U.S. Patent No. 7,292,870
`Declaration of Arthur T. Brody, Ph.D.
`Toshiba Pocket PC e740 User’s Manual
`Symbol PPT 2800 Series Produce Reference Guide for Pocket PC 2002
`Excerpts of Special Edition: Using Pocket PC 2002
`Toshiba Pocket PC e750 User’s Manual
`Exhibit A to Patent Owner’s Infringement Contentions dated May 2,
`2014
`Archived screenshots showing lists of emoticons used with various
`instant messaging programs
`Article entitled “Anytime, Anywhere” published on March 31, 2003 in
`the Wall Street Journal
`Verizon LTE White Paper entitled “LTE: The Future of Mobile
`Broadband Technology”
`Intentionally Left Blank
`Intentionally Left Blank
`Huawei Respondents’ Corrected Identification of Expert Witnesses,
`Investigation No. 337-TA-868 (U.S.I.T.C. June 27, 2013)
`Declaration of Alon Konchitsky, IPR2012-00026 and IPR2013-00109
`(May 21, 2013)
`Excerpts of July 2, 2013 A. Konchitsky deposition transcript in
`IPR2012-00026 and IPR2013-00109
`September 2001 Bournemouth University Research Awards Handbook
`British Library search results for “Konchitsky”
`March 3, 2014 British Library Research Report
`Directions and maps, Bournemouth University website
`August 27, 2015 A. Konchitsky deposition transcript
`September 8, 2015 Declaration of Prof. Mark Hadfield, Bournemouth
`University
`Photograph of bookshelf from the office of former Dean James Roach,
`Bournemouth University
`Photograph of bookshelf from the office of former Dean James Roach,
`Bournemouth University
`Photograph of bookshelf from the office of former Dean James Roach,
`
`
`
`Exhibit
`1001
`1002
`1003
`1004
`1005
`1006
`1007
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`1013
`1014
`
`1015
`
`1016
`
`1017
`1018
`1019
`1020
`1021
`1022
`
`1023
`
`1024
`
`1025
`
`
`
`BLACKBERRY EX. 1042, pg. 3
`Blackberry v. Zipit
`IPR2014-01507
`
`

`
`Case IPR2014-01507
`Notice of Supplemental Evidence
`
`
`Bournemouth University
`March 13, 2014 letter regarding Alon Konchitsky from Dr. F. Knight,
`Bournemouth University
`Results of Unit E database search for the name “Konchitsky”
`Results of Scopus search for “Konchitsky” and “Bournemouth”
`Konchitsky PhD diploma
`2002 Bournemouth University PhD diploma (name and thesis title
`redacted)
`September 9, 2015 Declaration of Emma Jackson, Bournemouth
`University
`September 9, 2015 Declaration of Dr. Fiona Knight, Bournemouth
`University
`Konchitsky MA diploma
`Joint Claim Construction and Prehearing Statement, Zipit Wireless Inc.
`v. BlackBerry Limited et al., Case No. 13-2959 (D.S.C.)
`September 3, 2014 Declaration of Alon Konchitsky, Zipit Wireless Inc.
`v. BlackBerry Limited et al., Case No. 13-2959 (D.S.C.)
`Introduction, Special Edition: Using Pocket PC 2002
`Dana Internet Solutions Guide
`September 29, 2015 Declaration of Jodi L. Gregory, with exhibits –
`SERVED ONLY
`September 24, 2015 Declaration of Dr. Rupert C. P. Lee, British
`Library – SERVED ONLY
`October 1, 2015 Declaration of Jane Forster, Bournemouth University –
`SERVED ONLY
`October 1,2015 Declaration of John F. Presper – SERVED ONLY
`
`1026
`
`1027
`1028
`1029
`1030
`
`1031
`
`1032
`
`1033
`1034
`
`1035
`
`1036
`1037
`1038
`
`1039
`
`1040
`
`1041
`
`
`
`BLACKBERRY EX. 1042, pg. 4
`Blackberry v. Zipit
`IPR2014-01507
`
`

`
`Case IPR2014-01507
`Notice of Supplemental Evidence
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on October 1, 2015, I caused a true and correct copy of
`
`
`
`
`
`the foregoing Notice of Supplemental Evidence, including Exhibits 1038–1040, to
`
`be served on the counsel of record for Patent Owner by delivering a copy via
`
`electronic mail to the following addresses:
`
`Stephen R. Risley
`srisley@srtslaw.com
`
`Robert B. Dulaney III
`rdulaney@srtslaw.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Robert C. Mattson/
`Robert C. Mattson
`Registration No. 42,850
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`BLACKBERRY EX. 1042, pg. 5
`Blackberry v. Zipit
`IPR2014-01507

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