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UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`APPLE INC.,
`ZTE CORPORATION and ZTE (USA) INC.,
`Petitioners
`v.
`E-WATCH, INC.,
`Patent Owner
`_____________________
`
`
`IPR2015-00412
`IPR2015-013661
`U.S. Patent No. 7,365,871 B2
`_____________________
`
`
`
`TRANSMITTAL LETTER ACCOMPANYING SUBMISSION OF
`CORRECTED EXHIBIT 1022
`
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`1 IPR2015-01366 has been joined with IPR2015-00412.
`
`
`
`

`
`Exhibit 1022 filed with the Petitioner Reply was intended to be the
`
`
`
`
`
`Complaint from Garnet Digital, LLC v. Apple Inc., No. 6:11-cv-000647 (E.D.
`
`Tex.), see Petitioner’s Reply, Paper 30 at iii (Oct. 15, 2015), but the Amended
`
`Complaint from that same case was inadvertently filed instead. Petitioner
`
`requested authorization to file a motion to substitute Exhibit 1022 with Corrected
`
`Exhibit 1022, and Patent Owner indicated it did not oppose the substitution of
`
`Corrected Exhibit 1022. As authorized by the Board by e-mail from Ms. Vignone
`
`on December 11, 2015, Petitioner hereby submits Corrected Exhibit 1022
`
`(Complaint, Garnet Digital, LLC v. Apple Inc., No. 6:11-cv-00647 (E.D. Tex.).).
`
`
`
`
`
`DATED: December 14, 2015
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`By: /s/ Brian M. Buroker
`
`Brian M. Buroker (Reg. No. 39,125)
`Blair A. Silver (Reg. No. 68,003)
`GIBSON, DUNN & CRUTCHER LLP
`1050 Connecticut Avenue, N.W.
`Washington, DC 20036-5306
`Telephone: 202.955.8500
`Facsimile: 202.467.0539
`bburoker@gibsondunn.com
`bsilver@gibsondunn.com
`
`Attorneys for Petitioner Apple Inc.
`
`
`1
`
`

`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies service pursuant to 37 C.F.R. § 42.6(e) of a copy
`
`
`
`
`
`of this Transmittal Letter Accompanying Submission of Corrected Exhibit 1022
`
`by electronic mail on December 14, 2015 on the counsel of record for:
`
`Patent Owner:
`
`Greg Donahue, gdonahue@dpelaw.com
`
`Andrew DiNovo, adinovo@dpelaw.com
`
`Robert C. Curfiss, bob@curfiss.com
`
`David Simmons, dsimmons1@sbcglobal.net
`
`ZTE Corporation and ZTE (USA) Inc.:
`
`
`
`
`
`
`
`
`
`Steve Moore, steve.moore@pillsburylaw.com
`
`Richard Thill, richard.thill@pillsburylaw.com
`
`Barry Shelton, barry.shelton@pillsburylaw.com
`
`Brian Nash, nash@pillsburylaw.com
`
`
`
`DATED: December 14, 2015
`
`By: /s/ Brian M. Buroker
`
`
`
`
`
`
`
`Brian M. Buroker (Reg. No. 39,125)
`
`Attorney for Petitioner Apple Inc.
`
`2

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