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Paper No. _____
` Filed: May 27, 2015
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`
`
`TOYOTA MOTOR CORPORATION
`
`Petitioner
`
`v.
`
`INNOVATIVE DISPLAY TECHNOLOGIES LLC
`
`Patent Owner
`
`______________
`
`Case No.: IPR2015-00857
`Patent No. 7,384,177
`______________
`
`
`
`PETITIONER’S UPDATED EXHIBIT LIST
`
`
`
`
`
`
`
`
`
`
`
`
`

`
`Case No.: IPR2015-00857
`
`Patent No. 7,384,177
`
`Further to 37 C.F.R. 42.63 (e), Petitioner Toyota Motor Corporation hereby
`
`submits a current listing of Toyota Exhibits to the Board and counsel for Patent
`
`Owner Innovative Display Technologies LLC.
`
`Filed Exhibits
`Exhibit 1001
`
`Description
`U.S- Patent No. 7,384,177
`
`Exhibit 1002
`
`Prosecution History of U.S. Patent No. 7,384,177
`
`Exhibit 1003
`
`Complaint filed in Innovative Display Technologies LLC v.
`.
`~
`. Inc., Case No. 2: l4—cv—00200—JRG
`
`Declaration ofDr. Zane Coleman (“Coleman Decl.”)
`U.S. Patent No. 5,461,547 (“Ciupke”)
`
`Exhibit 1008
`
`Exhibit 1009
`
`IPR2014-01362, Paper No. 2, “Petition for Inter Partes
`Review of U.S. Patent No. 7,384,177”
`
`IPR2015—00359, Paper No. 1, “Petition for Inter Partes
`Review ofClaims 1-3, 5-7, 9-10, 13-15, 19, 21, and 23-27 of
`
`U.S. Patent No. 7,384,177”
`
`Exhibit 1010
`
`Exhibit 101 1
`
`IPR2015-00489, Paper No. 2, “Petition for Inter Partes
`Review of U.S_ Patent No. 7,384,l77”
`
`IPR2015-00756, Paper No. 2, “Petition for Inter Partes
`Review of U.S. Patent No. 7,384,177”
`
`Exhibit 1012
`
`U.S. Patent No. 5,160,195 (“Miller”)
`
`Exhibit 1013
`
`J. A. Castellano, Handbook ofDisplay Technology, Academic
`Press Inc., San Diego, 1992, pp. 9-14 and Ch. 8
`
`Exhibit 1014
`
`U.S. Patent No. 5,598,280 (“Nishio”)
`
`Exhibit 1015
`
`U.S. Patent No. 5,384,658 (“0htake”)
`
`Exhibit 1016
`
`U.S. Patent No. 5,303,322 Winston”)
`
`

`
`Case No_: IPR2015-00857
`
`Patent No. 7,384,177
`
`Filed Exhibits
`Exhibit 1017
`
`Exhibit 1018
`
`U.S. Patent No. 5,050,946 (“Hathaway”)
`
`European Patent Application Publication No. EP5 00960
`(‘€0he,))
`
`Exhibit 1019
`
`U.S- Patent No. 5,828,488 (“0uderkirk”)
`
`Exhibit 1020
`
`3M product brochure 75-0500-0403-7, “Brightness
`Enhancement Film BEF
`2
`
`Exhibit 1021
`
`U.S. Patent No. 5,706,134 (“Konno”)
`
`Exhibit 1022
`
`U.S- Patent No. 5,944,405 (“Takeuchf’
`
`Exhibit 1023
`
`U.S. Patent No. 5,381,309 (“Borchardt”)
`
`Exhibit 1024
`
`Exhibit 1025
`
`IPR2014-01362, Paper No. 12, “Decision Granting Institution
`of Inter Partes Review”
`
`IDT’s preliminary infiingement contentions vs. Toyota:
`Exhibit B2: Exemplary claim chart for U_S. Pat. No.
`7,3 84, 1 77
`
`Exhibit 1026
`
`IPR2015—00835, Paper No. 2, “Petition for Inter Partes
`Review of U.S_ Patent No. 7,384,177”
`
`Exhibit 1027
`
`HIGHLY CONFIDENTIAL Executed Settlement Agreement
`between Innovative Display Technologies, Inc. and Toyota
`Motor Corporation (contains HIGHLY CONFIDENTIAL
`BUSINESS INFORMATION)
`
`Exhibit 1028
`
`IDT v Toyota, E.D.Tx. case no. 2:] 4—cv—200—JRG, Dkt. No. 22,
`Order Dismissing Case without Prejudice, filed May 20, 2015
`
`

`
`Case No.: IPR2015-00857
`Patent No. 7,384,177
`
`
`
`
`
`
`
`Respectfully Submitted,
`
`
`Dated: May 27, 2015
`
`
`
` /P. Andrew Riley/
`
`
`P. Andrew Riley, Lead Counsel
`Reg. No. 66,290
`Thomas W. Winland, Back-up Counsel
`Reg. No. 27,605
`David C. Reese, Back-up Counsel
`Reg. No. 67,942
`FINNEGAN, HENDERSON,
`FARABOW, GARRETT &
`DUNNER, LLP
`901 New York Avenue, NW
`Washington, DC 20001
`Tel.: 202.408.4266
`Fax: 202.408.4400
`Email: andrew.riley@finnegan.com
`Email: tom.winland@finnegan.com
`Email: david.reese@finnegan.com
`
`Toyota-IDT-IPR@finnegan.com
`
`Attorneys for Petitioner
`Toyota Motor Corporation
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`4
`
`
`

`
`
`
`
`Case No.: IPR2015-00857
`Patent No. 7,384,177
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing
`
`PETITIONER UPDATED EXHIBIT LIST AND EXHIBITS 1027 AND 1028
`
`were served on May 27, 2015 via email directed to counsel of record for the Patent
`
`Owner at the following:
`
`
`
`
`
`
`
`
`
`
`
`Justin Kimble, Lead Counsel
`jkimble@bcpc-law.com
`
`Jeffrey Bragalone
`jbragalone@bcpc-law.com
`
`Terry Saad
`tsaad@bcpc-law.com
`
`Nicholas Kliewer
`nkliewer@bcpc-law.com
`
`T. William Kennedy
`bkennedy@bcpc-law.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Bradley J. Moore/
`Bradley J. Moore
`Litigation Clerk
`
`
`
`
`
`FINNEGAN, HENDERSON,
`FARABOW, GARRETT &
`DUNNER LLP
`
`
`
`
`
`
`
`5
`
`
`
`
`Dated: May 27, 2015

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