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UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`MERCEDES-BENZ USA, LLC
`Petitioner,
`
`v.
`
`INNOVATIVE DISPLAY TECHNOLOGIES LLC,
`Patent Owner.
`______________
`Case IPR2015-00994
`Patent 6,886,956
`______________
`
`
`
`
`
`
`INNOVATIVE DISPLAY TECHNOLOGIES LLC’s
`MANDATORY NOTICES UNDER 37 C.F.R. 42.8(a)(2)
`
`Patent Owner, Innovative Display Technologies LLC, hereby files
`
`mandatory notices pursuant to 37 C.F.R. § 42.8(a)(2).
`
`A. Real Party-In-Interest (37 C.F.R. § 42.8 (b)(1))
`Innovative Display Technologies LLC is the owner of the entire interest in
`
`
`
`U.S. Patent No. 6,886,956 (“the ‘956 Patent”), and thus is a real-party-in-interest.
`
`B. Related Matters (37 C.F.R. § 42.8(b)(2))
`1
`
` 
` 
`
`

`

`
`
`The Patent Owner identifies the following judicial and/or administrative
`
`matters that may affect, or may be affected by, a decision in this Inter Partes
`
`Review:
`
`
`
`The ‘956 Patent is asserted by the Patent Owner in the following pending
`
`litigations in the U.S. District Court for the Eastern District of Texas: Innovative
`
`Display Technologies LLC v. BMW of North America, LLC and BMW
`
`Manufacturing Co., LLC, Civil Action No. 2:14-cv-106-JRG, filed February 28,
`
`2014; Innovative Display Technologies LLC v. Toyota Motor Corp. et al., Civil
`
`Action No. 2:14-cv-200-JRG, filed March 10, 2014; Innovative Display
`
`Technologies LLC v. Nissan Motor Co., Ltd. and Nissan North America, Inc., Civil
`
`Action No. 2:14-cv-202-JRG, filed March 10, 2014; Innovative Display
`
`Technologies LLC v. American Honda Motor Co., Inc.et al., Civil Action No. 2:14-
`
`cv-222-JRG, filed March 13, 2014; Innovative Display Technologies LLC
`
`v.Volkswagen AG et al., Civil Action No. 2:14-cv-300-JRG, filed April 7, 2014;
`
`and Innovative Display Technologies LLC v. Mercedes-Benz U.S. International,
`
`Inc. et al., Civil Action No. 2:14-cv-535, filed April 24, 2014.
`
`The ‘956 Patent is also asserted in the following pending litigations in the
`
`U.S. District Court of Delaware: Innovative Display Technologies LLC v. Ford
`
`Motor Company, Civil Action No. 1:14-cv-849, filed June 30, 2014; and
`
` 
` 
`
`2
`
`

`

`Innovative Display Technologies LLC v. GM, Civil Action No. 1:14-cv-850, filed
`
`June 30, 2014.
`
`Lead and Back-Up Counsel (37 C.F.R. § 42.8(b)(3))
`
`Patent Owner designates the following counsel:
`Lead Counsel
`Back-Up Counsel
`George W. Webb III
`Amir Alavi
`Pending Pro Hac Vice Motion
`Registration No. 60,737
`(gwebb@azalaw.com)
`(aalavi@azalaw.com)
`Telephone: 713-655-1101
`Brian Simmons
`Pending Pro Hac Vice Motion
`(bsimmons@azalaw.com)
`
`
`
`
`
`
`Address: AHMAD, ZAVITSANOS, ANAIPAKOS, ALAVI
`
`
`& MENSING P.C.
`
`
`1221 McKinney, Suite 3460
`
`
`Houston, TX 77010
`
`
`(713) 655-1101 (Reception)
`
`
`(713) 655-0062 (Facsimile)
`
`
`C. Service Information (37 C.F.R. § 42.8(b)(4))
`Please direct all correspondence regarding this proceeding to the counsel at
`
`
`
`the address listed above. Patent owner also consents to electronic service by email
`
`to the e-mail address listed above.
`
`
`
`
`
`
`
`
`
` 
` 
`
`3
`
`

`

`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully Submitted,
`
`By: /s/ George W. Webb III
`
`George W. Webb III
`
`Reg. No. 60,737
`
`
`Attorney for Patent Owner
`
`Innovative Display Technologies LLC
`
`
`
`
`
`
`
`Dated: April 10, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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`
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`
`
`AHMAD, ZAVITSANOS, ANAIPAKOS,
`ALAVI &MENSING, P.C.
`1221 McKinney Street, Suite 3460
`Houston, TX 77010
`Telephone: 713-655-1101
`
` 
` 
`
`4
`
`

`

`CERTIFICATE OF SERVICE
`I hereby certify that Innovative Display Technologies LLC’s Mandatory
`
`Notices Under 37 C.F.R. 42.8(a)(2) were served on this 10th day of April by
`electronic mail to the following:
`
`Lead Counsel
`Scott W. Doyle
`Reg. No. 39,176
`Shearman & Sterling LLP
`801 Pennsylvania Ave., NW
`Washington, DC 20004
`202-508-8000
`scott.doyle@shearman.com
`
`Back-up Counsel
`Jonathan R. DeFosse
`Shearman & Sterling LLP
`801 Pennsylvania Ave., NW
`Washington, DC 20004
`202-508-8000
`jonathan.defosse@shearman.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`By: /s/ George W. Webb III
`
`George W. Webb III
`
`
`
`Reg. No. 60,737
`
`
`Attorney for Patent Owner
`
`Innovative Display Technologies LLC
`
`
`Dated: April 10, 2015
`
`
`
`
`
`
`
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`
`
`
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`
`
`
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`
`
`
`
`
`
`
`
`
`
`
`AHMAD, ZAVITSANOS, ANAIPAKOS,
`ALAVI &MENSING, P.C.
`1221 McKinney Street, Suite 3460
`Houston, TX 77010
`Telephone: 713-655-1101
`
` 
` 
`
`5
`
`

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