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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` - - - - - - - - - - - - - - - - - - - - - -x
`
`VALEO NORTH AMERICA, INC., VALEO S.A.,
`VALEO GMBH, VALEO SCHALTER UND SENSOREN GMBH,
`AND CONNAUGHT ELECTRONICS LTD.,
`
` Petitioner, Case IPR2015-01410
`
` vs. Patent 8,643,724 B2
`
`MAGNA ELECTRONICS, INC.,
`
` Patent Owner.
`
` - - - - - - - - - - - - - - - - - - - - - -x
`
` Telephonic Hearing
`
` ~ Before ~
`
` Hon. J. Arbis
`
` Hon. M. Fitzpatrick
`
` Hon. R. Weinschenk
`
` Thursday, May 26, 2016
`
`REPORTED BY:
`JEANESE JOHNSON
`REF: 16479
`
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`

`
`A P P E A R A N C E S:
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`Page 2
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`KIRKLAND & ELLIS, LLP
`Attorneys for Petitioner
` BY: HARI SANTHANAM, ESQ.
` 300 North LaSalle
` Chicago, Illinois 60654
` (312) 862-7172
` (312) 862-2200
` hari.santhanam@kirkland.com
`
`STERNE, KESSLER, GOLDSTEIN, FOX
`Attorneys for Patent Owner
` BY: SALVADOR M. BEZOS, ESQ.
` 1100 New York Avenue NW, Suite 600
` Washington, DC 20005
` (202) 371-2600
` (202) 371-2540
` sbezos@skgf.com
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` --o0o--
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` 9:00 a.m.
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`Page 3
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` HON. J. ARBIS: Good morning,
`
` everyone. This is Judge Arbis with the
`
` Patent Trial and Appeal Board. I have
`
` with me on the line Judge Fitzpatrick and
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` Judge Weinschenk. This is a call in
`
` IPR2015-01410.
`
` Are there counsel for the
`
` Petitioner on the line?
`
` MR. SANTHANAM: Yes, Your
`
` Honor. This is Hari Santhanam from
`
` Kirkland & Ellis on behalf of the
`
` Petitioners.
`
` HON. J. ARBIS: Okay.
`
` And counsel for the Patent
`
` Owner.
`
` MR. BEZOS: Yes, good morning,
`
` Your Honors. This is Sal Bezos from
`
` Sterne Kessler, counsel for the Patent
`
` Owner, Magna Electronics.
`
` HON. J. ARBIS: Great. Thank
`
` you. And do we have a court reporter on
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` the line?
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` THE COURT REPORTER: Yes, we
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` do, Your Honor. Good morning.
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` HON. J. ARBIS: Thank you. And
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` was the court reporter retained by
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` Petitioner or Patent Owner?
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` MR. SANTHANAM: By the
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` petitioners, Your Honor.
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` HON. J. ARBIS: Okay.
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` MR. SANTHANAM: And again,
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` we'll arrange to have a transcript filed
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` with the court as soon as feasible.
`
` HON. J. ARBIS: Thank you very
`
` much. We appreciate that.
`
` Okay. The issue today to
`
` discuss I believe is Exhibits 1045,
`
` 1046, 1054, 1055 and 1060.
`
` So as I understand the facts,
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` the exhibits were not filed with
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` Petitioner's reply, were inadvertently
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` omitted, but then petitioners sought the
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` ability to file those afterwards.
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` As we understand it, Patent
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` Owner does not object to the late filing
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` of the exhibits but does object to them
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` being filed in reply at all.
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` So we can hear from counsel for
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` Patent Owner first.
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` Do we have the facts correct,
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` and if so, what relief would you be
`
` seeking?
`
` MR. BEZOS: Yes, Your Honor.
`
` That sounds like an accurate description.
`
` Just to add to that, it would not just be
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` the exhibits, but of course the relevant
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` portions of the reply we think would need
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` to be stricken or, you know, a new copy
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` of the reply filed with those sections
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` referencing these exhibits omitted.
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` The reason why we think that
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` this is an appropriate remedy is that
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` these exhibits -- and the reason why we
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` thought it was permissible for
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` Petitioner to submit the exhibits into
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` the record late, is that we did, in fact,
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` have these, but they were being used by
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` the Petitioner in response to evidentiary
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` objections, and so that's such a
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` completely different purpose from which
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` they are trying to use these exhibits
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` now, and that's as supplemental
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` information. They are being used to go
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` to the actual heart of the matter as to
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` whether the Wang reference is, in fact, a
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` prior art reference and not the earlier
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` dispute dealing with whether Wang should
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` be admissible in the first place or not.
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` By introducing the evidence at
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` this stage in the proceeding, first off,
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` the Patent Owner has no opportunity to
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` respond and we're not seeking an
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` opportunity to respond. We're seeking --
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` as far as the remedy, we're seeking all
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` of this to be expunged from the record,
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` but we're not afforded the opportunity.
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` It's very late in the game.
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` But second, the Petitioner was
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` in the position from the outset of this
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` proceeding, based on their knowledge of
`
` how this played out in ICR2014-00220, to
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` have cited everything that they could
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` have come across or would have needed at
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` the outset in the petition. And failing
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` that, should they have come across
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` anything else, the proper avenue to
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` approach this to introduce these exhibits
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` into the record is a motion for
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` supplemental information at the
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` post-institution stage, and they did not
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` seek that remedy either.
`
` HON. J. ARBIS: Okay. So we
`
` have a couple questions, and then I can
`
` hear from Petitioner.
`
` One, can you point us -- I have
`
` Petitioner's reply in front of me. Can
`
` you point to the specific portions of the
`
` reply that you believe should be
`
` stricken?
`
` MR. BEZOS: Yes, Your Honor.
`
` Let me see here. So on page 11, there's
`
` a few instances here.
`
` Yeah, so there's a citation to
`
` Exhibit 1055 at the bottom of page 11, so
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` there's some supporting sentences around
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` that.
`
` And on page 12, the last
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` paragraph of that same section in its
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` entirety is dealing with the new exhibits
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` and is also at issue there.
`
` HON. J. ARBIS: Okay.
`
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` MR. BEZOS: And, Your Honor, I
`
` apologize, and also on the very first
`
` paragraph of that section, there's a
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` Section 2 starting at page 11, there's a
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` citation to the Federal Circuit decision
`
` that's Exhibit 1045 as well, and so that
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` sentence should be stricken.
`
` HON. J. ARBIS: Okay. So it
`
` appears that on pages 11 and 12 there are
`
` some portions that talk about these five
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` specific exhibits and some portions maybe
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` that do not.
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` So you would be seeking to
`
` strike just the portions that talk about
`
` the new exhibits. Is that right?
`
` MR. BEZOS: That's correct,
`
` Your Honor. I mean, our position isn't
`
` that they are not allowed to respond to
`
` these issues. Our position is that their
`
` response should be contained to the
`
` evidence that they presented or should
`
` have presented previously; otherwise,
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` it's almost a clear extension of their
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` reach in a reply and the addition the
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` matter by adding this evidence and citing
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` to it.
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` HON. J. ARBIS: Okay. And your
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` position is that this argument that is
`
` made in Petitioner's reply is beyond the
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` scope of a proper reply. It's not in
`
` response to arguments made by Patent
`
` Owner in the response.
`
` MR. BEZOS: Well, Your Honor, I
`
` know that the Petitioner is going to say
`
` that it's responsive, but the issue isn't
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` I think whether it's responsive or not.
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` It's that under the Trial Practice Guide,
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` the Petitioner has an obligation to
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` present all of their evidence at the
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` outset or to follow the rules for
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` supplemental information.
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` And, you know, the Trial
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` Practice Guide very clearly says that a
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` reply that raises a new issue or
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` belatedly presents evidence will not be
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` considered and may be returned.
`
` And that's what transpired
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` here. It's allowing the Petitioner to
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` basically sand bag us with evidence that
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` they had been holding onto until this
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` late stage in the game cannot be allowed,
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` whether they think it's responsive or
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` not.
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` HON. J. ARBIS: Can we hear
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` from counsel for Petitioner. Would you
`
` like to respond?
`
` MR. SANTHANAM: Yes, Your
`
` Honor. Again, this is Hari Santhanam
`
` from Kirkland & Ellis.
`
` I would like to begin by way of
`
` a little bit of background, and I'd also
`
` like to address this argument that some
`
` of these exhibits that have been
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` presented since institution qualify as
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` supplemental information.
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` But first, by way of
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` background, as Your Honors may be aware,
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` due to the motions that were filed,
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` Kirkland & Ellis got involved in this ITR
`
` just shortly before institution.
`
` After the ITR was instituted,
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` Patent Owner served a number of
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` objections regarding exhibits, in
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` particular, as to the authenticity of
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` various articles, including the Wang
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` reference that seems to be the focus of
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` their current argument.
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` And in response to that, we
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` submitted declarations and other
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` evidence, including copies of articles
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` from different libraries, et cetera,
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` within the time frame for supplemental
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` evidence. And one outstanding piece of
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` that evidence was we had requested
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` certified copies of the Wang reference
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` and a couple of other articles that we
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` were able to locate at the Library of
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` Congress, and we were informed at that
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` time that it would take a period of time
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` to have the library actually prepare
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` those certifications and provide them in
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` the litigation. Or excuse me, in these
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` IPRs.
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` We received that from the
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` Library of Congress on March 18th, and we
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` served those on the Patent Owner that
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` very same day. And then on May 23rd in
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` our reply, we relied on some of these
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` exhibits, not all of them, some of these
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` exhibits that we submitted as
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` supplemental evidence. And to respond to
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` Patent Owner's arguments that the Wang
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` reference does not qualify as prior art.
`
` Now, I'll get into their
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` argument about supplemental information,
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` but one thing I want to make clear to
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` this board is that we're not talking
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` about, you know, whether there's a
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` question that Wang is prior art. I mean,
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` we've submitted a certified copy from the
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` U.S. Library of Congress the same day
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` that we received it. It doesn't get more
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` authentic than that, and it doesn't get
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` more dispositive than that as to whether
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` or not this reference is, in fact, prior
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` art.
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` So the only argument that they
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` are raising is that this certified copy
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` and a couple of other items that we had
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` submitted in response to Patent Owner's
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` objections and in the reply some been
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` submitted with the petition. And we
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` completely disagree with that.
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` It's supplemental information,
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` you know, as this board can appreciate,
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` you know, covers instances where things
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` should have been submitted with the
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` petition and substantive evidence in the
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` first instance. Here that's not the
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` case. What we submitted with the reply
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` was absolutely responsive to arguments
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` that the Patent Owner raised. There was
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` -- in our view based on the review of the
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` petition, even though we got involved
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` just shortly before institution, in our
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` view, the petition sets forth a very
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` strong prima facie case that this
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` particular reference, the Wang reference,
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` is, in fact, prior art.
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` There was a Federal Circuit
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` decision applying this reference as prior
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` art to a patent claim that had an earlier
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` priority date. There's a previous board
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` decision addressing the prior art nature
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` of this reference. We submitted with the
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` petition a declaration by one of our
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` experts explaining his experience with
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` IEEE and his background and opinion that
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` this is, in fact, prior art.
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` So there was quite a bit of
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` evidence that was submitted with the
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` petition to demonstrate that this was
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` prior art, and the court instituted it
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` based on that evidence.
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` And so what we have done is we
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` provided articles, certified copies of
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` articles and other information in
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` response to Patent Owner's objections to
`
` the evidence, and then when we saw the
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` Patent Owner's -- Patent Owner response,
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` again, arguing that this Wang reference
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` is not prior art, we then submitted that
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` in connection with our reply.
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` There's no question here that
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` this is all responsive to arguments that
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` the Patent Owner has raised.
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` HON. J. ARBIS: Okay. Can we
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` hear from counsel for Patent Owner. You
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` can have the last word, and then the
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` panel will confer.
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` MR. BEZOS: Yes, Your Honor.
`
` So a couple of things I want to
`
` address that Mr. Santhanam raised.
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` The first is kind of the
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` quality of these exhibits that are being
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` submitted and what they stand for, and I
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` know we don't really want to get into the
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` specifics, but since counsel raised the
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` issue, I wanted to note that the Federal
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` Circuit case nowhere addresses whether
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` Wang qualifies as a premiere publication
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` or not. That's just not an issue there.
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` And in the previous board
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` decision that opposing counsel raised,
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` that's which exhibit? Yeah, that's the
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` IPR2014-00220 case, in that case -- and
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` this is why our trajectory in this case
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` has proceeded the way it has -- the Board
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` made it clear that, you know, following
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` the Handi Quilter case that there's a
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` very clear separation between the
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` admissibility evidence issue and the
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` substantive issue of whether our
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` reference is, in fact, prior art or not.
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` And in this case, which we took
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` that to heart and made our arguments in
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` the Patent Owner response and dealt with
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` the admissibility issue separately.
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` What Petitioner has done here
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` is they basically brought in the exhibits
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` that they served on us for the purpose of
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` dealing with the admissibility issue,
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` which if we file a motion to exclude,
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` they can use those exhibits in that way
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` because that's how they've proceeded in
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` this case.
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` But by bringing these exhibits
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` in in their reply, they are bringing us
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` the exhibits at this late stage of the
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` game for the purpose of dealing with the
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` substantive issue of whether Wang is or
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` is not prior art.
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` Now --
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` HON. J. ARBIS: Can I ask the
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` question about the substantive issue.
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` So if you have a Petitioner
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` that presents some evidence with their
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` petition that references a prior art
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` printed publication and that's determined
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` by the board to make a threshold showing
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` at least sufficient to institute in the
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` case, Patent Owner in response argues
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` that it is not a printed publication, why
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` is the Petitioner not entitled to respond
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` to that and present new evidence? What
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` is your position on that?
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` MR. BEZOS: Well, I mean, I
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` think that the Petitioner is permitted to
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` respond to that, but any permissible
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` response has to be relying on the
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` previously submitted evidence because the
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` Petitioner has that, that threshold
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` burden of making the prima facie case.
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` And so they can introduce new
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` evidence at that stage, but any new
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` evidence that they bring in really has to
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` be directed to the substantive issues
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` that they dealt with at the outset of the
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` petition, whether the evidence that they
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` brought in initially to show that Wang is
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` prior art and to justify that it's prior
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` art itself shows that Wang is prior art.
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` So, you know, there is some
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` interpretation of the initial exhibits
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` that more clearly shows their point that
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` Wang is prior art, then sure they could
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` say that.
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` But what they have done here
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` instead is brought in entirely new copies
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` of the Wang reference, brought in
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` entirely new evidence that should -- it's
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` being used for a completely different
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` date. The Library of Congress date on
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` these documents doesn't match the date
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` that they originally suggested was the
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` Wang date. There's a conference date on
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` the initial document.
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` So it's kind of all over the
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` place. But I think more interestingly,
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` you can kind of tell what seems to have
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` happened here with the change of counsel,
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` that, you know, new counsel has decided,
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` okay, maybe there's an issue with the
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` sufficiency of the original pleading,
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` let's supplement that now. And the best
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` avenue to do that for them seemed to be
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` bringing in the reply when they had every
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` opportunity since March 18th to go the
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` proper route that would have allowed us a
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` response by submitting this as
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` supplemental information.
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` Now, opposing counsel said, Oh,
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` yeah, we felt really comfortable with
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` what was originally filed in the
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` petition.
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` So stick to that. I mean, I
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` think they should be held to that
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` original evidentiary issue, especially if
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` they are saying, and they represented
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` this to me on the call in the meet and
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` confer yesterday, that they felt
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` comfortable with what was there in the
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` petition. So if that's enough, then they
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` should be held to that.
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` HON. J. ARBIS: Okay. I think
`
` we understand both parties' positions.
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` We'll take just a minute while the panel
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` confers and be back shortly.
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` MR. SANTHANAM: Okay. Thank
`
` you, Your Honor.
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` (Pause)
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` HON. J. ARBIS: Okay. Do we
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` still have both parties on the line?
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` MR. SANTHANAM: Yes, Your
`
` Honor.
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` MR. BEZOS: Yes, Your Honor.
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` HON. J. ARBIS: Okay. The
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` panel has conferred, and one question
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` before we decide the matter. Do both
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` parties intend to request an oral hearing
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` in this matter?
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` MR. BEZOS: Your Honor, this is
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` counsel for the Patent Owner. At the
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` time we're undecided, but, yeah, we do
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` not know at the moment.
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` HON. J. ARBIS: Okay. Counsel
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` for Petitioner?
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` MR. SANTHANAM: Your Honor,
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` we're in the same position, although I
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` believe we're leaning towards no oral
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` argument. We believe the papers should
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` speak for themselves, but if the board is
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` inclined, we can have an oral argument.
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` HON. J. ARBIS: Okay. Well,
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` what we would like to do, given the
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` situation, we don't believe that a motion
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` to strike or deciding the matter now is
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` appropriate.
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` And so what the panel would
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` like to do is to have the parties address
`
` the issue at the hearing, if one is
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` requested, and then the panel can decide
`
` whether the arguments that were made by
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` Petitioner and the new evidence submitted
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` by Petitioner with the reply are
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`Page 21
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` appropriate as we would do at the time of
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` rendering any final written decision.
`
` So if the parties request a
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` hearing, I know that the deadline for
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` doing so is not until July 13th, but if
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` the parties request a hearing, you can
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` say in your request how much time you
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` believe would be appropriate for a
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` hearing to hear this issue as well as all
`
` the others and then the panel can make
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` that determination afterwards.
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` If the parties determine that
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` you would not like a hearing, we can
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` revisit the matter at that time.
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` Any questions from either
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` party?
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` MR. BEZOS: Your Honor, this is
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` counsel for the Patent Owner. Just one
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` quick question. If the parties do not
`
` request oral hearing for any reason,
`
` would the board still potentially weigh
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` this issue based on the transcript of
`
` this call?
`
` HON. J. ARBIS: Why don't we
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` revisit that issue if and when that
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`Page 22
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` occurs. Counsel, if you would like to
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` discuss the matter further if you believe
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` it would warrant additional discussion,
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` once the deadline passes or before that
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` deadline, if the parties determine that
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` they will both not be requesting hearing,
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` just request another conference call with
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` the panel and we can decide the issue at
`
` that time.
`
` MR. BEZOS: Okay. Great, Your
`
` Honor. I'm thinking for efficiency of
`
` the panel and the hearing, we wouldn't
`
` want to bring up an oral hearing if this
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` is the only issue that needs to be
`
` discussed. So certainly, if the board
`
` invites us to have a call after the
`
` deadline passes, then we might be willing
`
` to take you up on that.
`
` HON. J. ARBIS: Okay. Any
`
` other matters to discuss?
`
` MR. SANTHANAM: That's it for
`
` petitioners, Your Honor.
`
` MR. BEZOS: Nothing else for
`
` Patent Owner, Your Honor.
`
` HON. J. ARBIS: Thank you.
`
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`

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`Page 23
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` And may I ask counsel for
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` Petitioner, please file the transcript of
`
` the call as soon as it's available, and
`
` we are adjourned for today.
`
` MR. SANTHANAM: Great. Thank
`
` you.
`
` MR. BEZOS: Thank you.
`
` HON. J. ARBIS: Thank you.
`
` (Time noted: 9:20 a.m.)
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`Page 24
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` REPORTER'S CERTIFICATION
`
` I, Jeanese Johnson, Certified Shorthand
`
`Reporter, in and for the State of California,
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`do hereby certify:
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` That the foregoing proceedings
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`were reported stenographically by me and
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`later transcribed into typewriting under my
`
`direction;
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` That the foregoing is a true record of the
`
`proceedings taken at that time.
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` I further certify that I am not
`
`attorney or counsel of any of the parties,
`
`nor am I a relative or employee of any
`
`attorney or counsel of party connected with
`
`the action, nor am I financially interested
`
`in the action.
`
` The foregoing certification of this
`
`transcript does not apply to any reproduction
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`of same by any means unless under the direct
`
`control and/or direction of the certifying
`
`officer.
`
`IN WITNESS WHEREOF, I have subscribed my name
`
`this 26th day of May, 2016.
`
` ______________________________
` Jeanese Johnson, CSR No. 11635,
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`

`
`A
`a.m 3:2 23:10
`ability 4:22
`able 11:12
`absolutely 13:6
`accurate 5:8
`action 24:15,16
`actual 6:3
`add 5:9
`adding 8:25
`addition 8:24
`additional 22:3
`address 10:12
`14:23 20:20
`addresses 15:5
`addressing 13:19
`adjourned 23:4
`admissibility 15:17
`15:23 16:2
`admissible 6:7
`afforded 6:15
`allowed 8:18 10:1
`18:19
`allowing 9:23
`AMERICA 1:4
`and/or 24:20
`apologize 8:2
`Appeal 1:2 3:7
`appears 8:9
`apply 24:18
`applying 13:16
`appreciate 4:14
`12:25
`approach 7:1
`appropriate 5:16
`20:18 21:1,8
`Arbis 1:17 3:5,6,17
`3:24 4:4,9,13 7:6
`7:25 8:8 9:2 10:4
`14:17 16:14 19:10
`19:17,22 20:6,14
`21:24 22:19,25
`23:8
`argues 16:22
`arguing 14:11
`argument 9:3
`
`10:12 11:2 12:5
`12:17 20:11,13
`arguments 9:6 12:2
`13:6 14:15 15:21
`20:23
`arrange 4:11
`art 6:5 12:3,9,16
`13:14,17,19,24
`14:3,12 15:19
`16:12,18 17:16,17
`17:17,21
`articles 10:25 11:5
`11:11 14:6,7
`attorney 24:12,14
`Attorneys 2:4,10
`authentic 12:13
`authenticity 10:24
`available 23:3
`avenue 2:11 6:25
`18:16
`aware 10:17
`
`B
`
`B2 1:7
`back 19:13
`background 10:11
`10:17 13:23
`bag 9:24
`based 6:19 13:8
`14:4 21:22
`basically 9:24
`15:25
`behalf 3:15
`belatedly 9:20
`believe 4:16 7:12
`20:10,11,16 21:8
`22:2
`best 18:15
`beyond 9:4
`Bezos 2:11 3:20,21
`5:7 7:14 8:1,16
`9:8 14:21 17:2
`19:21 20:2 21:17
`22:10,23 23:7
`bit 10:11 13:25
`board 1:2 3:7 12:7
`12:25 13:18 15:8
`
`15:13 16:20 20:12
`21:21 22:15
`bottom 7:18
`bring 17:11 22:13
`bringing 16:7,8
`18:17
`brought 15:25
`17:15,24,25
`burden 17:8
`
`C
`
`C 2:1
`California 24:3
`call 3:9 19:5 21:23
`22:7,16 23:3
`case 1:6 13:5,12
`15:5,11,11,12,15
`15:20 16:6,22
`17:8
`certainly 22:15
`certification 24:1
`24:17
`certifications 11:16
`certified 11:10
`12:10,18 14:6
`24:2
`certify 24:4,11
`certifying 24:20
`cetera 11:6
`change 18:11
`Chicago 2:6
`Circuit 8:5 13:15
`15:5
`citation 7:17 8:5
`cited 6:21
`citing 8:25
`claim 13:17
`clear 8:23 12:6
`15:14,16
`clearly 9:18 17:20
`come 6:22,24
`comfortable 18:23
`19:7
`completely 5:24
`12:23 18:2
`confer 14:20 19:6
`conference 18:6
`
`22:7
`conferred 19:23
`confers 19:13
`Congress 11:13,20
`12:11 18:3
`CONNAUGHT 1:5
`connected 24:14
`connection 14:13
`considered 9:21
`contained 8:20
`control 24:20
`copies 11:5,10 14:6
`17:24
`copy 5:12 12:10,18
`correct 5:4 8:16
`counsel 3:11,18,22
`5:2 10:5 14:18
`15:3,9 18:11,12
`18:22 20:3,6
`21:18 22:1 23:1
`24:12,14
`couple 7:7 11:11
`12:19 14:22
`course 5:10
`court 3:25 4:2,5,12
`14:3
`covers 13:1
`CSR 24:24
`current 11:2
`
`D
`date 13:18 18:3,3,4
`18:6,6
`day 11:22 12:11
`24:23
`DC 2:12
`deadline 21:4 22:4
`22:5,17
`dealing 6:6 7:23
`16:2,10
`dealt 15:22 17:13
`decide 19:24 20:22
`22:8
`decided 18:12
`deciding 20:17
`decision 8:5 13:16
`13:19 15:9 21:2
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`declaration 13:21
`declarations 11:4
`demonstrate 14:2
`description 5:8
`determination
`21:11
`determine 21:12
`22:5
`determined 16:19
`different 5:24 11:6
`18:2
`direct 24:19
`directed 17:12
`direction 24:8,20
`disagree 12:23
`discuss 4:16 22:2
`22:20
`discussed 22:15
`discussion 22:3
`dispositive 12:14
`dispute 6:6
`document 18:7
`documents 18:4
`doing 21:5
`due 10:18
`
`E
`
`E 2:1,1
`earlier 6:5 13:17
`efficiency 22:11
`either 7:5 21:15
`Electronics 1:5,8
`3:23
`Ellis 2:4 3:15 10:9
`10:19
`employee 24:13
`entirely 17:24 18:1
`entirety 7:23
`entitled 16:24
`especially 19:3
`ESQ 2:5,11
`et 11:6
`evidence 6:8 8:21
`8:25 9:14,20,24
`11:5,8,9 12:1 13:3
`14:1,4,9 15:17
`16:17,25 17:6,10
`
`

`
`17:11,14 18:1
`20:24
`evidentiary 5:22
`19:3
`exclude 16:3
`excuse 11:17
`exhibit 7:18 8:6
`15:10
`exhibits 4:16,19,25
`5:10,14,17,19,25
`7:1,23 8:11,15
`10:13,23 11:24,25
`14:25 15:25 16:4
`16:7,9 17:19
`experience 13:22
`experts 13:22
`explaining 13:22
`expunged 6:14
`extension 8:23
`
`F
`facie 13:12 17:8
`fact 5:20 6:4 12:15
`13:14,24 15:19
`facts 4:18 5:4
`failing 6:23
`far 6:13
`feasible 4:12
`Federal 8:5 13:15
`15:4
`felt 18:23 19:6
`file 4:22 16:3 23:2
`filed 4:11,19 5:1,13
`10:18 18:24
`filing 4:24
`final 21:2
`financially 24:15
`first 5:3 6:7,9 8:2
`10:16 13:4 14:24
`Fitzpatrick 1:18
`3:8
`five 8:10
`focus 11:1
`follow 9:15
`following 15:14
`foregoing 24:5,9,17
`forth 13:11
`
`FOX 2:10
`frame 11:7
`front 7:10
`further 22:2 24:11
`
`G
`game 6:16 10:1
`16:10
`given 20:15
`GMBH 1:4,4
`go 6:2 18:18
`going 9:9
`GOLDSTEIN 2:10
`good 3:5,20 4:3
`Great 3:24 22:10
`23:5
`Guide 9:12,18
`
`H
`Handi 15:15
`happened 18:11
`Hari 2:5 3:14 10:8
`hari.santhanam...
`2:7
`hear 5:2 7:8 10:4
`14:18 21:9
`hearing 1:15 19:25
`20:21 21:4,6,9,13
`21:20 22:6,12,13
`heart 6:3 15:21
`held 19:2,9
`holding 9:25
`Hon 1:17,18,19 3:5
`3:17,24 4:4,9,13
`7:6,25 8:8 9:2
`10:4 14:17 16:14
`19:10,17,22 20:6
`20:14 21:24 22:19
`22:25 23:8
`Honor 3:14 4:3,8
`5:7 7:14 8:1,17
`9:8 10:8 14:21
`19:15,20,21 20:2
`20:8 21:17 22:11
`22:22,24
`Honors 3:21 10:17
`
`I
`ICR2014-00220
`6:20
`IEEE 13:23
`Illinois 2:6
`inadvertently 4:20
`inclined 20:13
`including 10:25
`11:5
`information 6:2 7:3
`9:16 10:15 12:5
`12:24 14:7 18:21
`informed 11:13
`initial 17:19 18:7
`initially 17:15
`instance 13:4
`instances 7:16 13:1
`institute 16:21
`instituted 10:21
`14:3
`institution 10:14,20
`13:10
`intend 19:25
`interested 24:15
`interestingly 18:9
`interpretation
`17:19
`introduce 7:1 17:9
`introducing 6:8
`invites 22:16
`involved 10:19 13:9
`IPR2014-00220
`15:11
`IPR2015-01410 1:6
`3:10
`IPRs 11:18
`issue 4:15 7:24 9:10
`9:19 15:4,7,17,18
`15:23 16:2,11,15
`18:13 19:3 20:21
`21:9,22,25 22:8
`22:14
`issues 8:19 17:12
`items 12:19
`ITR 10:19,21
`
`J
`
`J 1:17 3:5,17,24 4:4
`4:9,13 7:6,25 8:8
`9:2 10:4 14:17
`16:14 19:10,17,22
`20:6,14 21:24
`22:19,25 23:8
`Jeanese 1:24 24:2
`24:24
`Johnson 1:24 24:2
`24:24
`Judge 3:6,8,9
`July 21:5
`justify 17:16
`
`K
`Kessler 2:10 3:22
`kind 14:24 18:8,10
`Kirkland 2:4 3:15
`10:9,19
`know 5:12 9:9,17
`12:8,25 13:1 15:2
`15:14 17:18 18:12
`20:5 21:4
`knowledge 6:19
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