`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________________
`
`SAMSUNG ELECTRONICS CO., LTD,
`Samsung
`Petitioner
`v.
`ELBRUS INTERNATIONAL LIMITED,
`Elbrus
`Patent Owner
`___________________________________
`Case IPR2015-01524
`Patent 6,366,130
`___________________________________
`
`PATENT OWNER’S NOTICE OF APPEAL
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`To: Office of the General Counsel
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`NOTICE OF APPEAL
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`Notice is hereby given, pursuant to 37 C.F.R. § 90.2(a), that Patent Owner
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`Elbrus International, Ltd., (“Elbrus”) hereby appeals to the United States Court of
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`Appeals for the Federal Circuit from the Final Written Decision entered on January
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`17, 2017 (Paper 26), and from all orders, decisions, rulings, and opinions
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`underlying the Final Written Decision.
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`For the limited purpose of providing the Director with information requested
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`in 37 C.F.R. § 90.2(a)(3)(ii), Patent Owner anticipates that the issues on appeal
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`may include the following, as well as any underlying findings, determinations,
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`rulings, decisions, opinions, claim interpretations, or other related issues:
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`• Whether the Board erred in its construction of Claims 1, 2, 5-7 and 9 of the
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`subject ‘130 patent;
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`•
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` Whether the Board erred in finding that claims 1, 2, 5, 6, and 9 are
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`unpatentable under 35 U.S.C. § 103(a) as being obvious in view of U.S.
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`Patent No. 5,828,241 (“Sukegawa”) and Nicky Chau-Chun Lu & Hu H.
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`Chao, Half-V DD Bit-Line Sensing Scheme in CMOS DRAM’s, SC-19:4
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`IEEE JOURNALOF SOLID STATE CIRCUITS 451–454 (1984) (“Lu”);
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`•
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` Whether the Board erred in finding that claim 7 is unpatentable under 35
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`U.S.C. § 103(a) as being obvious in view of Sukegawa, Lu and U.S. Patent
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`No. 6,249,469 B1 (“Hardee”).
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`Copies of this Notice of Appeal are being filed simultaneously with the
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`Director of the United States Patent and Trademark Office, the Patent Trial and
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`Appeal Board, the Clerk’s Office for the United States Court of Appeals for the
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`Federal Circuit, and served on the Petitioner.
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`Dated March 16, 2017.
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`Respectfully Submitted,
`
`Clifford H. Kraft
`Reg. No. 35,229
`Lead Counsel for Patent Owner
`
`By: /Joseph Hosteny/
`Joseph N. Hosteny
`Reg. No. 28,020
`Back-up Counsel for Patent Owner
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` Counsel Patent Owner Elbrus
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` International Limited
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that the foregoing NOTICE OF APPEAL TO
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`THE FEDERAL CIRCUIT (35 U.S.C. § 141(c)) was filed on March 16, 2017 with
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`the United States Patent & Trademark Office, and served electronically in
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`accordance with the parties’ electronic service agreement on March 16, 2017 on
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`the following lead and backup counsels of record for Petitioner Samsung
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`Electronics Co., LTD. at the below-listed email addresses:
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`Naveen Modi (naveenmodi@paulhastings.com)
`Joseph Palys (josephpalys@paulhastings.com)
`Joseph Rumpler (josephrumpler@paulhastings.com)
`PAUL HASTINGS LLP
`
`
`
`Clifford H. Kraft
`Reg. No. 35,229
`Lead Counsel for Patent Owner
`
`By: /Joseph Hosteny/
`Joseph N. Hosteny
`Reg. No. 28,020
`Back-up Counsel for Patent Owner
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` Counsel Patent Owner Elbrus
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` International Limited
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`Date: March 16, 2017
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