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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________
`
`RPX CORPORATION,
`Petitioner,
`
`v.
`
`APPLICATIONS IN INTERNET TIME, LLC,
`Patent Owner.
`_____________
`
`Case IPR2015-01751
`Patent 7,356,482 B2
`
`_____________
`
`
`
`
`PETITIONER’S UPDATED LIST OF EXHIBITS FOR REPLY BRIEF
`AFTER REMAND
`
`
`
`
`
`
`
`
`
`
`
`Description
`
`1008
`
`1012
`
`Exhibit
`
`1001 U.S. Patent No. 7,356,482 (“the ‘482 Patent”)
`1002 Declaration of Mark E. Crovella, Ph.D.
`1003
`CV of Mark E. Crovella, Ph.D.
`1004 U.S. Patent No. 6,249,291 (“Popp”)
`1005 Kovacevic, S., “Flexible, Dynamic User Interfaces for Web-Delivered
`Training,” in Proceedings of the International Workshop on Advanced
`Visual Interfaces - AVI'96, 1996 (“Kovacevic”)
`1006 U.S. Patent No. 5,806,071 (“Balderrama”)
`1007
`“Java Complete!” DATAMATION, March 1, 1996, Vol. 42 No. 5, pp.
`28-49 (“Java Complete”)
`Codd, E. F., “Does your DBMS run by the rules?” ComputerWorld,
`October 21, 1985, pp. 49-60 (“Codd”)
`1009 U.S. Patent No. 5,710,900 (“Anand”)
`1010 Krasner, G. E. and Pope, S. T., “A Description of the Model-View-
`Controller User Interface Paradigm in the Smalltalk-80System”
`ParcPlace Systems, 1988 (“Krasner”)
`1011 Webster’s New World Dictionary of Computer Terms, 6th Edition
`(1997), p. 30 (definition of “application”), p. 274 (definition of “Java
`applet”)
`Barron’s Dictionary of Computer and Internet Terms, 6th Edition
`(1998), p. 22 (definition of “application,” “application program”), p.
`371 (definition of “program”)
`1013 U.S. Patent No. 6,341,287 (“the ‘287 patent”)
`1014 Notice of Allowance for the ‘482 patent
`1015
`Petitioner’s revised version of Patent Owner's Proposed Discovery
`Requests to Petitioner
`Petitioner’s redline version of Patent Owner's Proposed Discovery
`Requests to Petitioner
`Standing Protective Order
`1017
`1018 Merriam-Webster’s Collegiate Dictionary, 11th Edition (2012), p. 111
`(definition of “behest”)
`RPX000099 - RPX000233 (PROTECTIVE ORDER MATERIAL)
`RPX000014 - RPX000025 (PROTECTIVE ORDER MATERIAL)
`RPX000009 - RPX000011(PROTECTIVE ORDER MATERIAL)
`RPX000012 - RPX000013 (PROTECTIVE ORDER MATERIAL)
`
`1016
`
`1019
`1020
`1021
`1022
`
`1
`
`
`
`
`
`
`
`1023
`1024
`1025
`1026
`1027
`1028
`1029
`
`1030
`1031
`
`1032
`
`1033
`
`RPX000224 – RPX000271(PROTECTIVE ORDER MATERIAL)
`RPX000076 (PROTECTIVE ORDER MATERIAL)
`RPX000047 – RPX000067 (PROTECTIVE ORDER MATERIAL)
`Emails between K. Sarvaiya and R. Giunta, dated September 16, 2015
`Email from S. Sereboff, dated October 29, 2015
`Emails from E. Hunt, dated October 30, 2015
`Email From R. Giunta, dated November 29, 2015
`(PROTECTIVE ORDER MATERIAL)
`Email from S. Sereboff, dated November 27, 2015
`Email from R. Giunta, dated November 28, 2015
`(PROTECTIVE ORDER MATERIAL)
`Email from S. Sereboff, dated November 28, 2015
`(PROTECTIVE ORDER MATERIAL)
`Email from S. Sereboff, dated November 29, 2015
`(PROTECTIVE ORDER MATERIAL)
`Screenshot (PROTECTIVE ORDER MATERIAL)
`Email from S. Sereboff, dated November 30, 2015
`(PROTECTIVE ORDER MATERIAL)
`Email from S. Sereboff, dated December 1, 2015
`Screenshot (PROTECTIVE ORDER MATERIAL)
`Email from R. Giunta, dated December 1, 2015
`(PROTECTIVE ORDER MATERIAL)
`Email from K. Sarvaiya, dated December 2, 2015
`(PROTECTIVE ORDER MATERIAL)
`1040 Declaration of Nick Boebel (PROTECTIVE ORDER MATERIAL)
`1041 Declaration of Frank Knuettel (PROTECTIVE ORDER MATERIAL)
`1042
`Email from R. Giunta, dated December 15, 2015
`(PROTECTIVE ORDER MATERIAL)
`Email from J. Pearce, dated December 15, 2015
`(PROTECTIVE ORDER MATERIAL)
`1044 Web Biography of Nicholas S. Boebel
`1045 Web Biography of Frank Knuettel
`1046 Article (PROTECTIVE ORDER MATERIAL)
`1047
`Revised Protective Order
`1048
`Redline version of Revised Protective Order
`1049
`2014 NPE Litigation Report, at p. 30
`1050
`List of Fees Requested in Petitioner’s Motion for Attorneys’ Fees
`1051
`Partially Redacted Wolf Greenfield Invoice No. 16011003 (January 22,
`2016)
`
`1034
`1035
`
`1036
`1037
`1038
`
`1039
`
`1043
`
`2
`
`
`
`
`
`
`
`1052
`
`1056
`
`1057
`
`1058
`
`Partially Redacted Wolf Greenfield Invoice No. 16020633 (February
`24, 2016)
`List of Time/Fee Entries Incurred but NOT Requested
`1053
`1054 Merriam-Webster definition of “modification” ( http://www.merriam-
`webster.com/dictionary/modification ), marked as Exhibit 1054 at the
`deposition of Hosagrahar Jagadish, Ph.D., taken June 23, 2016
`1055 Merriam-Webster definition of “update” (http://www.merriam-
`webster.com/dictionary/update ), marked as Exhibit 1055 at the
`deposition of Hosagrahar Jagadish, Ph.D., taken June 23, 2016
`Comparison of ‘482 patent claim 1 with excerpt from Ex. 2032 ¶ 27,
`marked as Exhibit 1056 at the deposition of Hosagrahar Jagadish,
`Ph.D., taken June 23, 2016
`Comparison of ‘482 patent claim 1 with excerpt from Ex. 2032 ¶ 27,
`marked as Exhibit 1057 at the deposition of Hosagrahar Jagadish,
`Ph.D., taken June 23, 2016
`Transcript of deposition of Hosagrahar Jagadish, Ph.D., taken June 23,
`2016
`1059 AIT's Opening Claim Construction Brief, filed in Civil Action No.:
`3:13-CV-00628 (USDC, NV)
`1060 AIT's Reply Claim Construction Brief, filed in Civil Action No.: 3:13-
`CV-00628 (USDC, NV)
`1061 Declaration of Craig Rosenberg re Claim Construction, filed in Civil
`Action No.: 3:13-CV-00628 (USDC, NV)
`Reply Declaration of Mark E. Crovella, Ph.D.
`1062
`Petitioner’s Demonstrative Exhibits
`1063
`RESERVED – NOT USED
`1064
`Jeffrey M Lipshaw Curriculum vitae and List of Publications
`1065
`1066 Declaration of Jeffrey M Lipshaw
`1067
`2018 United States Spencer Stuart Board Index
`1068 Notice of 2018 Annual Meeting and 2018 Proxy Statement of
`salesforce.com
`1069 Notice of Annual Meeting and Proxy Statement of RPX Corporation,
`filed April 27, 2017
`Board of Directors | BloomEnergy,
`https://www.bloomenergy.com/company/board (retrieved January 4,
`2019)
`2002 Proxy Statement of Great Lakes Chemical Corporation,
`https://www.sec.gov/Archives/edgar/data/43362/000091205702012288
`/a2073489zdef14a.htm (retrieved January 4, 2019)
`
`1070
`
`1071
`
`3
`
`
`
`
`
`
`
`1072
`
`1073
`
`1074
`
`1075
`
`1076
`
`1077
`
`1078
`
`1079
`
`1080
`
`1081
`
`1082
`
`1083
`
`Confirmed: Cisco Did Invest in SpringPath, The Register (April 13,
`2016) (available at
`https://www.theregister.co.uk/2016/04/13/cisco_invested_in_springpath
`/) (last visited December 19, 2017)
`Second Declaration of William W. Chuang (CONFIDENTIAL –
`PROTECTIVE ORDER MATERIAL)
`RPX Form Membership Agreement (CONFIDENTIAL –
`PROTECTIVE ORDER MATERIAL)
`RPX Form Membership Agreement (CONFIDENTIAL –
`PROTECTIVE ORDER MATERIAL)
` Confidential Agreement (CONFIDENTIAL – PROTECTIVE ORDER
`MATERIAL)
`Third Amendment to Membership and License Agreement
`(CONFIDENTIAL – PROTECTIVE ORDER MATERIAL)
`Confidential Agreement (CONFIDENTIAL – PROTECTIVE ORDER
`MATERIAL)
`Confidential Agreement (CONFIDENTIAL – PROTECTIVE ORDER
`MATERIAL)
`Salesforce.com, Inc. Order Form (CONFIDENTIAL – PROTECTIVE
`ORDER MATERIAL)
`Payment records by Salesforce to RPX (CONFIDENTIAL –
`PROTECTIVE ORDER MATERIAL)
`Email from S. Sereboff, dated September 8, 2015, with names and e-
`mail addresses of RPX employees redacted
`Email from R. Giunta, dated September 9, 2015, with names and e-mail
`addresses of RPX employees redacted
`Email from S. Sereboff, dated October 28, 2015
`1084
`Email from R. Giunta, dated October 30, 2015
`1085
`Email from S. Sereboff, dated November 3, 2016
`1086
`Email from R. Giunta, dated November 4, 2016
`1087
`Email from S. Sereboff, dated February 9, 2018
`1088
`Email from M. Rader, dated February 9, 2018
`1089
`1090 Declaration of Steve W. Chiang (CONFIDENTIAL – PROTECTIVE
`ORDER MATERIAL)
`RPX notice of production of confidential information to Salesforce
`(CONFIDENTIAL – PROTECTIVE ORDER MATERIAL)
`E-mail thread responsive to RPX notice of production of confidential
`information to Salesforce (CONFIDENTIAL – PROTECTIVE ORDER
`MATERIAL)
`
`1091
`
`1092
`
`4
`
`
`
`
`
`
`
`
`
`1094
`
`1095
`
`1096
`
`1097
`
`1093 AIT’s Complaint for Patent Infringement, filed in Civil Action No.:
`3:13-CV-00628 (USDC, NV)
`Transcript of deposition of Steve W. Chiang, taken January 29, 2019
`(CONFIDENTIAL – PROTECTIVE ORDER MATERIAL)
`Transcript of deposition of William W. Chuang, taken January 30, 2019
`(CONFIDENTIAL – PROTECTIVE ORDER MATERIAL)
`Petitioner’s Responses to Patent Owner’s Requests for Production,
`served November 3, 2015 (CONFIDENTIAL – PROTECTIVE
`ORDER MATERIAL)
`Email from V. Weeks, dated December 7, 2015
`
`
`
`
`5
`
`
`
`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
`
`I certify that on April 5, 2019, I will cause a copy of the foregoing
`
`document and Exhibits 1096 and 1097, to be served via electronic mail, as
`
`previously consented to by Patent Owner, upon the following:
`
`Steven C. Sereboff
`Jonathan Pearce
`
`
`ssereboff@socalip.com
`jpearce@socalip.com
`uspto@socalip.com
`
`
`
`Date: April 5, 2019
`
`/MacAulay Rush/
`MacAulay Rush
`Paralegal
`WOLF, GREENFIELD & SACKS, P.C.
`
`6
`
`
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