Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 1 of 19 PageID #: 3251
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`DELAWARE DISPLAY GROUP LLC
`and INNOVATIVE DISPLAY
`TECHNOLOGIES LLC,
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`Plaintiffs,
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`Defendants.
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` C.A. No. 13-2108-RGA
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` JURY TRIAL DEMANDED
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` C.A. No. 13-2109-RGA
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` JURY TRIAL DEMANDED
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` C.A. No. 13-2112-RGA
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` JURY TRIAL DEMANDED
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`v.
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`LENOVO HOLDING CO. INC., and
`LENOVO (UNITED STATES) INC.,
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`DELAWARE DISPLAY GROUP LLC
`and INNOVATIVE DISPLAY
`TECHNOLOGIES LLC,
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`Plaintiffs,
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`v.
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`LG ELECTRONICS, INC.,
`LG ELECTRONICS U.S.A., INC.,
`LG DISPLAY CO., LTD., and
`LG DISPLAY AMERICA, INC.,
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`Defendants.
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`DELAWARE DISPLAY GROUP LLC
`AND INNOVATIVE DISPLAY
`TECHNOLOGIES LLC,
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`VIZIO, INC., et al.
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`v.
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`Plaintiffs,
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`Defendant.
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`IDT_000001
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`

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`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 2 of 19 PageID #: 3252
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`JOINT STATUS REPORT ON IPR PETITIONS
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`As required by the Court’s Oral Order of May 12, 2015,1 the parties submit the following
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`report on the status of petitions for inter partes review that were identified in Defendants’ Joint
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`Opening Brief in Support of Motion to Stay Pending Inter Partes Review (Dkt. 45). In addition,
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`the parties attach a summary chart as Exhibit A.
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`A. Defendants’ Summary:
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`On April 3, 2015 the Defendants jointly moved for a stay pending the outcome of inter
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`partes review of all Asserted Patents pursuant to requests by LG Display Co., Ltd. (“LGD”),
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`Sony Corp. (“Sony”), and other parties. After Defendants moved to stay the case, Plaintiffs
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`dropped the ’547 and ’194 patents from the case, both patents of which were subject to IPR.
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`Subsequently, Plaintiffs requested adverse judgment in the Patent Office with respect to those
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`two IPRs. Also after Defendants moved to stay the case, two additional IPRs were instituted for
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`the ’660 and ’973 patents. Thus, of the seven remaining patents in the case, all except the ’196
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`patent are currently subject to either instituted IPRs or pending requests for IPRs (as outlined in
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`detail below in Defendants’ Section). Final decisions for the four currently instituted IPRs (the
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`’177, ’660, ’370, and ’973 patents) will be rendered on March 2, 2016, July 16, 2016, January
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`13, 2016, and July 6, 2016, respectively. Moreover, institution decisions on the remaining
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`patents will be rendered by March 11, 2016.
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`1 Dkt. 54 in Case No. 13-cv-2108. All docket numbers referenced in this submission will refer to
`Case No. 13.cv-2108.
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`2
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`IDT_000002
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`

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`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 3 of 19 PageID #: 3253
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`B. Plaintiffs’ Summary:
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`Of the 46 requests for Inter Partes Review, 8 of the petitions were denied institution on
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`all claims, and 2 were granted only on claims not in suit. Another 25 of the IPR petitions were
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`terminated prior to any institution decision because the parties who filed them all obtained
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`licenses to the patents-in-suit. There were 2 other IPRs related only to patents no longer asserted
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`in the case, and the related IPRs were terminated and are not pertinent to the motion. Only 4
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`petitions, covering 3 patents-in-suit, have been instituted on any claims in suit. The earliest that
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`decisions will issue on any claims actually in this case is March, mid-June and July 2016.
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`Recently, LGE and a supplier to LGD filed 5 new petitions, but none of those IPRs have been
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`instituted, and the earliest that a final written decision would issue in any of those IPRs (if
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`instituted) would not be until approximately March of 2017. There is no pending IPR relating to
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`the ’196 patent.
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`The parties each set forth additional details regarding the procedural history and present
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`status below.
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`C. Defendants’ Detailed Position:
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`1. U.S. Patent No. 6,755,547: IPR Instituted, But Patent Dismissed from Litigation
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`LG Display Co., Ltd. (“LGD”) filed a petition to institute an inter partes review of claims
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`1-4, 16, and 26 of U.S. Patent No. 6,755,547 (“the ’547 patent”) on August 21, 2014. The Patent
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`Trial and Appeal Board (“the Board”) granted the petition and instituted an inter partes review
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`of all challenged claims on February 26, 2015. The patent owner moved for adverse judgment
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`and the Board granted its request on June 10, 2015 in the inter partes review. Plaintiffs dismissed
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`the ’547 patent from the litigation on April 28, 2015.
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`3
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`IDT_000003
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`

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`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 4 of 19 PageID #: 3254
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`2. U.S. Patent No. 7,300,194: IPR Instituted, But Patent Dismissed from Litigation;
`Other Petitions Terminated by Settlement
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`LGD filed a petition to institute an inter partes review of claims 1-4, 16, 22, 23, 27, 28,
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`and 31 of U.S. Patent No. 7,300,194 (“the ’194 patent”) on July 1, 2014. The Board granted the
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`petition and instituted an inter partes review of all challenged claims on January 13, 2015. The
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`patent owner moved for adverse judgment and the Board granted its request on September 15,
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`2015 in the inter partes review. Plaintiffs dismissed the ’194 patent from this litigation on April
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`28, 2015.
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`Separately, on December 4, 2014, Mercedes Benz USA, LLC and Mercedes-Benz U.S.
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`International, Inc. (collectively “Mercedes-Benz”) filed a petition requesting an inter partes
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`review of claims 1, 4-6, 16, 22, 23, 27, 28, and 31 of the ’194 patent and filed a motion for
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`joinder seeking to join that proceeding with the inter partes review filed by LGD. On May 22,
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`2015, the Board instituted an inter partes review of all the challenged claims and granted the
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`motion for joinder. On July 2, 2015, this inter partes review was terminated as a result of a
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`settlement agreement reached between the patent owner and Mercedes-Benz.
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`3. U.S. Patent No. 7,384,177: Two Petitions Instituted; Five Petitions Terminated by
`Settlement
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`LGD filed a petition to institute an inter partes review of claims 1-3, 5-7, 9, 10, 13-15,
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`19, 21 and 23-27 of U.S. Patent No. 7,384,177 (“the ’177 patent”) on August 22, 2014. The
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`Board instituted an inter partes review of all challenged claims on March 2, 2015.
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`Separately, on December 29, 2014, LG Electronics, Inc. (“LGE”) filed a petition
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`requesting an inter partes review of claims 1-3, 5-7, 9, 10, 13-15, 19, 21 and 23-27 of the ’177
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`patent and filed a motion for joinder seeking to join that proceeding with the inter partes review
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`filed by LGD. On July 13, 2015, the Board instituted an inter partes review of all the challenged
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`claims and granted the motion for joinder.
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`4
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`IDT_000004
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`

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`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 5 of 19 PageID #: 3255
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`Oral argument for the LGD and LGE inter partes reviews is scheduled for November 20,
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`2015. A final written decision is expected by March 2, 2016.
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`Mercedes-Benz filed a petition to institute an inter partes review of claims 1-3, 5-7, 9-10,
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`13-15, 19, 21 and 23-27 of the ’177 patent on December 4, 2014. On April 13, 2015, Mercedes-
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`Benz filed another petition to institute an inter partes review of claims 1, 6-7, 9-10, 13-15, 19,
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`and 22 of the ’177 patent. On July 2, 2015, both of these inter partes reviews were terminated as
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`a result of a settlement agreement reached between the patent owner and Mercedes-Benz.
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`On March 5, 2015, Toyota Motor Corporation (“Toyota”) filed a petition to institute an
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`inter partes review of claims 1, 6-7, 9-10, 13-15, 19, and 22 of the ’177 patent. On March 9,
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`2015, Toyota filed an additional petition to institute an inter partes review of claims 1, 6-7, 9-10,
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`13-15, 19, and 22 of the ’177 patent. On May 29, 2015, both of these inter partes reviews were
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`terminated as a result of a settlement agreement reached between the patent owner and Toyota.
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`On February 18, 2015, Sony filed a petition to institute an inter partes review of claims
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`1-3, 5-7, 9-10, 13-15, 19, 21 and 23-27 of the ’177 patent. On August 12, 2015, this inter partes
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`review was terminated as a result of a settlement agreement reached between the patent owner
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`and the Sony defendants in this litigation.
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`4. U.S. Patent No. 7,404,660: One Petition Instituted; One Petition Currently Pending;
`Two Petitions Denied; Five Petitions Terminated by Settlement
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`LGD filed a petition to institute an inter partes review of claims 1, 3, 5, 10, 13, 16, 17,
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`25–29, and 33–35 on December 23, 2014. The Board instituted review of claims 1, 3, 5, 10, 13,
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`16, 17, 25–29, and 33–35 of the ’660 patent on July 16, 2015. Oral argument for the inter partes
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`review is scheduled for March 16, 2016 and a final decision is expected by July 16, 2016.
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`5
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`IDT_000005
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`

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`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 6 of 19 PageID #: 3256
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`LGE filed a petition to institute an inter partes review of claims 1, 3, 5, 10, 13, 16, 17,
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`25, 26, 27, 28, 29, 33, 34, and 35 of the ’660 patent on August 13, 2015. This petition is
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`currently pending before the Board.
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`LGD filed a petition to institute an inter partes review of claims 1, 3, 10, 16, 17, 25, 33,
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`and 34 of U.S. Patent No. 7,404,660 (“the ’660 patent”) on July 1, 2014. The Board declined to
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`institute an inter partes review of the challenged claims on January 13, 2015.
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`Separately, LGE filed a petition requesting an inter partes review of claims 1-3, 5-7, 9,
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`10, 13-15, 19, 21 and 23-27 of the ’660 patent and filed a motion for joinder seeking to join that
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`proceeding with the inter partes review filed by LGD on December 29, 2014. On July 13, 2015,
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`the Board denied the petition and declined to institute an inter partes review of the challenged
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`claims.
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`Mercedes-Benz filed a petition to institute an inter partes review of claims 1, 3, 10, 16,
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`17, 25, 33, and 34 of the ’660 patent on December 4, 2014. Mercedes-Benz filed a second
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`petition to institute an inter partes review of claims 1, 3, 10, 16, 17, 25, 33, and 34 of the ’660
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`patent on April 24, 2015. On July 2, 2015, both of these inter partes reviews were terminated as
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`a result of a settlement agreement reached between the patent owner and Mercedes-Benz.
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`Toyota filed a petition to institute an inter partes review of claims 1, 3, 10, 16-17, 25, 33,
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`and 34 of the ’660 patent on March 10, 2015. Toyota filed a second petition to institute an inter
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`partes review of claims 1, 3, 10, 16-17, 25, 33, and 34 of the ’660 patent on March 19, 2015. On
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`May 29, 2015, both of these inter partes reviews were terminated as a result of a settlement
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`agreement reached between the patent owner and Toyota.
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`Sony filed a petition to institute an inter partes review of claims 1-3, 5, 10, 12, 13, 16, 17,
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`25, 28-30, and 33-35 of the ’660 patent on February 17, 2015. On August 12, 2015, this inter
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`6
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`IDT_000006
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`

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`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 7 of 19 PageID #: 3257
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`partes review was terminated as a result of a settlement agreement reached between the patent
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`owner and the Sony defendants in this litigation.
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`5. U.S. Patent No. 7,434,974: One Petition Currently Pending; Two Petitions Denied;
`Four Petitions Terminated by Settlement
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`KJ Pretech Co., Ltd. (“KJ Pretech”) filed a petition to institute an inter partes review of
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`claims 1, 3–5, 7–8, and 10-11 of the ’974 patent on September 11, 2015. This petition is
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`currently pending before the Board.
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`LGD filed a petition to institute an inter partes review of claims 1, 3–5, 7–11, 13, and 17
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`of U.S. Patent No. 7,434,974 (“the ’974 patent”) on July 1, 2014. The Board declined to institute
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`an inter partes review of the challenged claims on January 13, 2015.
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`Separately, on December 29, 2014, LGE filed a petition requesting an inter partes review
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`of claims 1, 3–5, 7– 11, 13, and 17 of the ’974 patent and filed a motion for joinder seeking to
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`join that proceeding with the inter partes review filed by LGD. On July 15, 2015, the Board
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`denied the petition and declined to institute an inter partes review of the challenged claims.
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`Mercedes-Benz filed a petition to institute an inter partes review of claims 1, 3–5, 7–11,
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`13, and 17 of the ’660 patent on December 4, 2014. On July 2, 2015, this inter partes review was
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`terminated as a result of a settlement agreement reached between the patent owner and
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`Mercedes-Benz.
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`Sony filed a petition to institute an inter partes review of claims 1, 3–5, 7–11, 13, and 17
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`of the ’660 patent on February 18, 2015. On August 12, 2015, this inter partes review was
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`terminated as a result of a settlement agreement reached between the patent owner and the Sony
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`defendants in this litigation.
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`Toyota filed a petition to institute an inter partes review of claims 1, 3–5, 7–9, and 13 of
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`the ’660 patent on March 5, 2015. Toyota filed a second petition to institute an inter partes
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`7
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`IDT_000007
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`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 8 of 19 PageID #: 3258
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`review of claims 1, 3–5, 7–9, and 13 of the ’660 patent on March 6, 2015. On May 29, 2015,
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`both of these inter partes reviews were terminated as a result of a settlement agreement reached
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`between the patent owner and Toyota.
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`6. U.S. Patent No. 7,537,370: Two Petitions Instituted; One Petition Currently
`Pending; One Petition Terminated by Settlement
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`LGD filed a petition to institute an inter partes review of claims 1, 4, 8, 13, 15, 27, 29,
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`and 47 of U.S. Patent No. 7,537,370 (“the ’370 patent”) on July 1, 2014. The Board instituted an
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`inter partes review of claims 15 and 27 on January 13, 2015.
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`KJ Pretech filed a petition to institute an inter partes review of claims 1, 4-6, 9, 13, 29,
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`and 47 of the ’370 patent on September 11, 2015. This petition is currently pending before the
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`Board.
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`On December 29, 2014, LGE filed a petition requesting an inter partes review of claims
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`1, 4, 8, 13, 15, 27, 29, and 47 of the ’370 patent and filed a motion for joinder seeking to join that
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`proceeding with the inter partes review filed by LGD. On July 15, 2015, the Board instituted an
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`inter partes review of claims 15 and 27, and granted the motion for joinder. The oral argument
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`on the LGD and LGE inter partes reviews took place on September 21, 2015. A final written
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`decision is expected by January 13, 2016.
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`Sony filed a petition to institute an inter partes review of claims 1, 3-6, 8, 9, 11-13, 15,
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`27, 29, and 47 of the ’370 patent on February 17, 2015. On August 12, 2015, this inter partes
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`review was terminated as a result of a settlement agreement reached between the patent owner
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`and the Sony defendants in this litigation.
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`7. U.S. Patent No. 8,215,816: One Petition Currently Pending; Two Petitions Denied;
`Four Petitions Terminated by Settlement
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`KJ Pretech filed a petition to institute an inter partes review of claims 1, 3, and 4 of the
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`’816 patent on September 11, 2015. This petition is currently pending before the Board.
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`8
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`IDT_000008
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`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 9 of 19 PageID #: 3259
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`LGD filed a petition to institute an inter partes review of claims 1-4 of U.S. Patent No.
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`8,215,816 (“the ’816 patent”) on July 1, 2014. The Board declined to institute an inter partes
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`review of the challenged claims on January 13, 2015.
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`Separately, on December 29, 2014, LGE filed a petition requesting an inter partes review
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`of claims 1-4 of the ’816 patent and filed a motion for joinder seeking to join that proceeding
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`with the inter partes review filed by LGD. On July 20, 2015, the Board declined to institute an
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`inter partes review of the challenged claims.
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`Mercedes-Benz filed a petition requesting inter partes review of claims 1-4 of the ’816
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`patent on December 4, 2014. Mercedes-Benz filed a second petition requesting inter partes
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`review of claims 1, 3, and 4 of the ’816 patent on April 25, 2015. On July 2, 2015, both of these
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`inter partes reviews were terminated as a result of a settlement agreement reached between the
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`patent owner and Mercedes-Benz.
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`Toyota filed a petition requesting inter partes review of claims 1 and 3-4 of the ’816
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`patent on March 4, 2015. On May 29, 2015, this inter partes review was terminated as a result of
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`a settlement agreement reached between the patent owner and Toyota.
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`Sony filed a petition requesting an inter partes review of claims 1-4 of the ’816 patent on
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`February 17, 2015. On August 12, 2015, this inter partes review was terminated as a result of a
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`settlement agreement reached between the patent owner and the Sony defendants in this
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`litigation.
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`8. U.S. Patent No. 7,434,973: One Petition Instituted; One Petition Currently Pending
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`LGD filed a petition to institute an inter partes review of claims 1-5 of U.S. Patent No.
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`7,434,973 (“the ’973 patent”) on December 30, 2014. The Board instituted an inter partes
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`review of all challenged claims on July 6, 2015. Oral argument for the LGD inter partes review
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`is scheduled for March 1, 2016 and a final decision is expected by July 6, 2016.
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`9
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`IDT_000009
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`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 10 of 19 PageID #: 3260
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`Separately, LGE filed a petition requesting inter partes review of claims 1-5 of the ’973
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`patent on August 5, 2015. This petition is currently pending before the Board.
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`9. U.S. Patent No. 7,914,196: Two Petitions Denied; One Petition Terminated by
`Settlement
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`LGD filed a petition to institute an inter partes review of claims 1-25 of U.S. Patent No.
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`7,914,196 (“the ’196 patent”) on August 21, 2014. The Patent Trial and Appeal Board declined
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`to institute an inter partes review of the challenged claims on January 13, 2015.
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`Separately, on December 29, 2014, LGE filed a petition requesting an inter partes review
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`of claims 1-25 of the ’196 patent and filed a motion for joinder seeking to join that proceeding
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`with the inter partes review filed by LGD. On July 13, 2015, the Board declined to institute an
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`inter partes review of the challenged claims.
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`Sony filed a petition requesting an inter partes review of claims 1-25 of the ’196 patent
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`on February 18, 2015. On August 12, 2015, this inter partes review was terminated as a result of
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`a settlement agreement reached between the patent owner and the Sony defendants in this
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`litigation.
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`D. Plaintiffs’ Detailed Position:
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`1. Dismissed Patents (2)
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`Two patents, U.S. 6,755,547 and U.S. 7,300,194, were dismissed from the litigation, and
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`are no longer pertinent to the motion to stay.
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`2. Petitions Terminated Prior to Any Institution Decision (25)
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`Mercedes Benz USA, LLC and Mercedes-Benz U.S. International, Inc. (collectively
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`“Mercedes”) filed a total of ten (10) petitions requesting institution of inter partes reviews of
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`some, but not all, of the patents in suit. Similarly, Toyota Motor Corporation (“Toyota”) filed a
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`total of eight (8) petitions requesting institution of an inter partes on some, but not all, of the
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`10
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`IDT_000010
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`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 11 of 19 PageID #: 3261
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`patents in suit. And Sony Corp. (“Sony”) filed a total of seven (7) petitions requesting institution
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`of inter partes reviews of some, but not all, of the patents in suit. After Mercedes, Toyota, and
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`Sony obtained licenses to the patents in suit, each of those proceedings were terminated by joint
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`motion. All twenty five (25) of these petitions were dismissed by the Patent Trial and Appeal
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`Board (“PTAB” or the “Board”) prior to any decision on institution.
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`3. Petitions Where Institution Was Denied On All Claims (8)
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`LG Display Co., Ltd. (“LGD”) filed a petition to institute an inter partes review of claims
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`1, 3, 10, 16, 17, 25, 33, and 34 of U.S. Patent No. 7,404,660 B2 (“the ’660 patent”) on July 1,
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`2014. Separately, on December 29, 2014, LG Electronics, Inc. (“LGE”) filed a petition
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`requesting an inter partes review of claims 1-3, 5-7, 9, 10, 13-15, 19, 21 and 23-27 of the ’660
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`patent. The PTAB declined to institute LGD’s request for inter partes review of the challenged
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`claims on January 13, 2015. On July 13, 2015, the PTAB declined to institute LGE’s request for
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`inter partes review of all challenged claims.
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`LGD filed a petition to institute an inter partes review of claims 1, 3–5, 7–11, 13, and 17
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`of U.S. Patent No. 7,434,974 (“the ’974 patent”) on July 1, 2014. The PTAB declined to
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`institute LGD’s inter partes review of the challenged claims on January 13, 2015. Separately, on
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`December 29, 2014, LGE filed a petition requesting an inter partes review of the same claims of
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`the ’974 patent. On July 15, 2015, the PTAB denied LGE’s petition and declined to institute an
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`inter partes review of any of the challenged claims.
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`LGD filed a petition to institute an inter partes review of claims 1-4 of U.S. Patent No.
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`8,215,816 (“the ’816 patent”) on July 1, 2014. The PTAB declined to institute an inter partes
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`review of the challenged claims on January 13, 2015. Separately, on December 29, 2014, LGE
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`11
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`IDT_000011
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`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 12 of 19 PageID #: 3262
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`filed a petition requesting an inter partes review of claims 1-4 of the ’816 patent. On July 20,
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`2015, the Board denied LGE’s petition for inter partes review as to all challenged claims.
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`LGD filed a petition to institute an inter partes review of claims 1-25 of U.S. Patent No.
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`7,914,196 (“the ’196 patent”) on August 21, 2014. The PTAB declined to institute an inter
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`partes review of the challenged claims on January 13, 2015. Separately, on December 29, 2014,
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`LGE filed a petition requesting an inter partes review of claims 1-25 of the ’196 patent. On July
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`13, 2015, the Board denied LGE’s petition for inter partes review as to all challenged claims.
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`4. Petitions Where Institution Was Granted Only On Claims Not in Suit (2)
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`LGD filed a petition to institute an inter partes review of claims 1, 4, 8, 13, 15, 27, 29,
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`and 47 of U.S. Patent No. 7,537,370 (“the ’370 patent”) on July 1, 2014. On December 29,
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`2014, LGE filed a petition requesting an inter partes review of claims 1, 4, 8, 13, 15, 27, 29, and
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`47 of the ’370 patent and moved to join that proceeding with the inter partes review filed by
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`LGD. On July 15, 2015, the PTAB denied to institute review of claims 1, 4, 8, 13, 29, and 47,
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`but instituted an inter partes review of claims 15 and 27 only, and granted the motion for joinder.
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`Oral argument on these two IPRs took place on September 21, 2015. A final written decision is
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`expected by January 13, 2016. Neither of the two claims on which review was instituted (claims
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`15 and 27) have ever been asserted in this litigation.
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`5. Petitions With No Institution Decision (5)
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`LGE filed a petition requesting inter partes review of claims 1-5 of U.S. Patent No.
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`7,434,973 (“the ’973 patent”) on August 5, 2015. Patent Owner’s Preliminary Response is due
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`on November 14, 2015, a decision on institution would not be expected until February 14, 2016,
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`and a final written decision would not be expected until February 14, 2017. LGE also filed a
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`petition to institute an inter partes review of claims 1, 3, 5, 10, 13, 16, 17, 25, 26, 27, 28, 29, 33,
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`12
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`IDT_000012
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`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 13 of 19 PageID #: 3263
`
`34, and 35 of the ’660 patent on August 13, 2015. Patent Owner’s Preliminary Response is not
`
`due until November 21, 2015, a decision on institution would not be expected until February 21,
`
`2016, and if an IPR is instituted a final written decision would not be expected until February 21,
`
`2017. On September 11, 2015, a Korean-based supplier to LGD, KJ Pretech Co., Ltd. (“KJ
`
`Pretech”) filed petitions to institute inter partes review of claims 1, 3–5, 7–8, and 10-11 of the
`
`’660 patent, claims 1, 4-6, 9, 13, 29, and 47 of the ’370 patent, and claims 1, 3, and 4 of the ’816
`
`patent. These petitions are currently pending before the PTAB. Patent Owner’s Preliminary
`
`Responses are not due until December 22, 2015, a decision on institution would not be expected
`
`until March 22, 2016, and, if an IPR review on these petitions were instituted, a final written
`
`decision would not be expected until approximately March 22, 2017.
`
`6. Petitions Where Review Was Instituted (4)
`
`LGD filed a petition to institute an inter partes review of claims 1-3, 5-7, 9, 10, 13-15,
`
`19, 21 and 23-27 of U.S. Patent No. 7,384,177 (“the ’177 patent”) on August 22, 2014. The
`
`PTAB instituted an inter partes review of all challenged claims on March 2, 2015. LGE filed a
`
`similar petition requesting an inter partes review of the same claims of the ’177 patent and
`
`moved to join that proceeding with the inter partes review filed by LGD. On July 13, 2015, the
`
`Board instituted an inter partes review of all challenged claims and granted joinder. Oral
`
`argument for the LGD and LGE inter partes reviews is scheduled for November 20, 2015. A
`
`final written decision is expected by March 2, 2016.
`
`LGD filed a petition to institute an inter partes review of claims 1-5 of the ’973 patent on
`
`December 30, 2014. The PTAB instituted an inter partes review of all challenged claims on July
`
`6, 2015. Oral argument for the LGD inter partes review is scheduled for March 1, 2016. A final
`
`written decision is expected by July 6, 2016.
`
`13
`
`IDT_000013
`
`

`
`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 14 of 19 PageID #: 3264
`
`LGD filed a petition to institute an inter partes review of claims 1, 3, 5, 10, 13, 16, 17,
`
`25–29, and 33–35 of the ’660 patent on December 23, 2014. The PTAB instituted review of the
`
`challenged claims on July 16, 2015. Oral argument for the inter partes review is scheduled for
`
`March 16, 2016. A final written decision is expected by July 16, 2016.
`
`14
`
`IDT_000014
`
`

`
`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 15 of 19 PageID #: 3265
`
`
`
`
`
`Respectfully submitted,
`
`
`
`ROSS ARONSTAM & MORITZ LLP
`
` /s/ Benjamin J. Schladweiler
`David E. Ross (#5228)
`Benjamin J. Schladweiler (#4601)
`100 S. West Street, Suite 400
`Wilmington, DE 19801
`(302) 576-1600
`dross@ramllp.com
`bschladweiler@ramllp.com
`
`Counsel for Defendants LG Electronics, Inc.,
`LG Electronics U.S.A., Inc., LG Display Co.,
`Ltd., and LG Display America, Inc.
`
`
`
`YOUNG CONAWAY STARGATT & TAYLOR, LLP
`
` /s/ Pilar G. Kraman
`Adam W. Poff (#3990)
`Pilar G. Kraman (#5199)
`1000 North King Street
`Rodney Square
`Wilmington, DE 19801
`(302) 571-5600
`apoff@ycst.com
`pkraman@ycst.com
`
`Counsel for Defendant VIZIO, Inc.
`
`15
`
`
`
`FARNAN LLP
`
` /s/ Brian E. Farnan
`Joseph J. Farnan, Jr. (#100245)
`Brian E. Farnan (#4089)
`Michael J. Farnan (#5165)
`919 North Market Street, 12th Floor
`Wilmington, DE 19801
`(302) 777-0300
`farnan@farnanlaw.com
`bfarnan@farnanlaw.com
`mfarnan@farnanlaw.com
`
`Counsel for Plaintiffs Delaware Display
`Group LLC and Innovative Display
`Technologies LLC.
`
`POTTER ANDERSON & CORROON LLP
`
` /s/ Stephanie E. O’Byrne
`Richard L. Horwitz (#2246)
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Stephanie E. O’Byrne (#4446)
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`(302) 984-6000
`rhorwitz@potteranderson.com
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`sobyrne@potteranderson.com
`
`Counsel for Defendants Lenovo Holding Co.
`Inc. and Lenovo (United States) Inc.
`
`
`
`Dated: October 12, 2015
`
`IDT_000015
`
`

`
`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 16 of 19 PageID #: 3266
`
`
`Exhibit A
`
`Asserted
`IPR
`Patent-
`Proceeding
`at-issue
`
`IPR2014-1096 7,537,370 LG Display
`
`Petitioner
`
`IPR2014-1097 7,300,194 LG Display
`
`Instituted on
`some non-
`asserted claims
`Instituted
`
`Status on
`4/6/2015
`
`Status on
`10/9/2015
`
`Final Written
`Decision by
`January 13, 2016
`Judgment and Final
`Written Decision
`entered on 9/15/15
`Judgment and Final
`Written Decision
`entered on 6/10/15
`Final Written
`Decision by March
`2, 2016
`Instituted
`
`Instituted
`
`Instituted and
`joined with
`IPR2014-01362 on
`7/13/15; Final
`Written Decision
`by March 2, 2016
`Judgment and Final
`Written Decision
`entered on 9/15/15
`
`Institution denied
`on 7/13/15
`
`Instituted and
`joined to IPR2015-
`01096 on
`7/15/2015; Final
`Written Decision
`by January 13,
`2016
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`IPR2014-1357 6,755,547 LG Display
`
`Instituted
`
`IPR2014-1362 7,384,177 LG Display
`
`Instituted
`
`7,404,660 LG Display
`
`7,434,973 LG Display
`
`Pending—
`institution
`decision expected
`by 7/20/15
`Pending—
`institution
`decision expected
`by 7/22/15
`7,384,177 LG Electronics Pending—
`institution
`decision expected
`by 7/20/15
`
`7,300,194 LG Electronics Pending—
`institution
`decision expected
`by 7/20/15
`7,914,196 LG Electronics Pending—
`institution
`decision expected
`by 7/20/15
`7,537,370 LG Electronics Pending—
`institution
`decision expected
`by 7/20/15
`
`IPR2015-487
`
`6
`
`IPR2015-506
`
`7
`
`IPR2015-489
`
`8
`
`IPR2015-490
`
`9
`
`IPR2015-492
`
`10
`
`IPR2015-493
`
`
`
`IDT_000016
`
`

`
`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 17 of 19 PageID #: 3267
`
`
`
`11
`
`IPR
`Proceeding
`
`IPR2015-495
`
`12
`
`IPR2015-496
`
`13
`
`IPR2015-497
`
`14
`
`IPR2015-755
`
`15
`
`IPR2015-752
`
`16
`
`IPR2015-745
`
`17
`
`IPR2015-753
`
`18
`
`IPR2015-757
`
`19
`
`IPR2015-749
`
`20
`
`IPR2015-756
`
`Status on
`10/9/2015
`
`Institution denied
`on 7/20/15
`
`Institution denied
`on 7/20/215
`
`Institution denied
`on 7/15/15
`
`Proceedings
`Terminated by Joint
`Motion on 8/12/15
`
`Proceedings
`Terminated by Joint
`Motion on 8/12/15
`
`Proceedings
`Terminated by Joint
`Motion on 8/12/15
`
`Proceedings
`Terminated by Joint
`Motion on 8/12/15
`
`Proceedings
`Terminated by Joint
`Motion on 8/12/15
`
`Proceedings
`Terminated by Joint
`Motion on 8/12/15
`
`Proceedings
`Terminated by Joint
`Motion on 8/12/15
`
`Petitioner
`
`Status on
`4/6/2015
`
`7,434,974 Sony
`
`8,215,816 Sony
`
`7,404,660 Sony
`
`7,537,370 Sony
`
`7,914,196 Sony
`
`Asserted
`Patent-
`at-issue
`7,537,370 LG Electronics Pending—
`institution
`decision expected
`by 8/5/15
`8,215,816 LG Electronics Pending—
`institution
`decision expected
`by 7/22/15
`7,434,974 LG Electronics Pending—
`institution
`decision expected
`by 7/22/15
`Pending—
`institution
`decision expected
`by 8/27/15
`Pending—
`institution
`decision expected
`by 8/27/15
`Pending—
`institution
`decision expected
`by 8/27/15
`Pending—
`institution
`decision expected
`by 8/27/15
`Pending—
`institution
`decision expected
`by 8/27/15
`Pending—
`institution
`decision expected
`by 8/27/15
`Pending—
`institution
`decision expected
`by 8/27/15
`
`7,300,194 Sony
`
`7,384,177 Sony
`
`2
`
`IDT_000017
`
`

`
`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 18 of 19 PageID #: 3268
`
`
`
`21
`
`IPR
`Proceeding
`
`IPR2015-831
`
`Petitioner
`
`Asserted
`Patent-
`at-issue
`7,434,974 Toyota
`
`22
`
`IPR2015-832
`
`7,434,974 Toyota
`
`23
`
`IPR2015-834
`
`8,215,816 Toyota
`
`24
`
`IPR2015-835
`
`7,384,177 Toyota
`
`25
`
`IPR2015-843
`
`7,300,194 Toyota
`
`26
`
`IPR2015-855
`
`7,404,660 Toyota
`
`27
`
`IPR2015-857
`
`7,384,177 Toyota
`
`28
`
`IPR2015-897
`
`7,404,660 Toyota
`
`29
`
`IPR2015-359
`
`7,384,177 Mercedes-
`Benz
`
`30
`
`IPR2015-360
`
`7,300,194 Mercedes-
`Benz
`
`Status on
`4/6/2015
`
`Status on
`10/9/2015
`
`Pending—
`institution
`decision expected
`by 9/13/15
`Pending—
`institution
`decision expected
`by 9/13/15
`Pending—
`institution
`decision expected
`by 9/13/15
`Pending—
`institution
`decision expected
`by 9/13/15
`Pending—
`institution
`decision expected
`by 9/20/15
`Pending—
`institution
`decision expected
`by 9/20/15
`Pending—
`institution
`decision expected
`by 9/20/15
`Pending—
`institution
`decision expected
`by 9/20/15
`Pending—
`institution
`decision expected
`by 5/4/15
`Pending—
`institution
`decision expected
`by 5/4/15
`
`Proceedings
`Terminated by Joint
`Motion on 5/29/15
`
`Proceedings
`Terminated by Joint
`Motion on 5/29/15
`
`Proceedings
`Terminated by Joint
`Motion on 5/29/15
`
`Proceedings
`Terminated by Joint
`Motion on 5/29/15
`
`Proceedings
`Terminated by Joint
`Motion on 5/29/15
`
`Proceedings
`Terminated by Joint
`Motion on 5/29/15
`
`Proceedings
`Terminated by Joint
`Motion on 5/29/15
`
`Proceedings
`Terminated by Joint
`Motion on 5/29/15
`
`Proceedings
`Terminated by Joint
`Motion on 7/2/15
`
`Proceedings
`Terminated by Joint
`Motion on 7/2/15
`
`3
`
`IDT_000018
`
`

`
`Case 1:13-cv-02108-RGA Document 81 Filed 10/12/15 Page 19 of 19 Pa