`Inter Partes Review
`Attorney Docket No. LMBTH 7.1O-001
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________________________________________
`
`TDK CORPORATION
`Petitioner
`
`v.
`
`LAMBETH MAGNETIC STRUCTURES LLC
`Patent Owner
`
`_______________________________________________
`
`INTER PARTES REVIEW OF U.S. PATENT NO. 7,128,988
`Inter Partes Review No. 2016-00013
`
`
`
`
`
`PATENT OWNER MANDATORY NOTICES
`PURSUANT TO 37 C.F.R. § 42.8
`
`
`
`4296361_1.docx
`
`Mail Stop: Patent Board
`Patent Trial and Appeal Board
`U.S. Patent And Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`U.S. Patent No. 7,128,988
`Atty. Docket No. LMBTH 7.1O-001
`
`I. MANDATORY NOTICES
`Lambeth Magnetic Structures, LLC, the Patent Owner, provides the
`
`following mandatory notices pursuant to 37 C.F.R. §42.8.
`
`A. Real Party-In- Interest Under 37 C.F.R. § 42.8(b)(1)
`Lambeth Magnetic Structures, LLC (“Lambeth”), the assignee of record for
`
`U.S. Patent 7,128,988 (“the ‘988 Patent”), is the real party-in-interest.
`
`B. Related Matters Under 37 C.F.R. § 42.8(b)(2)
`Lambeth has sued Toshiba Corporation, Toshiba America Information
`
`Systems, Inc., Toshiba America Electronic Components, Inc. and Toshiba of
`
`Canada, Ltd. (collectively “Toshiba”) for infringement of claims 1, 3, 6, 8, 11, 12,
`
`17, 19, 23, 27, 28 and 29 of the ‘988 Patent in the United States District Court for
`
`the Western District of Pennsylvania. See Lambeth Magnetic Structures, LLC v.
`
`Toshiba Corp., Civil Action No. 2:14-cv-01526-CB (W.D. Pa.)(“Pennsylvania
`
`Action”). On October 9, 2015, Headway Technologies, Inc. (“Headway”), a
`
`supplier to Toshiba of products accused of infringement in the Pennsylvania
`
`Action, filed an action seeking a declaration of non-infringement of the ‘988 Patent
`
`for components included in the accused products in the Pennsylvania Action in the
`
`United States District Court for the Central District of California. See Headway
`
`Technologies, Inc. v. Lambeth Magnetic Structures, LLC, Civil Action No. 2:15-
`
`4296361_1.docx
`
`2
`
`
`
`U.S. Patent No. 7,128,988
`Atty. Docket No. LMBTH 7.1O-001
`
`cv-07987-DSF (C.D. Ca.). On October 12, 2015, Lambeth filed a motion seeking
`
`
`
`leave to amend its complaint in the Pennsylvania Action to add TDK Corporation,
`
`TDK U.S.A. Corporation (“TDK USA”), TDK Corporation of America, Headway,
`
`Husko, Inc. (“Husko”), and SAE Magnetics (H.K.) Ltd. (“SAE”) as defendants in
`
`the Pennsylvania Action. SAE, Husko and Headway are direct or indirect wholly
`
`owned subsidiaries of TDK Corporation.
`
`C. Lead And Backup Counsel Under 37 C.F.R. § 42.8(b)(3)
`Backup Lead Counsel:
`Lead Counsel:
`Orville R. Cockings
`Dr. Gregory J. Gonsalves
`(Reg. No. 42,424)
`(Reg. No. 43,639)
`gonsalves@gonsalveslawfirm.com
`ocockings@lernerdavid.com
`
`
`Postal and Hand-Delivery Address
`Postal and Hand-Delivery Address
`600 South Avenue West
`2216 Beacon Lane
`Westfield, NJ 07090
`Falls Church, Virginia 22043
`Telephone: (571) 419-7252
`Telephone: (908) 518-6397
`Fax: (908) 654-7866
`
`D. Service Information Under 37 C.F.R. § 42.8(b)(4)
`Please address all correspondence to the lead and backup counsel at the
`
`address shown above. Petitioner also consents to electronic service by e-mail at:
`
`litigation@lernerdavid.com, ocockings@lernerdavid.com, asolo@lernerdavid.com.
`
`4296361_1.docx
`
`3
`
`
`
`U.S. Patent No. 7,128,988
`Atty. Docket No. LMBTH 7.1O-001
`
`II.
`
`
`
`POWER OF ATTORNEY
`A power of attorney accompanies this mandatory notice disclosure.
`
`Dated: November 19, 2015
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`Electronic signature:
`/Orville R. Cockings/
`Orville R. Cockings
`Registration No.: 42,424
`Counsel for Patent Owner
`LERNER, DAVID, LITTENBERG,
`KRUMHOLZ & MENTLIK, LLP
`600 South Avenue West
`Westfield, New Jersey 07090
`(908) 654-5000
`
`4296361_1.docx
`
`4
`
`
`
`U.S. Patent No. 7,128,988
`Atty. Docket No. LMBTH 7.1O-001
`
`
`
`
`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a copy of the foregoing PATENT
`
`
`
`OWNER MANDATORY NOTICES PURSUANT TO 37 C.F.R. § 42.8,
`
`including the Patent Owner’s Power of Attorney, was served in its entirety on
`
`November 19, 2015, by emailing a copy to the attorneys of record for the
`
`Petitioner TDK Corporation at the below email addresses:
`
`Lead Counsel:
`Hector Gallegos
`(Reg. No. 40,614)
`
`hgallegos@mofo.com
`MORRISON & FOERSTER, LLP
`200 Pennsylvania Avenue, NW
`Suite 6000
`Washington, D.C. 20006-1888
`Telephone: (202) 887-6920
`Fax: (202) 887-0763
`
`
`
`
`4296361_1.docx
`
`Backup Counsel:
`Jonathan Bockman
`(Reg. No. 45,640)
`
`jbockman@mofo.com
`MORRISON & FOERSTER, LLP
`1650 Tysons Boulevard
`Suite 400
`McLean, VA 22102-4220
`Telephone: (703) 760-7769
`Fax: (703) 760-7777
`
`
`
`
`
`By: /Orville R. Cockings/
`Orville R. Cockings
`Registration No. 42,424
`Counsel for Petitioner
`LERNER, DAVID, LITTENBERG,
`KRUMHOLZ & MENTLIK, LLP
`600 South Avenue West
`Westfield, New Jersey 07090
`(908) 654-5000
`
`
`5
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