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UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`
`MICRON TECHNOLOGY, INC.
`Petitioner
`
`v.
`
`LIMESTONE MEMORY SYSTEMS LLC
`Patent Owner
`____________________
`
`Case No. IPR 2016-00096
`
`U.S. Patent 6,233,181
`Filed February 17, 1999
`Issued May 15, 2001
`Title: SEMICONDUCTOR MEMORY DEVICE WITH IMPROVED
`FLEXIBLE REDUNDANCY SCHEME
`____________________
`
`Customer No: 22242
`____________________
`
`
`LIMESTONE MEMORY SYSTEMS LLC’S MANDATORY
`NOTICES PURSUANT TO 37 C.F.R. §42.8(a)(2)
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`
`
`
`
`
`
`

`
`Case IPR 2016-00096 for
`U.S. Patent No. 6,233,181
`
`Patent Owner Limestone Memory Systems LLC (“Limestone”) hereby files
`
`its Mandatory Notices pursuant to 37 C.F.R. §42.8(a)(2) for the above-captioned
`
`proceeding.
`
`I.
`
`Real Parties-In-Interest Under 37 C.F.R. §42.8(b)(1)
`
`The real parties-in-interest are Limestone Memory Systems LLC and Acacia
`
`Research Group LLC.
`
`II. Related Matters Under 37 C.F.R. §42.8(b)(2)
`
`Patent Owner notes the following matters that may affect or be affected by a
`
`decision in this proceeding:
`
`A. Related Administrative Matters
`
`The following patents claim priority to U.S. Patent No. 6,233,181 (“the ‘181
`
`patent”):
`
`Application No.
`09/798,944
`10/229,001
`10/387,573
`
`
`Filing Date
`Mar. 6, 2001
`Aug. 28, 2002
`Mar. 14, 2003
`
`Patent No.
`U.S. Patent No. 6,449,199
`U.S. Patent No. 6,545,931
`U.S. Patent No. 6,678,195
`
`The ‘181 patent does not claim priority from another U.S. patent or patent
`
`application. There are no pending U.S. patent applications related to the ‘181
`
`patent.
`
`
`
`1
`
`

`
`Case IPR 2016-00096 for
`U.S. Patent No. 6,233,181
`
`Petitioner Micron has filed five concurrent IPR petitions against patents
`
`owned by Limestone. The patents at issue in each of these concurrent proceedings
`
`are unrelated except by their common assignment to Limestone and by having
`
`been asserted in lawsuits involving Limestone and Petitioner. In addition to the
`
`current matter, these matters include the following case numbers and patents:
`
`Case No.
`IPR 2016-00093
`IPR 2016-00094
`IPR 2016-00095
`IPR 2016-00096
`IPR 2016-00097
`
`
`Patent No.
`U.S. Patent No. 5,805,504 (“the ‘504 patent”)
`U.S. Patent No. 5,894,441 (“the ‘441 patent”)
`U.S. Patent No. 5,943,260 (“the ‘260 patent”)
`U.S. Patent No. 6,233,181 (“the ‘181 patent”)
`U.S. Patent No. 6,697,296 (“the ‘296 patent”)
`
`B. Related Judicial Matters
`
`The patent at issue in the current matter, U.S. Patent 6,233,181 (“the ‘181
`
`patent”), is asserted in the following pending lawsuits:
`
` Limestone Memory Systems LLC v. Micron Technology, Inc., No. 8:15-CV-
`
`00278 (filed February 17, 2015 C.D. Cal.) (asserts the ‘504, ‘441, ‘260,
`
`‘181, and ‘296 patents);
`
` Limestone Memory Systems LLC v. Dell, Inc., No. 8:15-CV-00648 (filed
`
`April 23, 2015 C.D. Cal.) (asserts the ‘504, ‘441, ‘260, ‘181, and ‘296
`
`patents);
`
`
`
`2
`
`

`
` Limestone Memory Systems LLC v. Lenovo United States Inc., No. 8:15-CV-
`
`Case IPR 2016-00096 for
`U.S. Patent No. 6,233,181
`
`
`00650 (filed April 23, 2015 C.D. Cal.) (asserts the ‘504, ‘441, ‘260, ‘181,
`
`and ‘296 patents);
`
` Limestone Memory Systems LLC v. Hewlett-Packard Company, No. 8:15-
`
`CV-00652 (filed April 23, 2015 C.D. Cal.) (asserts the ‘504, ‘441, ‘260,
`
`‘181, and ‘296 patents);
`
` Limestone Memory Systems LLC v. Acer America Corporation, No. 8:15-
`
`CV-00653 (filed April 23, 2015 C.D. Cal.) (asserts the ‘504, ‘441, ‘260,
`
`‘181, and ‘296 patents);
`
` Limestone Memory Systems LLC v. Kingston Technology Co., Inc., No.
`
`8:15-CV-00654 (filed April 23, 2015 C.D. Cal.) (asserts the ‘504, ‘441,
`
`‘260, ‘181, and ‘296 patents);
`
` Limestone Memory Systems LLC v. OCZ Storage Solutions, Inc., No. 8:15-
`
`CV-00658 (filed April 23, 2015 C.D. Cal.) (asserts the ‘504, ‘441, ‘181, and
`
`‘296 patents); and
`
` Limestone Memory Systems LLC v. Apple, Inc., No. 8:15-CV-01274 (filed
`
`August 10, 2015 C.D. Cal.) (asserts the ‘504, ‘441, ‘181, and ‘296 patents).
`
`The Patent Owner has filed additional lawsuits, which assert some of the
`
`same patents that are subject of the five concurrent IPR petitions filed by the
`
`Petitioner (listed above). These lawsuits are unrelated to the current matter except
`
`3
`
`

`
`Case IPR 2016-00096 for
`U.S. Patent No. 6,233,181
`
`to the extent they involve Limestone and certain accused products in the cases are
`
`manufactured by the Petitioner. The ‘181 patent is not asserted in these additional
`
`lawsuits:
`
` Limestone Memory Systems LLC v. PNY Technologies, Inc., No. 8:15-CV-
`
`00656 (filed April 23, 2015 C.D. Cal.) (asserts the ‘260 patent); and
`
` Limestone Memory Systems LLC v. Transcend
`
`Information,
`
`Inc.
`
`(California), No. 8:15-CV-00657 (filed April 23, 2015 C.D. Cal.) (asserts
`
`the ‘260 patent).
`
`III. Lead and Back-Up Counsel Under 37 C.F.R. §42.8(b)(3)
`
`Patent Owner identifies lead and back-up counsel as follows:
`
`A.
`
`Lead Counsel
`
`Nicholas T. Peters
`PTO Registration No. 53,456
`FITCH EVEN TABIN & FLANNERY LLP
`120 South LaSalle Street, Suite 1600
`Chicago, Illinois 60603
`Telephone: (312) 577-7000
`Facsimile: (312) 577-7007
`Email: LimestoneIPR@fitcheven.com
`
`B.
`
`Back-Up Counsel
`
`Paul B. Henkelmann
`PTO Registration No. 65,891
`FITCH EVEN TABIN & FLANNERY LLP
`120 South LaSalle Street, Suite 1600
`Chicago, Illinois 60603
`Telephone: (312) 577-7000
`
`
`
`4
`
`

`
`Case IPR 2016-00096 for
`U.S. Patent No. 6,233,181
`
`
`Facsimile: (312) 577-7007
`Email: LimestoneIPR@fitcheven.com
`
`
`
`IV. Service Information Under 37 C.F.R. §42.8(b)(4)
`
`Please address all correspondence to the lead and back-up counsel as shown
`
`above. Patent Owner consents to electronic service by email at the email addresses
`
`Respectfully submitted,
`FITCH EVEN TABIN & FLANNERY LLP
`By: /Nicholas T. Peters/
`
`Nicholas T. Peters
`Registration No. 53,456
`ntpete@fitcheven.com
`
`above.
`
`
`
`
`Dated: November 17, 2015
`
`
`
`120 South LaSalle Street
`Suite 1600
`Chicago, Illinois 60603
`(312) 577-7000
`(312) 577-7007 (fax)
`
`
`
`5
`
`

`
`Case IPR 2016-00096 for
`U.S. Patent No. 6,233,181
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies
`
`that
`
`the foregoing LIMESTONE
`
`MEMORY SYSTEMS LLC’S MANDATORY NOTICES PURSUANT TO
`
`37 C.F.R. §42.8(a)(2) was served electronically via email on November 17, 2015,
`
`in their entireties on the following counsel of record for Petitioner:
`
`Justin L. Constant
`Reg. No. 66,883
`Weil, Gotshal & Manges LLP
`700 Louisiana, Suite 1700
`Houston, TX 77002
`Justin.constant@weil.com
`(713) 546-5217
`
`Respectfully submitted,
`FITCH EVEN TABIN & FLANNERY LLP
` /Nicholas T. Peters/
`
`Nicholas T. Peters
`Registration No. 53,456
`ntpete@fitcheven.com
`Lead Counsel for Patent Owner
`
`Jeremy J. Lang
`Reg. No. 73,604
`Weil, Gotshal & Manges LLP
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065
`jason.lang@weil.com
`(650) 802-3237
`
`
`
`
`Dated: November 17, 2015 By:
`
`
`
`
`120 South LaSalle Street
`Suite 1600
`Chicago, Illinois 60603
`(312) 577-7000
`(312) 577-7007 (fax)
`
`
`
`6

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