`By: Andriy Lytvyn (andriy.lytvyn@smithhopen.com)
`Anton J. Hopen (anton.hopen@smithhopen.com)
`Nicholas Pfeifer (nicholas.pfeifer@smithhopen.com)
`Smith & Hopen, P.A.
`180 Pine Avenue North
`Oldsmar, Florida 34677
`Tel: (813) 925-8505
`Fax: (800) 726-1491
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`SK HYNIX INC., SK HYNIX AMERICA INC.,
`SK HYNIX MEMORY SOLUTIONS INC., and
`HYNIX SEMICONDUCTOR MANUFACTURING AMERICA INC.,
`Petitioner,
`
`v.
`
`DSS TECHNOLOGY MANAGEMENT, INC.
`Patent Owner.
`
`____________
`
`Case IPR2016-00192
`U.S. Patent No. 6,784,552
`
`
`
`____________
`
`MANDATORY NOTICES OF THE PATENT OWNER
`UNDER 37 C.F.R. § 42.8
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`Case IPR2016-00192
`U.S. Patent No. 6,784,552
`Attorney Docket No: 2952.14
`
`Pursuant to 37 C.F.R. § 42.8, Patent Owner, DSS Technology Management,
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`
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`
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`Inc., submits the following Mandatory Notices in response to the Petition for inter
`
`partes review of U.S. Patent No. 6,784,552.
`
`1. Real Party-In-Interest
`
`In accordance with 37 C.F.R. § 42.8(b)(1), the real parties-in-interest are
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`DSS Technology Management, Inc., which is a wholly-owned subsidiary of
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`Document Security Systems, Inc.
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`DSS Technology Management, Inc.
`1818 Library Street, Suite 500
`Reston, VA 20190
`
`Document Security Systems, Inc.
`28 Main Street East, Suite 1525
`Rochester, NY 14614
`
`2. Related Matters
`
`In accordance with 37 C.F.R. § 42.8(b)(2), Patent Owner identifies the
`
`following related proceedings: DSS Tech. Mgmt., Inc. v. SK Hynix, Inc., et al.,
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`Case No. 6:15-cv-691 in the U.S. District Court for the Eastern District of Texas,
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`filed on July 16, 2015, currently pending; DSS Tech. Mgmt., Inc. v. Samsung Elec.
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`Co., Ltd. et al., Case No. 6:15-cv-690 in the U.S. District Court for the Eastern
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`District of Texas, filed on July 16, 2015, currently pending; DSS Tech. Mgmt., Inc.
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`v. Qualcomm, Inc., Case No. 6:15-cv-692 in the U.S. District Court for the Eastern
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`Page 2 of 5
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`Case IPR2016-00192
`U.S. Patent No. 6,784,552
`Attorney Docket No: 2952.14
`
`
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`District of Texas, filed on July 16, 2015, currently pending; and DSS Tech. Mgmt.,
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`Inc. v. Intel, Corp. et al., Case No. 6:15-cv-130 in the U.S. District Court for the
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`Eastern District of Texas, filed on February 16, 2015, currently pending.
`
`3. Lead and Back-Up Counsel
`
`In accordance with 37 C.F.R. § 42.8(b)(3), Patent Owner identifies Andriy
`
`Lytvyn as lead counsel and Anton J. Hopen and Nicholas Pfeifer as back-up
`
`counsel:
`
`Lead Counsel
`
`Andriy Lytvyn, Reg. No. 65,166
`SMITH & HOPEN, P.A.
`180 Pine Avenue North
`Oldsmar, FL 34677
`Tel: 813-925-8505
`Fax: 800-726-1491
`Email: andriy.lytvyn@smithhopen.com
`
` Back-Up Counsel Anton J. Hopen, Reg. No. 41,849
`
`
`
`
`SMITH & HOPEN, P.A.
`180 Pine Avenue North
`Oldsmar, FL 34677
`Tel: 813-925-8505
`Fax: 800-726-1491
`Email: anton.hopen@smithhopen.com
`
` Back-Up Counsel Nicholas Pfeifer, Reg. No. 70,568
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`
`
`
`SMITH & HOPEN, P.A.
`180 Pine Avenue North
`Oldsmar, FL 34677
`Tel: 813-925-8505
`Fax: 800-726-1491
`Email: nicholas.pfeifer@smithhopen.com
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`Page 3 of 5
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`Case IPR2016-00192
`U.S. Patent No. 6,784,552
`Attorney Docket No: 2952.14
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`4. Service Information
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`
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`Patent Owner consents to electronic service by email. In accordance with 37
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`C.F.R. § 42.8(b)(4), Patent Owner requests that all correspondence be addressed to
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`the lead and back-up counsel at all email addresses shown above.
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`Date: December 3, 2015
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`Respectfully submitted,
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`
`
`/andriy lytvyn/
`Andriy Lytvyn (Reg. No. 65,166)
`Anton J. Hopen (Reg. No. 41,849)
`Nicholas Pfeifer (Reg. No. 70,568)
`Attorneys for Patent Owner
`
`
`SMITH & HOPEN, P.A.
`180 Pine Avenue North
`Oldsmar, FL 34677
`(813) 925-8505
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`
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`Page 4 of 5
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`Case IPR2016-00192
`U.S. Patent No. 6,784,552
`Attorney Docket No: 2952.14
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`CERTIFICATE OF SERVICE
`
`
`
`
`
`The undersigned hereby certifies that, in accordance with 37 C.F.R. §
`
`42.6(e), the above Mandatory Notices of the Patent Owner and a copy of the Power
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`of Attorney were served via electronic mail on December 3, 2015, in their entirety
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`upon the following:
`
`Heath J. Briggs, Lead Counsel for Petitioner
`HynixGTIPR@gtlaw.com
`
`Patrick J. McCarthy, Back-Up Counsel for Petitioner
`HynixGTIPR@gtlaw.com
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`
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`
`/andriy lytvyn/
`Andriy Lytvyn
`Lead Counsel for Patent Owner
`Registration No. 65,166
`
`SMITH & HOPEN, P.A.
`180 Pine Avenue North
`Oldsmar, FL 34677
`(813) 925-8505
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`Page 5 of 5
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`Date: December 3, 2015
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