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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`TOYOTA MOTOR CORPORATION
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`Petitioner
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`v.
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`BLITZSAFE TEXAS, LLC
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`Patent Owner
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`Patent No. 8,155,342
`Issued: Apr. 10, 2012
`Filed: Jun. 27, 2006
`
`Inventor: Ira Marlowe
`Title: MULTIMEDIA DEVICE INTEGRATION SYSTEM
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`
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`Inter Partes Review No.: IPR2016-00418
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`
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`PETITIONER’S REVISED MANDATORY NOTICES
`UNDER 37 CFR § 42.8(b)
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`1
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`
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`Honorable Board:
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`
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`In accordance with 37 CFR § 42.8(b), Petitioner Toyota Motor Corporation
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`submits the following revised Mandatory Notices, to update the Mandatory Notices
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`filed with the Petition (IPR2016-00418, Paper 1).
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`A. Real Party-In-Interest
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`As stated in the Petition, the Petitioner is Toyota Motor Corporation, and
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`additional Real Parties-in-Interest are: Toyota Motor Sales, U.S.A., Inc.; Toyota
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`Motor Manufacturing Texas, Inc.; Toyota Motor Manufacturing Kentucky, Inc.;
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`and Toyota Motor Manufacturing Mississippi, Inc.
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`B. Related Matters
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`As stated in the Petition, Petitioner states that the '342 patent is currently the
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`subject of the following on-going litigations: Blitzsafe Texas, LLC v. Nissan Motor
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`Co., Ltd. et al., 2-15-cv-01276, July 16, 2015 (E.D. TX); Blitzsafe Texas, LLC v.
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`Toyota Motor Corp. et al., 2-15-cv-01277, July 16, 2015 (E.D. TX); Blitzsafe
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`Texas, LLC v. Volkswagen Group of Am., Inc. et al., 2-15-cv-01278, July 16, 2015
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`(E.D. TX); Blitzsafe Texas, LLC v. Hyundai Motor Co. et al., 2-15-cv-01275, July
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`16, 2015 (E.D. TX); Blitzsafe Texas, LLC v. Honda Motor Co., Ltd. et al., 2-15-cv-
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`01274, July 16, 2015 (E.D. TX).
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`2
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`As stated in the Petition, U.S. Patent No. 7,489,786 ("the '786 patent"), a
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`parent patent to the '342 patent, was previously the subject of the following
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`litigations: Marlowe Patent Holdings LLC v. DICE Electronics, LLC et al., 3:10-
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`cv-01199 (D. NJ); and Marlowe Patent Holdings LLC v. Ford Motor Company,
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`3:10-cv-07044 (D. NJ). Both cases settled by June 2015.
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`Additionally, Petitioner has concurrently filed another Petition for Inter
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`Pares Review (IPR2016-00419) challenging the claims of the ‘342 patent on
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`grounds that are non-cumulative with those presented herein. In addition, a Petition
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`for Inter Partes Review of the '342 patent (IPR2016-00118) was filed on October
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`30, 2015 by Unified Patents Inc, challenging claims 1-25, 49, 73, 97, 120, and 121.
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`C.
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`Lead and Backup Counsel
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`As stated in the Petition, Lead Counsel for Petitioner is William H. Mandir,
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`Registration No. 32,156. Back-Counsel for Petitioner are John F. Rabena,
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`Registration No. 38,584; Yoshinari Kishimoto, Registration No. 47,327; Brian K.
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`Shelton, Registration No. 50,245; Fadi N. Kiblawi, Registration No. 61,973; and
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`Margaret M. Welsh, Registration No. 70,754.
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`3
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`D.
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`Service Information
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`Service of any documents via hand-delivery may be made at the postal
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`mailing addresses listed below. Petitioner also consents to electronic service by
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`email at toyota@sughrue.com.
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`SUGHRUE MION PLLC
`c/o William Mandir
`2100 Pennsylvania Ave NW
`Suite 800
`Washington, DC 20037
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`Respectfully submitted,
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`/William H. Mandir/
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`William H. Mandir
`Registration No. 32,156
`Sughrue Mion, PLLC
`Telephone: (202) 293-7060
`Facsimile: (202) 293-7860
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`WASHINGTON OFFICE
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`23373
`CUSTOMER NUMBER
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`Date: DECEMBER 31, 2015
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`4
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the attached PETITIONER’S
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`REVISED MANDATORY NOTICES UNDER 37 C.F.R. § 42.8(b) in Case
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`IPR2016-00418 and this Certificate of Service are being served on December 31,
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`2015 overnight via Federal Express upon the following:
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`Ira M. Marlowe
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`BLITZSAFE OF AMERICA, INC.
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`33 Honeck Street
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`Englewood, NJ 07631
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` A
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` courtesy copy of the attached PETITIONER’S REVISED MANDATORY
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`NOTICES UNDER 37 C.F.R. § 42.8(b) has also been sent via e-mail to:
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`Peter Lambrianakos
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`Brown Rudnick LLP
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`Seven Times Square
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`New York, NY 10036
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`plambrianakos@brownrudnick.com
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`_/Soo Jin Hur/___
`
` Soo Jin Hur
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