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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`v.
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`POLYGROUP LIMITED (MCO),
`Petitioner,
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`WILLIS ELECTRIC CO., LTD.,
`Patent Owner.
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`PATENT OWNER’S MANDATORY NOTICES
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`UNDER 37 C.F.R. § 42.8
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`Inter Partes Review No. IPR2016-00802
`Patent No. 9,044,056
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`The Patent Owner, Willis Electric Co., Ltd., hereby provides the following mandatory
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`notices:
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`1.
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`Real Party in Interest (§ 42.8(b)(1))
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`The real party of interest is WILLIS ELECTRIC CO., LTD., located at 8F, No. 310, Sec.
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`4, Zhongxiao E. Road, Da’an Dist., Taipei City 106, Taiwan; WEBER ELECTRIC CO., LTD.,
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`located at 8F, No. 310, Sec. 4, Zhongxiao E. Road, Da’an Dist., Taipei City 106, Taiwan;
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`WILLPOINT INTERNATIONAL INC., located at 2nd Floor, Building B, SNPF Plaza, Savalalo,
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`Apia, Samoa; WILLIS ELECTRIC CO., LTD., located at 25 Guzman Street Belama Phase 1
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`Belize City, Belize, C.A.; YUCENT GROUP LIMITED, located at Unit 1405, 14/F, Lippo Sun
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`Plaza, 28 Canton Road, Tsim Sha Tsui, Hong Kong; KUGIN DEVELOPMENT LIMITED,
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`located at Unit 1405, 14/F, Lippo Sun Plaza, 28 Canton Road, Tsim Sha Tsui, Kowloon, Hong
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`Kong; KUPOINT (DONG GUAN) ELECTRIC CO., LTD., located at Huaide Industrial Area,
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`Humen Town, Dong Guan, Guang Dong Province, China; DONGGUAN KUPOINT LIGHTING
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`& WIRE CO., LTD., located at Jichi Village, Hu-Men, Dong Guan, Guang Dong, China.
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`2.
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`Related Matters (§ 42.8(b)(2))
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`Patent Owner originally filed suit alleging infringement of the ’056 Patent and three similar
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`patents: Willis Elec. Co. v. Polygroup Ltd., No. 0:15-cv-03443- DWF-SER (D. Minn. filed Aug.
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`28, 2015). On December 22, 2015, Patent Owner filed an amended complaint, alleging
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`infringement of two additional patents. Petitioner has filed IPR Petitions against three of the
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`asserted patents (USPN 8,454,186 (IPR2016-00800); USPN 8,454,187 (IPR2016-00801), and
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`USPN 9,044,056 (instant matter) and has represented that it will file Petitions against the
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`remaining asserted patents (USPNs 8,936,379; 9,066,617; 8,974,072). In addition, IPR Petitions
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`were previously filed against the ’186 and ’187 Patents (IPR2014-01263 and -01264) in the name
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`2
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`of Polygroup Ltd. An anonymous party previously filed Ex Parte Reexaminations (90/020,073 and
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`-074) against the ’186 and ’187 Patents, respectively. The ’187 and ’072 Patents and pending U.S.
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`Patent Application No. 14/512,021 claim priority to the ’186 Patent. Petitioner has filed suit against
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`Patent Owner based upon references in the same field of art: Polygroup Macau Ltd (BVI) v. Willis
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`Electric Co., Ltd., No. 3:15-cv-00552 (W.D.N.C.).
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`3.
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`Designation of Lead and Backup Counsel (§ 42.8(b)(3))
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`Lead Counsel
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`Larina A. Alton
`Reg. No. 72,750
`Christensen Fonder P.A.
`33 South Sixth Street
`Suite 3950
`Minneapolis, MN 55402
`alton@cfpatlaw.com
`phone: (612) 315-4116
`fax: (612) 315-4321
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`Backup Counsel
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`Douglas J. Christensen
`Reg. No. 35,480
`Christensen Fonder P.A.
`33 South Sixth Street
`Suite 3950
`Minneapolis, MN 55402
`christensen@cfpatlaw.com
`phone: (612) 315-4102
`fax: (612) 315-4321
`Timothy E. Bianchi
`Reg. No. 39,610
`Schwegman Lundberg & Woessner, P.A.
`1600 TCF Tower
`121 South Eight Street
`Minneapolis, MN 55402
`tbianchi@slwip.com
`phone: (612) 373-6912
`fax: (612) 339-3061
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`4.
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`Service Information
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`Service on Patent Owner may be made by electronic mail to Christensen Fonder P.A. at
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`the email addresses above. Alternatively, service may be made by mail or hand delivery to:
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`Christensen Fonder P.A., 33 South Sixth Street, Suite 3950, Minneapolis, Minnesota 55402. The
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`fax numbers for lead and backup counsel are shown above.
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`Respectfully Submitted,
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`s/Larina Alton
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`Larina Alton, No. 72,750
`Attorney for Willis Electric Co., Ltd.
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`Christensen Fonder P.A.
`33 South Sixth Street
`Suite 3950
`Minneapolis, MN 55402
`alton@cfpatlaw.com
`phone: (612) 315-4116
`fax: (612) 315-4321
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`4
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`Date: May 10, 2016
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`CERTIFICATE OF SERVICE
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` I
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` hereby certify, pursuant to 37 CFR § 42.6, that on May 10, 2016, the same day as the
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`filing of the above document, a true and correct copy of the foregoing Mandatory Notices for
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`IPR2016-00802 is being served via e-mail as authorized by the Petitioner in the Petition at the
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`following e-mail addresses:
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`paul.mcgowan@troutmansanders.com
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`ryan.schneider@troutmansanders.com
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`benjamin.wiles@troutmansanders.com
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`jasone-ptab@skgf.com
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`s/Larina Alton
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`Larina Alton, No. 72,750
`Attorney for Willis Electric Co., Ltd.
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`Christensen Fonder P.A.
`33 South Sixth Street
`Suite 3950
`Minneapolis, MN 55402
`alton@cfpatlaw.com
`phone: (612) 315-4116
`fax: (612) 315-4321
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