`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`APPLE INC.
`
`Petitioner,
`
`V.
`
`PAPST LICENSING GMBH & CO. KG
`
`Patent Owner
`
`Case IPR2016—01839
`
`Patent 6,4703 99
`
`
`PETITIONER APPLE INC.’S
`
`RESPONSIVE ITEMIZED LISTING
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`US. Patent and Trademark Office
`
`PO. Box 1450
`
`Alexandria, VA 22313-1450
`
`
`
`1. Responsive to: POR, 22:13—23:15 (“It is illogical in the context of the ’399
`
`Patent to interpret the claim language for ‘it is an input/output device’ to mean ‘it is
`
`one or more input or output devices’ as well as inconsistent with the district court’s
`
`claim construction in the underlying district court case”); Gafford, “111154—55;
`
`Supported by: Petition, 928—1 0 (“the terms are to be given their plain and ordinary
`
`meaning”).
`
`2. Responsive to: POR, 13:1 1—16; 15:8——19; (“Kawaguchi’s teaching of separate
`
`reading and writing units having different IDs is critical to his invention”); 27:20——
`
`28:13 (“each data writing unit or reading unit... has its own device ID”); Supported
`
`[3}: Petition 43:2—4.
`
`3. Responsive to: POR, 24:6—12; 27:20—28: 13 (“SCSI inquiry and responses are
`
`made at a given device ID. [The] data reading unit... has its own device ID”);
`
`20:12—14 (“Kawaguchi’s device could only, at best, signal to the host device that
`
`any of its IDs is a hard disk device, but one that can only be read or written”);
`
`Gafford, 111151—53, 74 (“not mandatory for a SCSI target... to respond with inquiry
`
`data”); Supported by: Petition, 43:2-44:4 (“[Kawaguchi’s] data transfer
`
`enables. . .writ[ing] or read[ing] data to each writing unit or from each reading unit
`
`using the same method as that for four hard disks”); Zadok, ‘1190 (“INQUIRY
`
`command “[r1eturns LUN specific information”); 1198 (“INQUIRY command ‘can
`
`be used to learn... the device type’”).
`
`
`
`4. Same as 3, and also Supported by; Petition, 33: 12—3426 and figure on p. 34;
`
`Zadok, 1166 (“Schmidt provides the details of this identification (citing Schmidt
`
`Table 12.1)); 1167 (“a device provides, among other parameters, its device class,
`
`which can include the disk drive class”); 1111108, 111.
`
`5. Same as 3, and also Supported by: Zadok 11108.
`
`6. Same as l.
`
`7. Same as 5.
`
`8. Responsive to: FOR, 2828—13 (“it would render the Kawaguchi invention
`
`in0perable if the interface device of Kawaguchi responded to any Inquiry... by
`
`saying the device at that ID is a hard drive”); 20: 12—14; Supported by: Petition,
`
`4322—4; Zadok, 1190 (“With regard to hard disks in particular, the (mandatory)
`
`INQUIRY command ‘[r]eturns LUN specific information”); see also additional
`
`support in 3.
`
`9—11. Responsive to: PQR, 27:20—28:13 (“SCSI inquiry and responses are made at a
`
`given device ID. [The] data reading unit... has its own device ID. . ..[I]t would
`
`render [Kawaguchi] inoperable if the interface device... responded to any Inquiry...
`
`by saying the device at that ID is a hard drive”); 20:12—14; Supported by: Zadok,
`
`1190 (“With regard to hard disks in particular, the (mandatory) INQUIRY command
`
`‘[r]eturns LUN specific information”); 1198 (“INQUIRY command ‘can be used to
`
`learn... the device type’”); see also additional support in 3.
`
`
`
`Respectfully submitted,
`
`STERNE, KESSLER,GOLDST1£IN & Fox P.L.L.C.
`‘
`i
`l' /
`by 1
`Lori A. Gordon, Reg. No. 50,633
`Attorney for Petitioner
`
`Date: December 12, 2017
`
`1 100 New York Avenue, NW.
`
`Washington, DC. 20005-3934
`(202) 371 -2600
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the foregoing PETITIONER’S
`
`RESPONSIVE ITEMIZED LIST was served electronically Via e—mail on
`
`December 12, 2017, in its entirety on the following:
`
`Gregory S. Donahue (Lead Counsel)
`Minghui Yang (Back—up Counsel)
`Michael R. Fleming (Back-up Counsel)
`Anthony L. Meola (Back-up Counsel)
`Jason A Murphy (Back-up Counsel)
`Victor J. Baranowski (Back—up Counsel)
`Arlen L. Olsen (Back-up Counsel)
`gdonahue/q dgelawcom
`mVanu/il dpelawcom
`
`docketingglggelawcom
`mtlemingu ircll.com
`
`ameola'z/ iplmvusacom
`imurphv’tz iplzm'usacom
`\‘baranoxx'ski/(j ipliyusacom
`aolscn/q iplmvusacom
`
`STERNE, KESSLER, GOLDSTEIN & Fox P.L.L.C.
`
`hfi/M/
`
`Lori A. Gordon, Reg. No. 50,633
`Attorney for Petitioner
`
`Date: December 12, 2017
`
`1 100 New York Avenue, NW.
`
`Washington, DC. 20005-3934
`(202) 371-2600
`
`
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