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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`SAMSUNG ELECTRONICS CO., LTD.; AND
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioner
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`v.
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`IMAGE PROCESSING TECHNOLOGIES, LLC
`Patent Owner
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`____________________
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`Case No. IPR2017-00357
`Patent No. 8,989,445
`____________________
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`PETITIONER’S RESPONSE TO THE NOTICE OF DEFECTIVE
`PETITION (PAPER NO. 3)
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`IPR2017-00357
`Patent No.8,989,445
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`In response to the Notice of Defective Petition (Paper No. 3), dated
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`December 2, 2016, Petitioner submits herewith a corrected exhibit list and
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`corrected Exhibit 1002. No substantive changes were made to the exhibit; only the
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`label and page numbers were updated.
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`Petitioner intends to request, by email to trials@uspto.gov, that the original,
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`incorrectly labeled exhibit be expunged.
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`By: /John Kappos/
`John Kappos (Reg. No. 37,861)
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`CERTIFICATE OF SERVICE
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`The undersigned certifies pursuant to 37 C.F.R. § 42.6(e) and § 42.105 that
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`on December 7, 2016, a true and correct copy of Petitioner’s Response To The
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`Notice Of Defective Petition (Paper No. 3) was served via express mail on the
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`Petitioner at the following correspondence address of record:
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`Gregory Nelson
`FOX ROTHSCHILD LLP
`997 Lennox Drive
`Lawrenceville, NJ 08648
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`Courtesy copies were also sent to Patent Owner’s litigation counsel at the
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`following addresses by email:
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`S. Calvin Capshaw
`ccapshaw@capshawlaw.com
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`Christopher J. Coulson
`chriscoulson@andrewskurthkenyon.com
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`Michael N. Zachary
`michaelzachary@andrewskurthkenyon.com
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`Respectfully submitted,
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`/s/ John Kappos .
`John Kappos (Reg. No. 37,861)
`O’Melveny & Myers LLP
`610 Newport Center Drive, 17th Floor
`Newport Beach, CA 92660
`Telephone: (949) 760-9600
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`Attorney for Petitioner