By:
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`Justin J. Lesko (justinlesko@patentit.com)
`Reg. No. 69,643
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`INTEL CORPORATION, GLOBALFOUNDRIES U.S., INC.,
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`MICRON TECHNOLOGY, INC., AND
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`SAMSUNG ELECTRONICS COMPANY, LTD.,
`
`Petitioners
`
`v.
`
`DANIEL L. FLAMM,
`
`Patent Owner
`
`CASE IPR2017-03911
`U.S. Patent No. 6,017,221
`
`
`PATENT OWNER’S MOTION TO ENTER
`CURRICULUM VITAE OF DANIEL L. FLAMM, SC.D
`
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`1 Samsung Electronics Company, Ltd. was joined as a party to this proceeding via
`a Motion for Joinder in IPR2017-01746
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`Justin J. Lesko (justinlesko@patentit.com)
`Reg. No. 69,643
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`INTEL CORPORATION, GLOBALFOUNDRIES U.S., INC.,
`
`MICRON TECHNOLOGY, INC., AND
`
`SAMSUNG ELECTRONICS COMPANY, LTD.,
`
`Petitioners
`
`v.
`
`DANIEL L. FLAMM,
`
`Patent Owner
`
`CASE IPR2017-03911
`U.S. Patent No. 6,017,221
`
`
`PATENT OWNER’S MOTION TO ENTER
`CURRICULUM VITAE OF DANIEL L. FLAMM, SC.D
`
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`1 Samsung Electronics Company, Ltd. was joined as a party to this proceeding via
`a Motion for Joinder in IPR2017-01746
`
`
`
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2017-00391
`
`
`I.
`
`Relief Requested
`
`With the Board’s authorization for this motion by email dated March 2, 2018,
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`Patent Owner Daniel L. Flamm, by its attorney, respectfully requests that the
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`Board enter the attached curriculum vitae (C.V.) of Daniel L. Flamm, Sc.D
`
`(Exhibit 2007) in this proceeding.
`
`II.
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`Statement of Facts Showing Good Cause for the Board to Enter the
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`Curriculum Vitae
`
`Patent Owner timely filed a Declaration of Daniel L. Flamm, Sc.D (Exhibit
`
`2001) with its Patent Owner Preliminary Response in this matter on March 14,
`
`2017.
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`Patent Owner timely filed a Second Declaration of Daniel L. Flamm, Sc.D
`
`(Exhibit 2003) with its Patent Owner Response in this matter on September 6,
`
`2017.
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`The Declarations describe Dr. Flamm’s background and qualifications at
`
`Paragraphs 1-5.
`
`Paragraph 1 of each declaration refers to Dr. Flamm’s curriculum vitae
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`“attached as Appendix A.”
`
`It recently came to the attention of Patent Owner’s counsel that Dr. Flamm’s
`
`C.V. was inadvertently not attached to these declarations at the time the
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`declarations were filed.
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`
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`1
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`
`
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2017-00391
`
`Dr. Flamm’s C.V. was previously filed in IPR2015-01767 involving the
`
`same patent at issue herein (U.S. Patent No. 6,017,221) on May 16, 2016 as
`
`Exhibit 2001 to Paper No. 15. It was also filed in IPR2016-01512 on May 1, 2017
`
`as Exhibit 2001 to Paper No. 9. Petitioner Samsung was also the Petitioner in
`
`IPR2016-01512, involving Reissue Patent No. RE40,264, and the other Petitioners
`
`herein are challenging RE40,264 in other currently pending inter partes review
`
`proceedings.
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`Accordingly, in the interest of justice and to assist the Board with its
`
`consideration of this matter, Patent Owner respectfully requests that the Board
`
`enter the attached C.V. of Daniel L. Flamm, Sc.D (Exhibit 2007). The C.V. simply
`
`provides further details of Dr. Flamm’s background and qualifications that were
`
`described in the declarations already of record, and Patent Owner clearly intended
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`to include the C.V. with the declarations. It is important for the Board to have the
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`C.V. in order to adequately weigh the testimony of Dr. Flamm.
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`Entering the C.V. will not prejudice the Petitioners, as it does not affect the
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`substantive arguments already set forth in the briefs, and it does not introduce any
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`new evidence. Some or all of the Petitioners have already seen the publicly
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`available C.V. of Dr. Flamm in other inter partes review proceedings, as discussed
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`above.
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`Petitioners do not oppose this motion to enter the curriculum vitae of Dr.
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`
`
`2
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`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2017-00391
`
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`Flamm.
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`III. Conclusion
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`Patent Owner respectfully requests that the Board grant its motion and enter
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`herein the attached C.V. of Daniel L. Flamm, Sc.D (Exhibit 2007).
`
`
`Date: March 6, 2018
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`Respectfully Submitted,
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`By: /Justin J. Lesko, reg. no. 69,643/
` Justin J. Lesko, reg. no. 69,643
`
`Law Offices of Steve G. Lisa, Ltd.
`7689 E Paradise Lane, Suite 2
`Scottsdale, AZ 85260
`Email: justinlesko@patentit.com
`
`
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`Counsel for Daniel L. Flamm
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`
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`3
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`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2017-00391
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the foregoing PATENT OWNER’S
`
`
`
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`
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`MOTION TO ENTER CURRICULUM VITAE OF DANIEL L. FLAMM,
`
`SC.D was served by electronic mail on this day, March 6, 2018, on the following
`
`David M. Tennant
`dtennant@whitecase.com
`WHITE & CASE LLP
`701 Thirteenth St., NW
`Washington, DC 20005
`(202) 626-3600
`
`Nathan Zhang
`nathan.zhang@whitecase.com
`WHITE & CASE LLP
`3000 El Camino Real
`5 Palo Alto Square, 9th Floor
`Palo Alto, CA 94306
`(650) 213-0300
`
`WCGlobalFoundries-
`FlammTeam@whitecase.com
`
`Counsel for GLOBALFOUNDRIES
`U.S., Inc.
`
`individuals:
`
`
`Jonathan McFarland
`JMcfarland@perkinscoie.com
`PERKINS COIE LLP
`1201 Third Ave., Suite 4900
`Seattle, WA 98101
`(206) 359-8000
`
`Daniel Keese
`DKeese@perkinscoie.com
`PERKINS COIE LLP
`1120 NW Couch St., 10th Floor
`Portland, OR 97209
`(503) 727-2000
`
`Chad S. Campbell
`CSCampbell@perkinscoie.com
`Tyler Bowen
`TBowen@perkinscoie.com
`PERKINS COIE LLP
`2901 North Central Ave., Suite 2000
`Phoenix, AZ 85012
`(602) 351-8000
`
`Intel-Flamm-Service-
`IPR@perkinscoie.com
`
`Counsel for Intel Corporation
`
`
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`4
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`
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`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2017-00391
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`
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`Jared Bobrow
`Jared.bobrow@weil.com
`Jeremy Jason Lang
`Jeremy.lang@weil.com
`WEIL, GOTSHAL & MANGES LLP
`201 Redwood Shores, CA 94065
`(650) 802-3000
`
`Micron.flamm.service@weil.com
`
`Counsel for Micron Technology, Inc.
`
`
`Naveen Modi
`naveenmodi@paulhastings.com
` Joseph E. Palys
`josephpalys@paulhastings.com
`Chetan R. Bansal
`chetanbansal@paulhastings.com
`Paul Hastings LLP
`875 15th Street, N.W.
`Washington, D.C. 20005
`(202) 551-1700
`
`PH-Samsung-Flamm-
`IPR@paulhastings.com
`
`Counsel for Samsung Electronics
`Company, Ltd.
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`By: /Justin J. Lesko, reg. no. 69,643/
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`5
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