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`Justin J. Lesko (justinlesko@patentit.com)
`Reg. No. 69,643
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`INTEL CORPORATION, GLOBALFOUNDRIES U.S., INC.,
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`MICRON TECHNOLOGY, INC., AND
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`SAMSUNG ELECTRONICS COMPANY, LTD.,
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`Petitioners
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`v.
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`DANIEL L. FLAMM,
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`Patent Owner
`
`CASE IPR2017-03911
`U.S. Patent No. 6,017,221
`
`
`PATENT OWNER’S UNOPPOSED MOTION TO FILE
`AMENDED PATENT OWNER RESPONSE
`
`
`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
`
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`I.
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`Relief Requested
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`With the Board’s authorization for this motion by email dated February 28,
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`2018 and at oral hearing on March 7, 2018, Patent Owner Daniel L. Flamm, by its
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`attorney, respectfully requests that the Board enter the attached amended Patent
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`Owner Response in this proceeding.
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`II.
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`Statement of Facts Showing Good Cause for the Board to Enter the
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`Corrected Patent Owner Response
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`Patent Owner timely filed a Patent Owner Response in this matter pursuant
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`to 37 C.F.R. § 42.120 on September 6, 2017 (Paper 13).
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`It recently came to the attention of Patent Owner’s counsel that Paper 13 as
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`filed includes clerical and typographical errors in several of its citations to the
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`Exhibits, including citations to Exhibit 1001, Exhibit 1006, Exhibit 2001, and
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`Exhibit 2003, as well as “Id.” citations that require clarification.
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`Accordingly, in the interest of justice and to assist the Board with its
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`consideration of the Patent Owner Response, Patent Owner provides herewith an
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`amended Patent Owner Response that corrects these typographical citation errors.
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`For the Board’s convenience, a redline of the changes made relative to Patent
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`Owner’s Response filed on September 6, 2017 (Paper 13) is also provided with this
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`motion.
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`In accordance with the February 28 email from the Board authorizing this
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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
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`motion, Patent Owner’s proposed amendments to the brief “correct[] obvious
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`clerical errors” and “are limited to one-for-one replacement.” None of the
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`corrections provide additional supporting citations beyond what was already set
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`forth in the original Patent Owner Response. Patent Owner also does not expand
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`existing citations by citing additional support.
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`Petitioner does not oppose this motion.
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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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`and consider the amended Patent Owner Response provided herewith.
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`Date: March 8, 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
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`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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`2
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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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`MOTION TO FILE AMENDED PATENT OWNER RESPONSE was served
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`by electronic mail on this day, March 8, 2018, on the following individuals:
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`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
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`WCGlobalFoundries-
`FlammTeam@whitecase.com
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`Counsel for GLOBALFOUNDRIES
`U.S., Inc.
`
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`Jonathan McFarland
`JMcfarland@perkinscoie.com
`PERKINS COIE LLP
`1201 Third Ave., Suite 4900
`Seattle, WA 98101
`(206) 359-8000
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`Daniel Keese
`DKeese@perkinscoie.com
`PERKINS COIE LLP
`1120 NW Couch St., 10th Floor
`Portland, OR 97209
`(503) 727-2000
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`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
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`Intel-Flamm-Service-
`IPR@perkinscoie.com
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`Counsel for Intel Corporation
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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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`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
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`Micron.flamm.service@weil.com
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`Counsel for Micron Technology, Inc.
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`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
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`PH-Samsung-Flamm-
`IPR@paulhastings.com
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`Counsel for Samsung Electronics
`Company, Ltd.
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`By: /Justin J. Lesko, reg. no. 69,643/
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`4
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