`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________
`
`
`NVIDIA CORPORATION,
`Petitioner,
`
`v.
`
`POLARIS INNOVATIONS LIMITED,
`Patent Owner.
`
`__________
`
`
`Case IPR2017-01819
`Patent 7,124,325
`
`__________
`
`
`PATENT OWNER’S INITIAL MANDATORY NOTICES
`
`
`
`
`
`
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.8(a)(2), the Patent Owner submits the following
`
`initial mandatory notices.
`
`
`
`1.
`
`Real Parties-In-Interest (37 C.F.R. § 42.8(b)(1))
`
`The real parties-in-interest of the Patent Owner are Polaris Innovations
`
`Limited, Wi-LAN Inc., and Quarterhill Inc. Polaris Innovations Limited, the
`
`owner of the patent under review, is a corporation organized and existing under the
`
`laws of Ireland, with its principal place of business at 29 Earlsfort Terrace, Dublin
`
`2, Republic of Ireland. Wi-LAN Inc. and Quarterhill Inc. are Canadian
`
`corporations with principal places of business at 303 Terry Fox Drive, Suite 300,
`
`Ottawa, Ontario, Canada K2K 3J1. Quarterhill Inc. is a publicly traded company.
`
`
`
`2.
`
`Related Matters (37 C.F.R. § 42.8(b)(2))
`
`The following judicial and administrative matters may affect or be affected
`
`by a decision in this case:
`
`(a) Polaris Innovations Ltd. v. Dell Inc. & Nvidia Corp., Case No. 5:16-
`
`cv-00451 (W.D. Tex. filed May 16, 2016) was an infringement action
`
`involving the patent under review. That case was transferred to the
`
`United States District Court for the Northern District of California on
`
`Dec. 5, 2016.
`
`(b) Polaris Innovations Ltd. v. Dell Inc. & Nvidia Corp., Case No. 4:16-
`
`cv-07005 (N.D. Cal.) is an infringement action, involving the patent
`
`IPR2017-01819
`
`PO Initial Mandatory Notices
`
`Page 2 of 6
`
`
`
`under review, transferred from the United States District Court for the
`
`Western District of Texas on Dec. 5, 2016 and accepted on Dec. 7,
`
`2016.
`
`(c)
`
`IPR2017-00382 was an inter partes review of the same patent, filed
`
`by the same petitioner on December 19, 2016. The Board denied
`
`institution of trial by a decision dated June 23, 2017 (Paper 10).
`
`3.
`
`Lead and Back-Up Counsel (37 C.F.R. § 42.8(b)(3))
`
`Pursuant to 37 C.F.R. §§ 42.8(b)(3) and 42.10(a), Patent Owner provides the
`
`following designation of counsel:
`
`LEAD COUNSEL
`
`Matthew Phillips (Reg. No. 43,403)
`Laurence & Phillips IP Law LLP
`7327 SW Barnes Road #521
`Portland, OR 97225
`Phone: (503) 964-1129
`Fax: (703) 439-1624
`mphillips@lpiplaw.com
`
`BACKUP COUNSEL
`
`Derek Meeker (Reg. No. 53,313)
`Laurence & Phillips IP Law LLP
`7327 SW Barnes Road #521
`Portland, OR 97225
`Phone: (360) 606-8922
`Fax: (703) 439-1624
`dmeeker@lpiplaw.com
`
`
`
`IPR2017-01819
`
`PO Initial Mandatory Notices
`
`Page 3 of 6
`
`
`
`Kevin Laurence (Reg. No. 38,219)
`Laurence & Phillips IP Law LLP
`1940 Duke Street, Second Floor
`Alexandria, VA 22314
`Phone: (703) 463-0640
`Fax: (703) 439-1624
`klaurence@lpiplaw.com
`
`Bryan Richardson (Reg. No. 43,043)
`WiLAN Inc.
`Plaza Tower, 600 Anton Blvd., Suite 1350
`Costa Mesa, CA 92626
`Phone: (613) 688-1690
`Fax: (714) 954-2595
`brichardson@wilan.com
`
`A power of attorney for the above-identified counsel accompanies this
`
`
`
`
`
`notice.
`
`
`
`
`
`4.
`
`Service Information (37 C.F.R. § 42.8(b)(4))
`
`Service of any documents may be made at the email addresses for the lead
`
`and back-up counsel designated above. If physical delivery is necessary, such
`
`service may be made at the postal addresses for the lead and back-up counsel
`
`designated above with a courtesy notification to each of their respective email
`
`addresses at the time of sending.
`
`5.
`
`Payment of Fees under 37 C.F.R. § 42.103
`
`The undersigned authorizes the U.S. Patent and Trademark Office to charge
`
`any applicable fees incurred by the Patent Owner in this case to Deposit Account
`
`No. 50-5836.
`
`IPR2017-01819
`
`PO Initial Mandatory Notices
`
`Page 4 of 6
`
`
`
`Date: 2017 July 28
`
`Respectfully submitted,
`
`By: / M.C. Phillips /
`Matthew C. Phillips
`Registration No. 43,403
`Lead Counsel for Patent Owner
`
`
`
`
`IPR2017-01819
`
`PO Initial Mandatory Notices
`
`Page 5 of 6
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
`I hereby certify that on July 28, 2017, copies of the foregoing PATENT
`
`OWNER’S INITIAL MANDATORY NOTICES and all documents filed with it
`
`were served via electronic mail, as agreed to by counsel, upon the following
`
`counsel for the Petitioner:
`
`David M. Hoffman:
`
`
`Jeremy J. Monaldo:
`
`
`W. Karl Renner:
`
`
`
`IPR24069-0004IP2@fr.com,
`PTABInbound@fr.com,
`hoffman@fr.com
`
`IPR24069-0004IP2@fr.com,
`PTABInbound@fr.com,
`monaldo@fr.com
`
`IPR24069-0004IP2@fr.com,
`PTABInbound@fr.com,
`renner@fr.com
`
`/ M. C. Phillips /
`Matthew Phillips
`Registration No. 43,403
`
`
`
`IPR2017-01819
`
`PO Initial Mandatory Notices
`
`Page 6 of 6
`
`
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