`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`UNIFIED PATENTS INC.
`
`Petitioner
`
`- vs. -
`
`FALL LINE PATENTS, LLC
`
`Patent Owner
`———————
`
`IPR2018-00043
`
`U.S. Patent 9,454,748
`
`PETITIONER’S SUBMISSION PURSUANT TO ORDER –
`
`MOTIONS FOR PROTECTIVE ORDER AND TO SEAL
`
`(PAPER 33)
`
`
`
`
`
`
`
`
`
`Petitioner’s Submission Pursuant to Paper 33
`IPR2018-00043 (U.S. Patent 9,454,748)
`In view of the Board’s deferral of rulings on the parties’ motions to seal
`
`(Papers 29 and 32), and pursuant to the Board’s instructions in the Order – Motions
`
`for Protective Order and to Seal (Paper 33), Petitioner Unified Patents Inc.
`
`herewith files redacted, public versions of Paper 30, Paper 31, and Exhibit 2009.
`
`Neither Paper 30, nor Paper 31, nor Exhibit 2009 need be sealed in its entirety.
`
`Petitioner respectfully requests that Exhibit 1028 be unsealed, as it does not
`
`contain sensitive, non-public information.
`
`Petitioner understands that Patent Owner wishes to file a responsive paper,
`
`as Patent Owner has indicated that it does not agree with Petitioner’s redactions to
`
`Paper 30, Paper 31, and Exhibit 2009.
`
`April 18, 2019
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`/David W. OBrien/
`David W. O’Brien
`Counsel for Petitioner
`Registration No. 40,107
`HAYNES AND BOONE, LLP
`
`1
`
`
`
`Petitioner’s Submission Pursuant to Paper 33
`IPR2018-00043 (U.S. Patent 9,454,748)
`PETITIONER’S EXHIBIT LIST
`April 18, 2019
`
`EX1001
`
`U.S. Patent 9,454,748 to J. David Payne
`
`EX1002
`
`Prosecution File History of U.S. Patent 9,454,748 (“’748 PH”)
`
`EX1003
`
`Prosecution File History of U.S. Patent 7,822,816 (“’816 PH”)
`
`EX1004
`
`U.S. Patent 7,822,816 to J. David Payne
`
`EX1005
`
`Declaration of A.L. Narasimha Reddy
`
`EX1006
`
`U.S. Patent 6,154,745 to Kari et al. (“Kari”)
`
`EX1007
`
`HTML 4 Unleashed by Darnell et al. (“Darnell”)
`
`EX1008
`
`Declaration of David Bader
`
`EX1009
`
`U.S. Patent 6,380,928 to Todd (“Todd”)
`
`EX1010
`
`U.S. Patent 6,381,603 to Chan et al. (“Chan”)
`
`EX1011 Memorandum Opinion and Order, Macrosolve, Inc. v. Antenna
`Software, Inc. et al., 6:11-cv-287 MHS-KNM (E.D. Tex. Jan. 21,
`2014) (“’816 Markman Order”)
`
`EX1012
`
`Institution Decision, IPR2014-00140 (“’816 Institution”)
`
`EX1013 Microsoft Computer Dictionary, 5th ed. (excerpt)
`
`EX1014
`
`U.S. Patent 6,222,483 to Twitchell et al. (“Twitchell”)
`
`EX1015
`
`U.S. Patent 5,043,736 to Darnell et al. (“Darnell ’736”)
`
`EX1016
`
`Dictionary of Computer Science (excerpt)
`
`EX1017
`
`Dictionary of Scientific and Technical Terms, 4th ed. (excerpt)
`
`EX1018
`
`Goran M. Djuknic & Robert E. Richton, Geolocation and Assisted
`GPS, IEEE Computer, Vol. 34 no. 2, 123-125 (Feb. 2001)
`
`2
`
`
`
`EX1019
`
`EX1020
`
`Petitioner’s Submission Pursuant to Paper 33
`IPR2018-00043 (U.S. Patent 9,454,748)
`Robert S. Anthony, The Ultimate Personal Peripheral, PC Magazine,
`Vol. 17 no. 5, 100-124 (Mar. 10, 1998)
`
`Johan Hjelm, Creating Location Services for the Wireless Web:
`Professional Developer’s Guide (2002).
`
`EX1021
`
`Reply Declaration of A.L. Narasimha Reddy (“Reddy Reply Decl.”)
`
`EX1022
`
`EX1023
`
`Ira Kalb, Wireless in Europe, May 2001, available at
`https://web.archive.org/web/20011215142247/http://www-
`106.ibm.com/developerworks/library/wi-eur/index.html, last retrieved
`August 16, 2018 (“Kalb”).
`
`HTML 4.0 Guidelines for Mobile Access, W3C Note – 15 March
`1999, https://web.archive.org/web/20000823062148/
`http://www.w3.org:80/TR/1999/NOTE-html40-mobile-19990315/,
`last retrieved September 6, 2018 (“HTML 4.0 Note”).
`
`EX1024
`
`Timothy Berners-Lee, Hypertext Markup Language – 2.0, RFC 1866,
`https://tools.ietf.org/pdf/rfc1866.pdf, last retrieved September 6, 2018
`(“RFC 1866”).
`
`EX1025
`
`Reddy Declaration in IPR2014-00140.
`
`EX1026
`
`Declaration of Kevin Jakel
`
`EX1027
`
`Unified Patents Voluntary Interrogatories
`
`EX1028
`
`Jakel Deposition Transcript Errata Sheet
`
`EX1029
`
`Redacted Version of Exhibit 2009 (Jakel Deposition Transcript)
`
`3
`
`
`
`Petitioner’s Submission Pursuant to Paper 33
`IPR2018-00043 (U.S. Patent 9,454,748)
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Unified Patents, Inc.
`
`Petitioner
`
`§
`§
`§
`§
`§
`
`Petition for Inter Partes Review
`
`IPR2018-00043
`U.S. Patent No. 9,454,748
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. § 42.6, that service
`was made on the Patent Owner as detailed below.
`Date of service April 18, 2019
`
`Manner of service Electronic Service by E-Mail
`
`Documents served 1) Petitioner’s Submission Pursuant to Order – Motions for
`Protective Order and to Seal (Paper 33)
`2) Patent Owner’s RPI Observations (Public Version –
`Paper 30)
`3) Petitioner’s Response to Patent Owner’s Observations
`(Public Version – Paper 31)
`4) Exhibit 1029 (Redacted Exhibit 2009)
`
`Persons served Terry L. Watt (terry.watt@crowedunlevy.com)
`Matthew J. Antonelli (matt@ahtlawfirm)
`Michael E. Ellis (michael@ahtlawfirm.com)
`Larry D. Thompson, Jr. (larry@ahtlawfirm.com)
`
`/Raghav Bajaj/
`Raghav Bajaj
`Counsel for Petitioner
`Registration No. 66,630
`
`
`
`
`
`
`
`
`
`
`4
`
`
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