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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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`UNIFIED PATENTS INC.,
`Petitioner
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`v.
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`VILOX TECHNOLOGIES LLC,
`Patent Owner
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`____________________
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`Case IPR2018-00044
`Patent No. 7,302,423 B2
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`PATENT OWNER’S NOTICE OF DEPOSITION OF DR. GREENSPUN
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`Pursuant to 37 C.F.R. §42.53, Patent Owner Vilox Technologies, LLC, by
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`Case IPR2018-00044
`Patent No. 7,302,423
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`1.
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`and through its counsel, shall take the deposition of Dr. Philip Greenspun. The
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`Parties have agreed the deposition is to be held at the Law Offices of Haynes
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`Boone LLC, 30 Rockefeller Center, New York, NY, on May 24, 2018. The
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`deposition will be conducted before an officer authorized to administer oaths. The
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`deposition will be recorded by stenographic and/or videographic means. All
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`counsel of record are invited to attend this deposition.
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`2.
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`Patent Owner intends to rely on the Exhibits and Documents previously filed
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`with the Board, including, but not limited to:
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`Petition for Inter Partes Review of U.S. Patent 7,302,423 (423 Patent)
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`Exhibit 1001, U.S. Patent 7,302,423
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`Exhibit 1002, Prosecution History of U.S. Patent 7,302,423
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`Exhibit 1005, Declaration of Dr. Philip Greenspun
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`Exhibit 1006, U.S. Patent 5,701.453 (Maloney)
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`Exhibit 1007, U.S. Patent 7,168,039 (Bertram)
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`Exhibit 1008, U.S. Patent 6,300,947 (Kanevsky)
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`Exhibit 1009, John Walkenbach, Microsoft Excel 2000 Bible
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`Exhibit 1010, IBM Dictionary of Computing, Tenth Edition
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`Exhibit 1011, Declaration of Dr. Ingrid Hsieh-Yee
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`Exhibit 1012, Curriculum Vitae of Dr. Philip Greenspun
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`2
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`Exhibit 2001, Declaration of Dr. Wesley Chu,
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`Exhibit 2003, Declaration of Dr. Joseph L. De Bellis
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`Case IPR2018-00044
`Patent No. 7,302,423
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`Exhibit 2005, U.S. Patent 6,593,949 to Chew et al. (Chew)
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`Patent Owner’s Preliminary Response
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`3.
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`Patent Owner intends to elicit testimony related to applicability of the
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`documents listed in paragraph 2, above as to the validity of the claims of the 423
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`Patent.
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`Dated: May 17, 2018
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`Respectfully submitted,
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`By: /John K. Harrop/
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`John K. Harrop
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`Reg. No. 41,817
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`Lead Counsel for Patent Owner
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`3
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on the date
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`Case IPR2018-00044
`Patent No. 7,302,423
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`indicated below, a complete and entire copy of this submission was provided by
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`email to Petitioner’s counsel via email, as agreed to by Petitioner’s Service
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`Information in the October 6, 2017 Petition submission, by serving the email
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`address of record as follows:
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`David M. O’Dell, Reg. No. 42,044 (David.odell.ipr@haynesboone.com)
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`Dated: May 17, 2018
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`Respectfully submitted,
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`By: /John K. Harrop/
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`John K. Harrop
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`Reg. 41,817
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`Lead Counsel for Patent Owner
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`4
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