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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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`ZTE (USA) Inc.,
`Samsung Electronics Co., Ltd., and
`Samsung Electronics America, Inc.,
`
`Petitioner
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`v.
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`Fundamental Innovation Systems International LLC,
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`Patent Owner
`
`Case No. IPR2018-001111
`Patent No. 8,624,550 B2
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`PATENT OWNER FUNDAMENTAL INNOVATION SYSTEMS
`INTERNATIONAL LLC’S UPDATED NOTICE
`PURSUANT TO 37 C.F.R. § 42.8
`
`
`1 LG Electronics, Inc., LG Electronics U.S.A. Inc., LG Electronics Mobilecomm
`U.S.A. Inc., LG Electronics Mobile Research U.S.A. LLC, and LG Electronics
`Alabama, Inc. were joined as parties to this proceeding via a Motion for Joinder in
`IPR2018-00461.
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`IPR2018-00111
`Patent No. 8,624,550
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`Pursuant to 37 C.F.R. § 42.8, the Patent Owner Fundamental Innovation
`
`Systems International LLC hereby submits the following updated notice.
`
`I.
`
`Real Party-In-Interest
`Fundamental Innovation Systems International LLC is the owner of U.S.
`
`Patent No. 8,624,550 (“the '550 patent”), and Fundamental Innovation Systems
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`International Holdings LLC is the parent entity of Fundamental Innovation
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`Systems International LLC. The Patent Owner has contracted JASPAR to manage
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`its patent portfolio.
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`II. Related Matters
`The Patent Owner identifies the following matters that may be deemed
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`related pursuant to 37 C.F.R. § 42.8(b)(2):
`
`• Fundamental Innovation Systems International LLC v. Samsung Elecs.
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`Co. et al., No. 2:17-cv-00145 (E.D. Tex.), settled;
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`• Fundamental Innovation Systems International LLC v. LG Electronics,
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`Inc. et al., No. 2:16-cv-01425 (E.D. Tex.) (the "LG action");
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`• Fundamental Innovation Systems International LLC v. Huawei
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`Investment & Holding Co. et al., No. 2:16-cv-01424 (E.D. Tex.),
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`consolidated with the LG action;
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`• Fundamental Innovation Systems International LLC v. ZTE Corp. et al.,
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`No. 3:17-cv-01827 (N.D. Tex.), consolidated with the LG action and
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`stayed pending settlement; and
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`- 2 -
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`IPR2018-00111
`Patent No. 8,624,550
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`• The '550 patent is a continuation application of application No. 13/175,509,
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`now U.S. Patent No. 8,232,766 ("the '766 patent"), which is in turn a
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`continuation of application No. 12/905,934, filed Oct. 15, 2010, now U.S.
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`Patent No. 7,986,127; which is a continuation of 12/714,204, filed Feb. 26,
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`2010, now U.S. Patent No. 7,834,586 ("the '586 patent); which is a
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`continuation of 12/268,297, filed Nov. 10, 2008, now U.S. Patent No.
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`7,737,657; which is a continuation of 11/749,680, filed May 16, 2007, now
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`U.S. Patent No. 7,453,233; which is a continuation of 11/175,885, filed July
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`6, 2005, now U.S. Patent No. 7,239,111 ("the '111 patent); which is a
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`continuation of 10/087,629, filed Mar. 1, 2002, now U.S. Patent No.
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`6,936,936. The '766 claims priority from Provisional Application Nos.
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`60/330,486, filed Oct. 23, 2001, and 60/273,021, filed Mar. 1, 2001.
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`• IPR Nos. 2018-00214, 2018-00215, 2018-00472 and 2018-00508 have also
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`been filed against the '766 patent, and the Board has denied institution for all
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`four while ZTE has requested a rehearing in IPR2018-00215;
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`• IPR Nos. 2018-00274, 2018-00485 and 2018-00493 have been filed against
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`the '586 patent, and the Board has denied institution for all three; and
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`• IPR Nos. 2018-00276, 2018-00487 and 2018-00495 have been filed against
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`the '111 patent, and the Board has denied institution for IPR2018-00487 and
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`2018-00495. IPR2018-00276 is pending.
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`- 3 -
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`IPR2018-00111
`Patent No. 8,624,550
`• IPR Nos. 2018-00110, 2018-00111, 2018-00460, 2018-00461 and 2018-
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`00465 have been filed against the '550 patent, and the Board has denied
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`institution for IPR2018-00110, IPR2018-00460, IPR2018-00465, and
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`terminated and consolidated IPR2018-00461 with IPR2018-00111.
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`III. Lead And Back-Up Counsel
`
`
`Lead Counsel
`Hong Annita Zhong (Reg. No. 66,530)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`hzhong@irell.com
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`
`
`Back-up Counsel
`Michael Fleming (Reg. No. 67,933)
`Jason Sheasby (pro hac vice to be requested)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`mfleming@irell.com
`jsheasby@irell.com
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`
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`IV. Service Information
`The Patent Owner consents to electronic service by email to email addresses
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`listed above and FundamentalIPRs@irell.com.
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`Dated: September 13, 2018
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`Respectfully submitted,
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`By:
`
`
`/s/ Hong Zhong
`H. Annita Zhong. (Reg. No. 66,530)
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`- 4 -
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`IPR2018-00111
`Patent No. 8,624,550
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`CERTIFICATE OF SERVICE
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`I hereby certify, pursuant to 37 C.F.R. section § 42.6, that on September
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`13, 2018, a complete copy of the foregoing document was served upon the
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`following, by ELECTRONIC MAIL:
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`MCDERMOTT WILL & EMERY
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`Charles M. McMahon
`cmcmahon@mwe.com
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`Brian A. Jones
`bajones@mwe.com
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`Thomas DaMario
`tdamario@mwe.com
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`HAYNES AND BOONE, LLP
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`David L. McCombs
`David.mccombs.ipr@haynesboone.com
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`Gregory P. Huh
`Gregory.huh.ipr@haynesboone.com
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`David M. O’Dell
`David.odell.ipr@haynesboone.com
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`
` /Susan M. Langworthy/
`Susan M. Langworthy
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`- 5 -
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