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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________
`
`
`
`HUAWEI DEVICE CO., LTD.
`
`Petitioner,
`
`v.
`
`FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC,
`
`Patent Owner.
`
`
`_________________
`
`Case No. IPR2018-00485
`Patent No. 7,834,586
`___________________
`
`
`
`
`
`PATENT OWNER FUNDAMENTAL INNOVATION SYSTEMS
`INTERNATIONAL LLC’S NOTICE PURSUANT TO 37 C.F.R. 42.8
`
`
`
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`

`

`IPR2018-00485
`Patent No. 7,834,586
`
`
`
`Pursuant to 37 C.F.R. 42.8, the Patent Owner Fundamental Innovation
`
`Systems International LLC hereby submits the following Notice.
`
`I.
`
`Real Party-In-Interest
`
`Fundamental Innovation Systems International LLC is the owner of U.S.
`
`Patent No. 7,834,586 (“the '586 patent”), and Fundamental Innovation Systems
`
`International Holdings LLC is the parent entity of Fundamental Innovation
`
`Systems International LLC. The Patent Owner has contracted with TnT IP, LLC to
`
`manage its patent portfolio.
`
`II. Related Matters
`The Patent Owner identifies the following matters that may be deemed
`
`related pursuant to 37 C.F.R. § 42.8(b)(2):
`
` Fundamental Innovation Systems International LLC v. Samsung Elecs.
`
`Co. et al., No. 2:17-cv-00145 (E.D. Tex.);
`
` Fundamental Innovation Systems International LLC v. LG Electronics,
`
`Inc. et al., No. 2:16-cv-01425 (E.D. Tex.) (the "LG action");
`
` Fundamental Innovation Systems International LLC v. Huawei
`
`Investment & Holding Co. et al., No. 2:16-cv-01424 (E.D. Tex.),
`
`consolidated with the LG action; and,
`
` Fundamental Innovation Systems International LLC v. ZTE Corp. et al.,
`
`No. 3:17-cv-01827 (N.D. Tex.).
`
`
`
`
`- 1 -
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`

`

`IPR2018-00485
`Patent No. 7,834,586
`
`
` The '586 patent is a continuation application of U.S. Application No.
`
`12/268,297, filed Nov. 10, 2008, now U.S. Patent No. 7,734,657; which
`
`is a continuation application of 11/749,680, filed May 16, 2007, now
`
`U.S. Patent No. 7,453,233; which is a continuation of 11/175,885, filed
`
`July 6, 2005, now U.S. Patent No. 7,239,111 (" the '111 patent); which is
`
`a continuation application of 10/087,629, filed Mar. 1, 2002, now U.S.
`
`Patent No. 6,936,936. The '586 patent claims priority from U.S.
`
`Provisional Applications 60/330,486, filed Oct. 23, 2001, and
`
`60/273/021, filed Mar. 1, 2001.
`
` The '586 patent has four children applications:
`
` U.S. Application No. 12/905,934, filed Oct. 15, 2010, now U.S.
`
`Patent No. 7,986,127;
`
` U.S. Application No. 13/175,487, filed July 1, 2011, now U.S.
`
`Patent No. 8,169,187;
`
` U.S. Application No. 13/175,509, filed on July 1, 2011, now U.S.
`
`Patent No. 8,232,766 ("the '766 patent); and,
`
` U.S. Application No. 13/536,767, filed on June 28, 2012, now U.S.
`
`Patent No. 8,624,550 ("the '550 patent).
`
`
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`- 2 -
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`

`IPR2018-00485
`Patent No. 7,834,586
`
`
` IPR No. 2018-00493 has also been filed against the '586 patent;
`
` IPR Nos. 2018-00487 and 2018-00495 have been filed against the '111
`
`patent.
`
` IPR Nos. 2018-00214, 2018-00215, 2018-00472 and 2018-00508 have
`
`been filed against the '766 patent; and,
`
` IPR Nos. 2018-0110, 2018-00111, 2018-00460, 2018-00461 and 2018-
`
`00465 have been filed against the '550 patent.
`
`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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`
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`Back-up Counsel
`Michael Fleming (Reg. No. 67,933)
`Jason Sheasby (pro hac vice to be requested)
`James Milkey (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
`jmilkey@irell.com
`
`
`- 3 -
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`

`

`IPR2018-00485
`Patent No. 7,834,586
`
`
`
`
`IV. Service Information
`The Patent Owner consents to electronic service by email to email addresses
`
`listed above and FundamentalIPRs@irell.com.
`
`
`Dated: January 22, 2018
`
`
`
`
`
`
`
`Respectfully submitted,
`By: /s/ Hong Zhong
`
`H. Annita Zhong. (Reg. No. 66,530)
`
`
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`- 4 -
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`IPR2018-00485
`Patent No. 7,834,586
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify, pursuant to 37 C.F.R. sections 42.6, that on January 22,
`
`2018, a complete copy of the foregoing document was served upon the following,
`
`by ELECTRONIC MAIL:
`
`
`COVINGTON & BURLING LLP
`One City Center
`850 Tenth Street, NW
`Washington DC 20001
`
`David A. Garr (Reg. No. 74,932)
`dgarr@cov.com
`
`Anupam Sharma (Reg. No. 55,609)
`asharma@cov.com
`
`
`
` /Susan M. Langworthy/
` Susan M. Langworthy
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`- 5 -
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