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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`SONOS, INC.,
`Petitioner,
`v.
`IMPLICIT, LLC,
`Patent Owner.
`______________________
`
`Case No. IPR2018-00767
`Patent No. 8,942,252
`______________________
`
`
`
`PATENT OWNER’S UPDATED EXHIBIT LIST
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`
`
`Case IPR2018-00767
`Patent No. 8,942,252
`
`Pursuant to 37 C.F.R. § 42.63(e), Patent Owner Implicit, LLC hereby
`
`
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`submits a current listing of Patent Owner exhibits. Exhibit 2097 is being filed and
`
`served today.
`
`Exhibit
`2001
`2002
`2003
`2004
`2005
`2006
`2007
`2008
`2009
`2010
`2011
`2012
`2013
`2014
`2015
`2016
`2017
`2018
`2019
`2020
`2021
`
`Description
`Declaration of Edward Balassanian
`“Technical Presentation.ppt” from BeComm files
`“demo000.html” from BeComm files
`“index.html” from BeComm files re: DEMO 2000
`“P0000542.jpg” from BeComm files
`“web_tablet.html” from BeComm files
`“strsings_audio.html” from BeComm files
`“index.html” from BeComm files re: Project Juno
`“Phase0Formatted.doc” from BeComm files re: Project Juno
`Joint Claim Construction Statement in Implicit, LLC v. Sonos, Inc.,
`No. 17-259-LPS-CJB (D. Del.)
`“Juno Phase 1.doc” from BeComm files re: Project Juno
`“Project Juno Status 021601.msg” from BeComm files re: Project
`Juno
`Strings Source Code CVS log excerpts for avsync.c file.
`Strings Source Code CVS log excerpts for timesync.c file.
`Strings Source Code CVS log excerpts for video.rule file within
`remotesync package.
`Strings Source Code CVS log excerpts for audiosync.c file.
`Source code for audiosync.c from BeComm files
`“clocksync.htm” from BeComm files
`Source code for timesync.c from BeComm files
`Source code for clocksync.c from BeComm files
`“Using Strings to Compose Applications from Reusable
`Componen.pdf” from BeComm files
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`
`
`1
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`
`Case IPR2018-00767
`Patent No. 8,942,252
`
`Description
`“rulesfiles.htm” from BeComm files
`Source code for source.pl from BeComm files re: test/demo
`Screen capture of “fightclubrgb.avi” from BeComm files in
`bdk/test/demo directory
`“Strings_Audio_Player.htm” from BeComm files
`“overview.htm” from BeComm files re: Strings Audio Player
`“usage.htm” from BeComm files re: Strings Audio Player
`Source code for audioplayerapp.rule from BeComm files re:
`test/demo2
`“DMPCaseStudy.doc” from BeComm files
`Strings Source Code CVS log excerpts for clocksync.c file
`Strings Source Code CVS log excerpts for audio.rule file re:
`tes/taudiosync
`Strings Source Code CVS log excerpts for makefile file for
`test/demo directory
`“ipaqperformance.html” from BeComm files
`Strings Source Code CVS log excerpts for audioplayerapp.rule file
`Strings Source Code CVS log excerpts for makefile for
`bdk/packages/videoclient/ directory
`Strings Source Code CVS log excerpts for videomulti.rule in the
`videoserver package
`“synchronization.doc” from BeComm files
`December 16, 2001 email chain re: synchro patent
`“BeComm Comcast RFI Response.doc” from BeComm files
`“Tatung Proposal Final.pdf” from BeComm files
`“Philips Proposal.pdf” from BeComm files
`“Philips Proposal.pdf” from BeComm files
`Source code for avidemux.c from BeComm files
`Source code for bmpdecoder.c from BeComm files
`Source code for bmptorgb.c from BeComm files
`Source code for fanout.c from BeComm files
`
`2
`
`Exhibit
`2022
`2023
`2024
`2025
`2026
`2027
`2028
`2029
`2030
`2031
`
`2032
`2033
`2034
`2035
`
`2036
`2037
`2038
`2039
`2040
`2041
`2042
`2043
`2044
`2045
`2046
`
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`
`Case IPR2018-00767
`Patent No. 8,942,252
`
`Description
`Source code for framer.c from BeComm files
`Source code for ipv4.c from BeComm files
`Source code for rgbalterencoding.c from BeComm files
`Source code for rgbvideo.c from BeComm files
`Source code for speaker.c from BeComm files
`Source code for tcp.c from BeComm files on POSIX
`Source code for udp.c from BeComm files on POSIX
`Source code for tcp.c from BeComm files on Win32
`Source code for udp.c from BeComm files on Win32
`Source code for audio.rule from BeComm files re: test/audiosync
`Source code for timesync.rule from BeComm files re:
`test/audiosync
`Source code for video.rule from BeComm files re: test/audiosync
`Source code for video2.rule from BeComm files re: test/audiosync
`Source code for ipaqvideo.rule from BeComm files re: test/demo
`Source code for localaudio.rule from BeComm files re: test/demo
`Source code for localvideo.rule from BeComm files re: test/demo
`Source code for mp3serveraudio.rule from BeComm files re:
`test/demo
`Source code for network.rule from BeComm files re: test/demo
`Source code for pcmserveraudio.rule from BeComm files re:
`test/demo
`Source code for syncaudio.rule from BeComm files re: test/demo
`Source code for syncmp3.rule from BeComm files re: test/demo
`Source code for timesync.rule from BeComm files re: test/demo
`Source code for unsyncaudio.rule from BeComm files re: test/demo
`Source code for unsyncmp3.rule from BeComm files re: test/demo
`Source code for videoclient.rule from BeComm files re: test/demo
`Source code for videomulti.rule from BeComm files re: test/demo
`Source code for videoserver.rule from BeComm files re: test/demo
`Copy of source code for clocksync.rule from BeComm files re:
`test/demo2
`
`3
`
`Exhibit
`2047
`2048
`2049
`2050
`2051
`2052
`2053
`2054
`2055
`2056
`2057
`2058
`2059
`2060
`2061
`2062
`2063
`2064
`2065
`2066
`2067
`2068
`2069
`2070
`2071
`2072
`2073
`2074
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`
`Case IPR2018-00767
`Patent No. 8,942,252
`
`Description
`Copy of source code for syncaudio.rule from BeComm files re:
`test/demo2
`Source code for mp3decoder.c from BeComm files
`Screen captures of metadata information for various exhibits
`Strings Source Code CVS log excerpts for synchronization.doc file.
`LinkedIn Profile of Angel Janevski, downloaded December 17,
`2001.
`Declaration of Atif Hashmi, Ph.D and Appendix 1
`Dr. Hashmi ’791 Patent Claim Chart
`Dr. Hashmi ’252 Patent Claim Chart
`Source code for timesync.rule from BeComm files re: test/demo2
`Source code for audiosync.c from BeComm files
`Source code for fanout.c from BeComm files
`Source code for sampleclock.c from BeComm files
`Source code for clocksync.c from BeComm files
`Source code for sampleclock.c from BeComm files
`2018 Annual Report of Sonos, Inc.
`Notice of Intent to Issue Subpoena to Larry Peterson
`Declaration of Edward Balassanian
`Excerpts of May 30, 2012 Deposition Transcript of Edward
`Balassanian
`Excerpts of March 11, 2019 Deposition Transcript (Rough) of
`Larry Peterson
`April 9, 2019 Deposition Transcript of Dr. Roman Chertov
`Patent Owner Demonstratives
`January 25, 2023 Conference Call Transcript
`Certificate of Correction to U.S. Patent No. 8,942,252
`
`Exhibit
`2075
`2076
`2077
`2078
`2079
`2080
`2081
`2082
`2083
`2084
`2085
`2086
`2087
`2088
`2089
`2090
`2091
`2092
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`2093
`2094
`2095
`2096
`2097
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`4
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`Date: February 10, 2023
`
`
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`
`
`Case IPR2018-00767
`Patent No. 8,942,252
`Respectfully submitted,
`
`
`
`
`/Timothy P. McAnulty/
`Timothy P. McAnulty, Reg. No. 56,939
`Finnegan, Henderson, Farabow,
` Garrett & Dunner, L.L.P.
`
`Counsel for Patent Owner
`Implicit, LLC
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`5
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`Case IPR2018-00767
`Patent No. 8,942,252
`
`CERTIFICATE OF SERVICE
`The undersigned certifies that a copy of the foregoing PATENT OWNER’S
`
`UPDATED EXHIBIT LIST and EXHIBIT 2097 were served electronically via
`
`email on February 10, 2023, in their entirety on the following:
`
`Rory P. Shea
`shea@ls3ip.com
`Cole B. Richter
`richter@ls3ip.com
`George I. Lee
`lee@ls3ip.com
`Michael P. Boyea
`boyea@ls3ip.com
`LEE SULLIVAN SHEA & SMITH LLP
`224 N. Desplaines St., Suite 250
`Chicago, IL 60661
`
`Petitioner has consented to service by electronic mail.
`
`
`
`
`
`/William Esper/
`William Esper
`Case Manager and PTAB Coordinator
`Finnegan, Henderson, Farabow,
` Garrett & Dunner, L.L.P.
`
`Dated: February 10, 2023
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