`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`NICHIA CORPORATION,
`
`Petitioner,
`
`v.
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`DOCUMENT SECURITY SYSTEMS, INC.,
`
`Patent Owner.
`
`____________________
`
`CASE NO. IPR2018-00965
`
`U.S. Patent No. 7,919,787
`
`____________________
`
`
`
`NICHIA CORPORATION’S RESPONSE TO EVERLIGHT
`ELECTRONICS CO., LTD.’S MOTION FOR JOINDER
`
`
`
`
`
`Pursuant to the Board’s Order dated September 18, 2018 (Paper No. 7 in
`
`IPR2018-01260; Paper No. 13 in IPR2018-00965), Nichia Corporation (“Nichia”)
`
`respectfully submits this response to Everlight Electronics Co., Ltd.’s (“Everlight”)
`
`Motion for Joinder of Everlight’s Inter Partes Review of U.S. Patent No.
`
`7,919,787 (“the ’787 patent”), Case No. IPR2018-01260 (“the Everlight IPR”),
`
`with Nichia’s Inter Partes Review of the ’787 patent, Case No. IPR2018-00965
`
`(“the Nichia IPR”).
`
`Since the Board’s Order granting permission for Everlight to file its motion
`
`to join the Nichia IPR, the Board has granted Everlight’s substantively identical
`
`motions for joinder, including in Case Nos. IPR2018-01225, IPR2018-01226, and
`
`IPR2018-01244, each of which involved patents owned by the same Patent Owner
`
`of the ’787 patent, Document Security Systems, Inc. (“DSS”). (Paper No. 14 in
`
`IPR2018-01225; Paper No. 15 in IPR2018-01226; Paper No. 15 in IPR2018-
`
`01244.)
`
`Accordingly, although Nichia maintains that joinder is inappropriate
`
`here because Nichia and Everlight are direct competitors and often have diverging
`
`interests, Nichia respects the Board’s recent decisions, and thus, does not
`
`oppose Everlight’s joinder request.
`
`
`
`
`
`
`
`
`2
`
`
`
`
`
`Dated: October 12, 2018
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Patrick R. Colsher/
`Patrick R. Colsher (Reg. No. 74,955)
`Shearman & Sterling LLP
`599 Lexington Ave
`New York, NY 10022
`Tel: (212) 848-7708
`Fax: (646) 848-7708
`Email: patrick.colsher@shearman.com
`
`Lead Counsel for Petitioner
`Nichia Corporation
`
`3
`
`
`
`Certificate of Service
`
`The undersigned hereby certifies that the foregoing document, NICHIA
`
`CORPORATION’S RESPONSE TO EVERLIGHT ELECTRONICS CO., LTD.’S
`
`MOTION FOR JOINDER, was served on October 12, 2018, via electronic mail
`
`upon the following:
`
`Wayne M. Helge
`Email: whelge@dbjg.com
`
`James T. Wilson
`Email: jwilson@dbjg.com
`
`Aldo Noto
`Email: anoto@dbjg.com
`
`Counsel for Document Security Systems, Inc.
`
`John Rabena
`Email: jrabena@sughrue.com
`
`William Mandir
`Email: wmandir@sughrue.com
`
`Counsel for Everlight Electronics Co., Ltd.
`
`
`
`
`
`/Patrick R. Colsher/
`Patrick R. Colsher (Reg. No. 74,955)
`Shearman & Sterling LLP
`599 Lexington Ave
`New York, NY 10022
`Tel: (212) 848-7708
`Fax: (646) 848-7708
`Email: patrick.colsher@shearman.com
`
`Lead Counsel for Petitioner
`Nichia Corporation
`
`
`
`
`
`
`
`
`
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