`
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`JUBILANT DRAXIMAGE INC.,
`Petitioner,
`v.
`
`BRACCO DIAGNOSTICS INC.,
`Patent Owner.
`______________
`
`Case IPR2018-01449
`U.S. Patent No. 9,299,467
`______________
`
`PATENT OWNER’S SUBMISSION OF
`PETITION FOR REVIEW OF ITC DECISION
`
`
`
`IPR2018-01449
`U.S. Patent No. 9,299,467
`
`Patent Owner’s Submission of Petition for Review
`
`Patent Owner submits herewith as Exhibit 2019, Bracco Diagnostics Inc.’s
`
`Petition for Review filed with the United States Court of Appeals for the Federal
`
`Circuit. The Petition for Review seeks to appeal the Commission Determination
`
`filed on December 2, 2019 in the United States International Trade Commission,
`
`Investigation No. 337-TA-1110.
`
`The Board authorized the instant filing by e-mail on January 13, 2020.
`
`A supplemental exhibit list is provided in the attached Appendix A.
`
`GREENBERG TRAURIG, LLP
`
`/s/ Heath J. Briggs
`Heath J. Briggs (Reg. No. 54,919)
`GREENBERG TRAURIG, LLP
`1144 15th Street, Suite 3300
`Denver, CO 80202
`briggsh@gtlaw.com
`Phone: (303) 572-6500
`Facsimile: (303) 572-6540
`
`Barry J. Schindler (Reg. No. 32,938)
`GREENBERG TRAURIG, LLP
`500 Campus Drive, Suite 400
`Florham Park, NJ 07932
`Telephone: (973) 360-7900
`Facsimile: (973) 301-8410
`SchindlerB@gtlaw.com
`
`Counsel for Patent Owner Bracco
`Diagnostics Inc.
`
`Dated: January 13, 2020
`
`Page 1 of 1
`
`
`
`IPR2018-01449
`U.S. Patent No. 9,299,467
`
`Patent Owner’s Submission of Petition for Review
`
`Appendix A
`
`2007
`
`2008
`
`2009
`
`Description
`Exhibit
`2001 U.S. Patent No. 6,767,319 to Reilly et al.
`2002 Comparison of U.S. Patent No. 6,767,319 to U.S. Patent Application
`Publication No. 2004/0260143 to Reilly et al.
`2003 Declaration of Dr. Norbert Pelc
`ITC Deposition of Dr. Robert Stone, October 9, 2018 (Redacted)
`2004
`ITC Deposition of Dr. Robert Stone, October 10, 2018 (Redacted)
`2005
`ITC Trial Testimony of Dr. Robert Stone, April 15, 2019 (Public
`2006
`Version)
`ITC Trial Testimony of Dr. Robert Stone, April 16, 2019 (Public
`Version)
`Errata of Dr. Robert Stone regarding Ex. 1015 of IPRs 2018-01448,
`-01449, and -01450
`Exhibit from Deposition of Dr. Robert Stone in IPRs 2018-01448,
`-01449, and -01450
`2010 Deposition testimony of Dr. Robert Stone in IPRs 2018-01448, -01449,
`and -01450
`ITC Corrected Expert Report of Dr. Norbert Pelc (Redacted)
`2011
`ITC Trial Testimony of Dr. Norbert Pelc (Public Version)
`2012
`ITC Trial Exhibits of Dr. Norbert Pelc (Redacted)
`2013
`2014 CAPINTEC CRC-15R User Manual, Nov. 2004
`2015 CAPINTEC CRC-15R User Manual, July 2007
`2016 Deposition testimony of Dr. Venkatesh Murthy in IPRs 2018-01448,
`-01449, and -01450
`Exhibit 1001 from Dr. Murthy’s Deposition (corrections to Ex. 1017)
`2017
`2018 Notice of Commission Determination to Review in Part a Final Initial
`Determination Finding No Section 337 Violation, filed on September
`30, 2019 in the United States International Trade Commission,
`Investigation No. 337-TA-1110
`2019 Bracco Diagnostics Inc.’s Petition for Review, filed on December 23,
`2019 in the United States Court of Appeals for the Federal Circuit
`
`
`
`
`
`
`
`
`
`
`
`IPR2018-01449
`U.S. Patent No. 9,299,467
`CERTIFICATE OF SERVICE
`
`Patent Owner’s Submission of Petition for Review
`
`I hereby certify that on this 13th day of January, 2020, a copy of this Patent
`
`Owner’s Submission of Petition for Review has been served in its entirety via
`
`electronic mail by emailing Petitioner’s lead and backup counsel at:
`
`Robert L. Hails
`rhails@bakerlaw.com
`T. Cy Walker
`cwalker@bakerlaw.com
`Theresa M. Weisenberger
`tweisenberger@bakerlaw.com
`Jubilant-Baker@bakerlaw.com
`
`as provided for by Petitioner’s listed Service Information in its Petition.
`
`
`
` Respectfully submitted,
`
` GREENBERG TRAURIG, LLP
`
`
`
`/s/ Heath J. Briggs
`Heath J. Briggs
`Registration No. 54,919
`1144 15th Street, Suite 3300
`Denver, CO 80202
`BriggsH@gtlaw.com
`Phone: (303) 572-6500
`Fax: (303) 572-6540
`
`
`
`Date: January 13, 2020
`
`
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