Filed on behalf of: Apple Inc.
`
`
`
`
`
`
`
`
`
`Entered: March 22, 2019
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________________
`
`APPLE INC.,
`Petitioner,
`v.
`AGIS SOFTWARE DEVELOPMENT LLC,
`Patent Owner.
`
`Case IPR2019-00523
`U.S. Patent No. 9,445,251
`
`PETITIONER’S EXHIBIT LIST
`
`
`
`
`
`
`
`
`
`
`
`Entered: March 22, 2019
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________________
`
`APPLE INC.,
`Petitioner,
`v.
`AGIS SOFTWARE DEVELOPMENT LLC,
`Patent Owner.
`
`Case IPR2019-00523
`U.S. Patent No. 9,445,251
`
`PETITIONER’S EXHIBIT LIST
`
`
`
`IPR2019-00523 (USP 9,445,251)
`
`
`Petitioner’s Exhibit List
`
`
`
`Pursuant to 37 C.F.R. § 42.63(e), Petitioner Apple Inc. (“Petitioner”)
`
`respectfully submits the following current exhibit list:
`
`1002
`
`1003
`1004
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`Exhibit No. Description
`1001
`U.S. Patent No. 9,445,251 to Beyer, Jr. et al., issued September 13,
`2016 (“’251 Patent”)
`File History of U.S. Patent No. 9,445,251 (“’251 Patent File
`History”)
`Declaration of David Hilliard Williams (“Williams”)
`Curriculum Vitae of David Hilliard Williams
`U.S. Patent No. 6,366,782 to Fumarolo et al., issued April 2, 2002
`(“Fumarolo-782”)
`U.S. Patent No. 6,204,844 to Fumarolo et al., issued March 20,
`2001 (“Fumarolo-844”)
`U.S. Patent Application Publication No. 2002/0173906 to
`Muramatsu, published November 21, 2002, (“Muramatsu”)
`U.S. Patent Application Publication No. 2002/0027901 to Liu et
`al., issued March 7, 2002 (“Liu”)
`Plaintiff’s Original Complaint for Patent Infringement, AGIS
`Software Development LLC v. Huawei Device USA Inc., et al.,
`Case No. 2:17-cv-00513 (TXED), filed June 21, 2017.
`(“Infringement Complaint”)
`U.S. Patent No. 7,031,728 to Beyer, Jr., issued April 18, 2006
`(“’728 Patent”)
`U.S. Patent No. 7,630,724 to Beyer, Jr. , et al., issued December 8,
`2009 (“’724 Patent”)
`911 and E911 Services, Federal Communications Commission,
`www.fcc.gov/e911 (last visited May 7, 2018)
`Fact Sheet, FCC Wireless 911 Requirements (January 2001),
`available at https://transition.fcc.gov/pshs/services/911-
`services/enhanced911/archives/factsheet_requirements_012001.pdf
`Jock Christie, et al., Development and Deployment of GPS Wireless
`Devices for E911 and Location Based Services (Position, Location,
`and Navigation Symposium, 2002) (“Christie”)
`Dale N. Hatfield, A Report on Technical and Operational Issues
`Impacting The Provision of Wireless Enhanced 911 Services,
`Federal Communications Commission (2002) (“Hatfield”)
`
`1014
`
`1015
`
`
`
`1
`
`
`
`IPR2019-00523 (USP 9,445,251)
`
`
`Petitioner’s Exhibit List
`
`1017
`
`1018
`
`1019
`1020
`
`1021
`
`1022
`
`Exhibit No. Description
`1016
`Charles E. Perkins, “Ad Hoc Networking.” Nokia Research Center
`(November 28, 2000) (“Perkins”)
`Duncan Scott Sharp, Adapting Ad Hoc Network Concepts to Land
`Mobile Radio Systems (1972 Ph.D. dissertation, University of
`Alberta) (on file with Simon Fraser University, December 2002)
`(“Duncan”)
`Madhavi W. Subbarao, Mobile Ad Hoc Data Networks for
`Emergency Preparedness Telecommunications - Dynamic Power-
`Conscious Routing Concepts (Submitted as an interim project for
`Contract Number DNCR086200 to the National Communications
`Systems, February 1, 2000) (“Subbarao”)
`Intentionally Left Blank
`McKinsey & Company, The McKinsey Report : FDNY 9/11
`Response (2002) (“The McKinsey Report”)
`William K. Rashbaum, Report on 9/11 Finds Flaws In Response of
`Police Dept., N.Y. Times (July 27, 2002), available at
`http://www.nytimes.com/2002/07/27/nyregion/report-on-9-11-
`finds-flaws-in-response-of-police-dept.html?mcubz=0
`Fred Durso, Jr., A Decade of Difference, NFPA Journal (Sept. 1,
`2011), available at http://www.nfpa.org/news-and-
`research/publications/nfpa-journal/2011/september-october-
`2011/features/a-decade-of-difference
`Rick Rotondo, “Locate-Track-Extract; Wireless Mesh Networking
`Allows Commanders to Keep Track of Firefighters at an Incident
`Scene,” Mission Critical Communications, March 2004
`U.S. Patent Publication No. 2003/0100326 to Grube et al.,
`published May 29, 2003 (“Grube”)
`U.S. Patent No. 6,654,683 to Jin et al., issued November 25, 2003
`(“Jin”)
`U.S. Patent No. 6,119,017 to Cassidy et al., issued September 12,
`2000 (“Cassidy”)
`U.S. Patent No. 5,563,931 to Bishop et al., issued October 8, 1996
`(“Bishop”)
`
`1023
`
`1024
`
`1025
`
`1026
`
`1027
`
`
`
`2
`
`
`
`IPR2019-00523 (USP 9,445,251)
`
`
`Petitioner’s Exhibit List
`
`1029
`
`Exhibit No. Description
`1028
`Ching-Chien Chen, et al., Automatically and Accurately Conflating
`Satellite Imagery and Maps (University of Southern California,
`October 2003) (“Chen”)
`Computer-generated redline comparison between petition in
`IPR2018-01083 and instant Petition
`Computer-generated redline comparison between Williams
`Declaration (Google 1003) ff IPR2018-01083 and Williams
`Declaration (Exhibit 1003) attached hereto
`Settlement and License Agreement (Parties and Board only)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`1030
`
`1031
`
`
`
`
`Dated: March 22, 2019
`
`
`
`
`
`By: / Matthew J. Moore /
`
`Matthew J. Moore (Reg. No. 42,012)
`Jonathan M. Strang (Reg. No. 61,724)
`Robert Steinberg (Reg. No. 33,144)
`Latham & Watkins LLP
`555 Eleventh Street, NW, Ste. 1000
`Washington, DC 20004-1304
`Tel.: 202.637.2200
`matthew.moore@lw.com
`jonathan.strang@lw.com
`bob.steinberg@lw.com
`
`Lisa K. Nguyen (Reg. No. 58,018)
`Latham & Watkins LLP
`140 Scott Drive
`Menlo Park, CA 94025
`Tel.: 650.470.4848
`lisa.nguyen@lw.com
`
`Counsel for Petitioner
`
`3
`
`
`
`
`
`
`
`
`IPR2019-00523 (USP 9,445,251)
`
`Petitioner’s Exhibit List
`
`
`
`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), I certify that on this 22nd day of March,
`
`2019, a copy of Petitioner’s Exhibit List and Exhibit 1031 were served by
`
`electronic mail on Patent Owner’s lead and backup counsel at the following email
`
`
`
`addresses:
`
`Vincent J. Rubino, III (Reg. No. 68,594)
`Alfred R. Fabricant (pro hac vice to be filed)
`Peter Lambrianakos (Reg. No. 58,279)
`Enrique W. Iturralde (Reg. No. 72,883)
`BROWN RUDNICK LLP
`7 Times Square
`New York, NY 10036
`212.209.4800
`vrubino@brownrudnick.com
`afabricant@brownrudnick.com
`plambrianakos@brownrudnick.com
`eiturralde@brownrudnick.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By: / Matthew J. Moore /
`
`Matthew J. Moore (Reg. No. 42,012)
`Latham & Watkins LLP
`555 Eleventh Street, NW, Ste. 1000
`Washington, DC 20004-1304
`202.637.2200
`matthew.moore@lw.com
`
`Counsel for Petitioner
`Apple Inc.
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
