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IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`)
`)
`)
`)
`)
`)
`)
`)
`
`Plaintiff,
`
`Defendant.
`
`
`
`
`C.A. No. 18-452 (WCB)
`
`
`
`IOENGINE, LLC,
`
`
`
`
`
`
`PAYPAL HOLDINGS, INC.,
`
`
`
`v.
`
`
`
`
`
`DEFENDANT PAYPAL HOLDINGS, INC.’S FIRST SUPPLEMENTAL
`INITIAL INVALIDITY CONTENTIONS
`
`Pursuant to Paragraph 4(d) of the District of Delaware Default Standard for Discovery,
`
`including Discovery of Electronically Stored Information (“ESI”) (“Default Standard”),
`
`Defendant PayPal Holdings, Inc. (“PayPal”) hereby supplements
`
`its Initial Invalidity
`
`Contentions, served on April 5, 2019, which are incorporated by reference in their entirey.
`
`PayPal’s Initial Invalidity Contentions, served on April 5, 2019, stated the following on
`
`pages 3-4:
`
`PayPal also reserves the right to rely on any documents produced, prior art identified, and
`invalidity contentions or challenges made, by PayPal or other parties in prior litigations
`or proceedings, or in any pending or future litigations or proceedings, involving any of
`the asserted patents (or related patents or applications), including any reexamination,
`inter partes review, or other challenge to the patentability of the subject matter of the
`asserted patents at any patent office. Such litigations or proceedings include, but are not
`limited to: IOENGINE LLC v. Interactive Media Corp., Case No. 14-1571 (D. Del.);
`IOENGINE LLC v. GlassBridge Enterprises, Inc., Case No. 14-1572 (D. Del.); Ingenico
`Inc. v. IOENGINE LLC, Case No. 18-452 (D. Del.); IPR2019-00416; IPR2019-00584;
`IPR2019-00879; IPR2019-00884; IPR2019-00885; IPR2019-00886; IPR2019-00887;
`IPR2019-00906; IPR2019-00907; IPR2019-00930; and IPR2019-00931.
`
`For avoidance of doubt, PayPal expressly incorporates IPR2019-00929, which was filed on April
`
`5, 2019, the same day PayPal’s Initial Invalidity Contentions were served.
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2083
`
`

`

`
`
`
`
`
`
`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
`
`/s/ Brian P. Egan
`
`
`
`
`Jack B. Blumenfeld (#1014)
`Brian P. Egan (#6227)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899
`(302) 658-9200
`jblumenfeld@mnat.com
`began@mnat.com
`
`Attorneys for Defendant
`
`
`
`
`
`
`
`
`
`
`
`
`
`OF COUNSEL:
`
`Jared Bobrow
`Travis Jensen
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`1000 Marsh Road
`Menlo Park, CA 94025-1015
`(650) 614-7400
`
`April 17, 2019
`
`2
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2083
`
`

`

`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on April 17, 2019, copies of the foregoing were caused to be served
`
`upon the following in the manner indicated:
`
`VIA ELECTRONIC MAIL
`
`VIA ELECTRONIC MAIL
`
`VIA ELECTRONIC MAIL
`
`VIA ELECTRONIC MAIL
`
`/s/ Brian P. Egan
`
`
`
`
`Brian P. Egan (#6227)
`
`
`
`
`
`
`
`Neal C. Belgam, Esquire
`Eve H. Ormerod, Esquire
`SMITH, KATZENSTEIN & JENKINS, LLP
`1000 West Street, Suite 1501
`Wilmington, DE 19801
`Attorneys for Plaintiff
`
`Noah M. Leibowitz, Esquire
`Gregory T. Chuebon, Esquire
`DECHERT LLP
`Three Bryant Park
`1095 Avenue of the Americas
`New York, NY 10036-6797
`Attorneys for Plaintiff
`
`Derek J. Brader, Esquire
`DECHERT LLP
`Cira Centre
`2929 Arch Street
`Philadelphia, PA 19104-2808
`Attorneys for Plaintiff
`
`Michael H. Joshi, Esquire
`DECHERT LLP
`2440 West El Camino Real, Suite 700
`Mountain View, CA 94040
`Attorneys for Plaintiff
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2083
`
`

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