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`Filed: May 12, 2020
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________
`
`ZTE (USA) INC.,
`
`PETITIONER,
`
`V.
`
`BELL NORTHERN RESEARCH, LLC,
`
`PATENT OWNER.
`___________________
`
`Case No. IPR2019-01365
`U.S. Patent No. 7,039,435
`___________________
`
`
`
` PATENT OWNER’S UPDATED EXHIBIT LIST
`
`
`
`PATENT OWNER’S UPDATED EXHIBIT LIST
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`
`
`Patent Owner Bell Northern Research, LLC hereby submits its updated
`
`exhibit list to accompany the submission of Exhibits 2022-2029:
`
`EXHIBIT
`2001.
`
`2002.
`
`2003.
`
`2004.
`
`DESCRIPTION
`
`Bell Northern Research, LLC v. ZTE Corporation, et al., No. 18-cv-1786-
`CAB(BLM), Scheduling Order Regulating Discovery and Other Pretrial
`Proceedings.
`
`Bell Northern Research, LLC v. ZTE Corporation, et al., No. 18-cv-1786-
`CAB(BLM), Defendants’ Second Amended Joint Invalidity Contentions.
`
`Lee, William. “Mobile Communications Engineering – Theory and
`Applications.” (1997)
`
`Bell Northern Research, LLC v. ZTE Corporation, et al., No. 18-cv-1786-
`CAB(BLM), June 19, 2019, Claim Construction Hearing Transcript.
`
`2005.
`
`Bell Northern Research, LLC v. ZTE Corporation, et al., No. 18-cv-1786-
`CAB(BLM), August 9, 2019, Claim Construction Order.
`2006. U.S. Patent No. 6,498,924 to Vogel.
`2007.
`
`Excerpt of United States District Court Southern District of California,
`Patent Local Rules.
`
`2008.
`
`2009.
`
`2010.
`
`2011.
`
`Bell Northern Research, LLC v. Huawei Device USA, Inc., et al., No.
`3:18-cv-1784-CAB(BLM), Order on the Joint Motion Concerning the
`May 15, 2019 Executive Order with Regard to Huawei.
`
`Bell Northern Research, LLC v. ZTE Corporation, et al., No. 18-cv-1786-
`CAB(BLM), Philip Mooney Deposition Transcript.
`
`Bell Northern Research, LLC v. ZTE Corporation, et al., No. 18-cv-1786-
`CAB(BLM), Philip Mooney Deposition, Exhibit 8.
`
`Bell Northern Research, LLC v. ZTE Corporation, et al., No. 18-cv-1786-
`CAB(BLM), Richard McDowell Deposition Transcript.
`
`1
`
`
`
`EXHIBIT
`2012.
`
`2013.
`
`2014.
`
`DESCRIPTION
`
`Bell Northern Research, LLC v. ZTE Corporation, et al., No. 18-cv-1786-
`CAB(BLM), Richard McDowell Deposition Exhibit 9.
`
`Bell Northern Research, LLC v. ZTE Corporation, et al., No. 18-cv-1786-
`CAB(BLM), Richard McDowell Deposition Exhibit 8.
`
`Bell Northern Research, LLC v. ZTE Corporation, et al., No. 18-cv-1786-
`CAB(BLM), Philip Mooney Deposition, Exhibit 12.
`
`2015.
`
`Bell Northern Research, LLC v. ZTE Corporation, et al., No. 18-cv-1786-
`CAB(BLM), Philip Mooney, Deposition Exhibit 9.
`2016. McGraw-Hill Dictionary of Scientific and Technical Terms, 6th Edition.
`2017.
`Expert Declaration of Mark Horenstein, Ph.D.
`2018. Curriculum Vitae of Mark Horenstein, Ph.D.
`2019.
`2020.
`Excerpt from Opening Expert Report of Jonathan Wells, Ph.D., M.B.A.
`2021. Radio Access for Third Generation Mobile Communications, 3rd Ed, H.
`Holma and A. Toskala, Eds. West Sussex, England: 2004 John Wiley and
`Sons.
`
`IEEE Standard Dictionary of Electrical and Electronics Terms.
`
`2022.
`
`Expert Declaration of Mark Horenstein, Ph.D., in support of Patent
`Owner Response
`2023. Cross Examination of Dr. Jonathan Wells (excerpted transcript of the
`December 19, 2019 deposition of Dr. Wells in Bell Northern Research,
`LLC v. Coolpad Technologies, Inc., et al., No. 3:18-cv 1783-
`CAB(BLM) and Bell Northern Research, LLC v. ZTE Corporation., et
`al., No. 3:18-cv- 1786-CAB(BLM) in the Southern District of
`California.
`Protective Order Material – Attorneys Eyes Only
`License Agreement between LSI Logic Corp. and LG Electronics (2013)
`Protective Order Material – Attorneys Eyes Only
`Declaration of Chad Hilyard
`
`2024.
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`2025.
`
`2
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`
`
`EXHIBIT
`2026. RESERVED
`Protective Order Material – Attorneys Eyes Only
`2027.
`License Agreement between Bell Northern Research LLC and Huawei
`
`DESCRIPTION
`
`2028.
`IDC Data on Phones – Cover Page Showing Company Market Share
`2029. Curriculum Vitae of Dr. Mark Horenstein, Ph.D.
`
`
`
`
`
`3
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`
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`Dated: May 12, 2020
`
`
`
`
`Respectfully Submitted,
`
`/Steven W. Hartsell/
`Steven W. Hartsell (Reg. No. 58,788)
`SKIERMONT DERBY LLP
`1601 Elm St., Ste. 4400
`Dallas, Texas 75201
`P: 214-978-6600/F: 214-978-6601
`Lead Counsel for Patent Owner
`
`Alexander E. Gasser (Reg. No. 48,760)
`SKIERMONT DERBY LLP
`1601 Elm St., Ste. 4400
`Dallas, Texas 75201
`P: 214-978-6600/F: 214-978-6621
`Back-Up Counsel for Patent Owner
`
`4
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`
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`CERTIFICATE OF SERVICE
`
`I certify that I caused to be served on the counsel for Petitioner a true and
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`correct copy of the foregoing Patent Owner’s Updated Exhibit List, by electronic
`
`means on May 12, 2020 at the following address of record:
`
`Respectfully Submitted,
`
`/Steven W. Hartsell/
`Steven W. Hartsell (Reg. No. 58,788)
`Counsel for Patent Owner
`
`Amol A. Parikh
`Charles M. McMahon
`Thomas M. DaMario
`Jiaxiao Zhang
`ZTEBNR-PTAB@mwe.com
`
`Dated: May 12, 2020
`
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