`________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
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`LG ELECTRONICS INC.,
`Petitioner,
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`v.
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`IMMERVISION, INC.,
`Patent Owner.
`____________
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`Case No. IPR2020-00195
`U.S. Patent No. 6,844,990 B2
`____________
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`PETITIONER’S NOTICE OF APPEAL
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`Petitioner’s Notice of Appeal
`Case IPR2020-00195
`U.S. Patent No. 6,844,990 B2
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`In accordance with 35 U.S.C. §§ 141-142 and 37 C.F.R. § 90.2, LG
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`Electronics Inc. (“Petitioner”) hereby appeals to the United States Court of Appeals
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`for the Federal Circuit (the “Court”) for review of the Judgment/Final Written
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`Decision of the Patent Trial and Appeal Board (the “Board”), entered on May 11,
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`2021, (the “Final Decision,” Paper 26), and from all underlying orders, decisions,
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`rulings, and opinions related to the Final Decision.
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`For the limited purpose of providing the Director of the United States Patent
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`and Trademark Office with the information required under 37 C.F.R. § 90.2(a)(3)(ii),
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`Petitioner anticipates that the issues on appeal will include, but are not limited to:
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`1. Whether the Board legally erred in holding Petitioner failed to
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`demonstrate by a preponderance of the evidence that the subject matter of claim 21
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`of U.S. Patent No. 6,844,990 B2 is unpatentable;
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`2. Whether substantial evidence fails to support the Board’s factual
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`findings underlying its holding that the subject matter of claim 21 of U.S. Patent No.
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`6,844,990 B2 is not unpatentable;
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`3. Whether the Board legally erred in applying the Court’s precedent in
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`analyzing whether there is an obvious error in the prior art; and
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`4. Whether substantial evidence fails to support the Board’s factual
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`findings that the prior art contains an obvious error.
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`1
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`Petitioner’s Notice of Appeal
`Case IPR2020-00195
`U.S. Patent No. 6,844,990 B2
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`Contemporaneously with this submission, a copy of the Notice of Appeal is
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`being filed electronically with the Patent Trial and Appeal Board. In addition, a
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`copy of this Notice of Appeal, along with the required docketing fees, is being
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`electronically filed with the Clerk’s Office for the United States Court of Appeals
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`for the Federal Circuit.
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`Dated: June 4, 2021
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`Respectfully submitted,
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` /Dion M. Bregman/
`Dion M. Bregman (Reg. No. 45,645)
`Morgan, Lewis & Bockius LLP
`1400 Page Mill Road
`Palo Alto, CA 94304
`T: +1.650.843.7519
`F: +1.650.843.4001
`dion.bregman@morganlewis.com
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`Attorneys for Petitioner
`LG Electronics Inc.
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`2
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`CERTIFICATE OF SERVICE
`In accordance with 37 CFR § 90.2(a)(1) and § 104.2, I hereby certify that on
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`June 4, 2021, in addition to being filed electronically through the Board’s E2E
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`System, the original version of the foregoing, Petitioner’s Notice of Appeal was filed
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`by USPS Priority Mail on the Director of the United States Patent and Trademark
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`Office, at the following address:
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`Director of the United States Patent and Trademark Office
`Office of the General Counsel
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
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` hereby certify that on June 4, 2021, a true and correct copy of the foregoing,
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` I
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`Petitioner’s Notice of Appeal, along with a copy of the Final Written Decision, was
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`filed electronically with the Clerk’s Office of the United States Court of Appeals for
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`the Federal Circuit, at the following address:
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`Clerk of Court
`United States Court of Appeals for the Federal Circuit
`717 Madison Place, N.W., Room 401
`Washington, DC 20439
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`Pursuant to 37 CFR § 42.6(e), the undersigned certifies that on June 4, 2021,
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`a complete and entire copy of this Petitioner’s Notice of Appeal was served by
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`FedEx Priority Overnight Delivery and via email, to the Patent Owner at the
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`following addresses:
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`3
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`Dated: June 4, 2021
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`Stephen E. Murray, Reg. No. 63,206
`Keith A. Jones, Reg. No. 67,781
`PANITCH SCHWARZE BELISARIO
`& NADEL LLP
`Two Commerce Square
`2001 Market Street, Suite 2800
`Philadelphia, Pennsylvania 19103
`(215) 965-1330
`(215) 965-1331 (Fax)
`smurray@panitchlaw.com
`kjones@panitchlaw.com
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`John D. Simmons, Reg. No. 52,225
`Dennis J. Butler, Reg. No. 51,519
`PANITCH SCHWARZE BELISARIO
`& NADEL LLP
`Wells Fargo Tower
`2200 Concord Pike, Suite 201
`Wilmington, DE 19803
`(302) 394-6030
`(302) 394-6031 (Fax)
`jsimmons@panitchlaw.com
`dbutler@panitchlaw.com
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` /Dion M. Bregman/
`Dion M. Bregman (Reg. No. 45,645)
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`4
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