PGR2020-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 27
`Patent Owner’s Objections to Evidence
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`FLEX LOGIX TECHNOLOGIES INC,
`
`Petitioner
`
`V.
`
`VENKAT KONDA,
`
`Patent Owner
`
`____________
`
`Case PGR2019-00037
`
`Patent 10,003,553 B2
`
`_________
`
`
`
`
`PATENT OWNER’S OBJECTIONS TO EVIDENCE
`PURSUANT TO 37 C.F.R. §42.64
`
`
`
`
`
`
`
`
`
`Page 1 of 6
`
`Page 1 of 6 IPR2020-00260
`
`VENKAT KONDA EXHIBIT 2018
`
`
`Patent 10,003,553
`
`
`
`
`Paper No. 27
`Patent Owner’s Objections to Evidence
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`FLEX LOGIX TECHNOLOGIES INC,
`
`Petitioner
`
`V.
`
`VENKAT KONDA,
`
`Patent Owner
`
`____________
`
`Case PGR2019-00037
`
`Patent 10,003,553 B2
`
`_________
`
`
`
`
`PATENT OWNER’S OBJECTIONS TO EVIDENCE
`PURSUANT TO 37 C.F.R. §42.64
`
`
`
`
`
`
`
`
`
`Page 1 of 6
`
`Page 1 of 6 IPR2020-00260
`
`VENKAT KONDA EXHIBIT 2018
`
`
`
`PGR2020-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 27
`Patent Owner’s Objections to Evidence
`
`PATENT OWNER'S EXHIBIT LIST 1
`
`Exhibit No.
`
`Description
`
`CMOS Circuit Design Layout and Simulation, 3rd
`Edition
`PGR2019-00037 Petition – Paper 1
`PGR2019-00042 Petition – Paper 1
`Venkat Konda Declaration in support of Revised
`Motion to Amend
`IPR2020-00260 Petition – Paper 1
`Dr. Baker’s Declaration in support of the Petition
`IPR2020-00260 – Ex. 1002
`Dr. Baker’s CV in support of the Petition IPR2020-
`00260 – Ex. 1003
`IPR2020-00260 Patent Owner’s Preliminary
`Response – Paper 8
`
`Ex. 2001
`
`Ex. 2002
`Ex. 2003
`
`Ex. 2004
`
`Ex. 2005
`
`Ex. 2006
`
`Ex. 2007
`
`Ex. 2008
`
`
`
`Previously
`Submitted
`
`X
`
`X
`X
`X
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 2 of 6
`
`Page 2 of 6 IPR2020-00260
`
`VENKAT KONDA EXHIBIT 2018
`
`
`
`PGR2020-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 27
`Patent Owner’s Objections to Evidence
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner Venkat Konda (“Patent
`
`Owner”) submits the following objections to evidence served with the Petition for
`
`Post Grant review (“PGR”) PGR2019-000371 by Flex Logix Technologies Inc.
`
`(“Flex Logix” or “Petitioner”). Prior to this, Petitioner filed PGR2019-00037 filed
`
`on March 18, 2019 Paper 1 (“Petition”). After Patent Owner submitted Patent
`
`Owner’s Preliminary response (Paper 5), Board instituted PGR2019-00037 on
`
`September 19, 2019 (Paper 13). On May 15, 2020, Patent Owner submitted
`
`Revised Motion to Amend (Paper 25).
`
`In the Petition, Petitioner proposes that “A person of ordinary skill in the art
`
`(“POSITA”) at the time of the alleged invention of the ‘523 Patent would have had
`
`a master’s degree in electrical engineering or a similar field, and at least two to
`
`three years of experience with integrated circuits and networks. (Ex. 1002, ¶¶18)
`
`Petitioner acknowledges that “[M]ore education can supplement practical
`
`experience and vice versa. (Id.)”.” (Petition, at 6)
`
`However Petitioner’s witness, Dr. Baker states “All of my opinions stated
`
`in this declaration are based on my own personal knowledge and professional
`
`
`1 In addition to this PGR, the Board instituted another PGR2019-00042 filed
`
`by the same Petitioner concurrently on the ‘553 Patent.
`
`
`
`Page 3 of 6
`
`Page 3 of 6 IPR2020-00260
`
`VENKAT KONDA EXHIBIT 2018
`
`
`
`PGR2020-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 27
`Patent Owner’s Objections to Evidence
`
`judgment. In forming my opinions, I have relied on my knowledge and
`
`experience in designing, developing, researching, and teaching regarding
`
`circuit design and memory devices referenced in this declaration. (Ex. 1002,
`
`¶3). Notably Petitioner’s witness by his own admission has no experience in
`
`networks.
`
`Furthermore, in a related Petition IPR2020-00260 filed on December 16,
`
`2019 by Petitioner on a related US Patent No. 8,269,523 (“the ‘523 patent”) owned
`
`by the Patent Owner (Ex. 2005), the same declarant Dr. Baker submitted his
`
`declaration (Ex. 2006) and CV (Ex. 2007) in support of the Petition IPR2020-
`
`00260. In response to the petition IPR2020-00260, Patent owner submitted his
`
`Preliminary response on May 6, 2020 (Ex. 2008).
`
`In Section III of Ex. 2007, Patent Owner with the support of Patent Owner
`
`Venkat Konda’s Declaration submitted that the Petitioner presented a flawed
`
`Definition of a Person Of Ordinary Skill In The Art to accommodate its
`
`unqualified witness (Ex. 2008, at 11-20) with illustration of several errors made by
`
`Dr. Baker.
`
`Accordingly, Patent Owner objects to Ex. 1002, Ex. 1003 and all the support
`
`presented in the Petition by Ex. 1002 and Ex. 1003. Pursuant to 37 C.F.R. § 42.11
`
`and 37 C.F.R. § 42.51(b)(iii), Patent Owner requests the Board to exclude Ex.
`
`
`
`Page 4 of 6
`
`Page 4 of 6 IPR2020-00260
`
`VENKAT KONDA EXHIBIT 2018
`
`
`
`PGR2020-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 27
`Patent Owner’s Objections to Evidence
`
`1002, Ex. 1003 and all the support presented in the Petition by Ex. 1002 and Ex.
`
`1003.
`
`Date: May 20, 2020
`
`Respectfully submitted,
`
`
`
`
`
`/Venkat Konda/
`Venkat Konda
`Pro Se Counsel
`6278 Grand Oak Way
`San Jose, CA 95135
`
`
`
`Page 5 of 6
`
`Page 5 of 6 IPR2020-00260
`
`VENKAT KONDA EXHIBIT 2018
`
`
`
`PGR2020-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 27
`Patent Owner’s Objections to Evidence
`
`CERTIFICATE OF SERVICE
`
`
`
`Pursuant to 37 C.F.R. § 42.6(e) and consent of the Petitioner, I certify that
`
`on May 20, 2020, a copy of Patent Owner’s Objections to Evidence was served on
`
`counsel of record for Petitioner by email to PH-FlexLogix-Konda-
`
`PGR@paulhastings.com
`
`
`
`Dated: May 20, 2020
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/Venkat Konda/
`Venkat Konda
`Pro Se Counsel
`
`
`
`
`
`
`
`
`
`
`
`Page 6 of 6
`
`Page 6 of 6 IPR2020-00260
`
`VENKAT KONDA EXHIBIT 2018
`
`
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
