`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________
`
`LG ELECTRONICS, INC.,
`
`PETITIONER,
`
`V.
`
`BELL NORTHERN RESEARCH, LLC,
`
`PATENT OWNER.
`___________________
`Case No. IPR2020-00319
`U.S. Patent No. 7,039,435
`___________________
`
`PATENT OWNER’S UPDATED EXHIBIT LIST
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`
`
`PATENT OWNER’S EXHIBIT LIST
`
`Patent Owner Bell Northern Research, LLC hereby submits its updated
`
`exhibit list to accompany the submission of Exhibit 2018-2020:
`
`EXHIBIT
`2001
`
`DESCRIPTION
`Scheduling Order Regulating Discovery and Other Pretrial Proceedings
`dated February 5, 2020 (Dkt. No. 103), Bell Northern Research, LLC v.
`LG Electronics, Inc., et al., C.A. No. 3:18-cv-2864
`
`2002
`
`2003
`
`2004
`
`2005
`
`2006
`
`2007
`
`Excerpts from the LG Defendants’ Second Amended Invalidity
`Contentions served March 10, 2020, Bell Northern Research, LLC v. LG
`Electronics, Inc., et al., C.A. No. 3:18-cv-2864
`
`Declaration of Mark Horenstein, Ph.D.
`
`Curriculum Vitae of Mark N. Horenstein, Ph.D.
`
`Excerpt from Lee, Mobile Communications Engineering, Theory and
`Applications, Second Edition (1998)
`
`Excerpt from Holma, WCDMA for UMTS, Radio Access for Third
`Generation Mobile Communications, Third Edition (2004)
`
`Transcript from June 19, 2019 Claim Construction Hearing for the
`Consolidated Defendants, Bell Northern Research, LLC v. Coolpad
`Technologies, Inc., et al., C.A. Nos. 3:18-cv-1783, 3:18-cv-1784, 3:18-
`cv-1785, 3:18-cv-1786
`
`2008
`
`[Reserved]
`
`1
`
`
`
`EXHIBIT
`2009
`
`DESCRIPTION
`Excerpts from Joint Motion to Extend the Case Management Order filed
`March 20, 2020 (Dkt. No. 115), Bell Northern Research, LLC v. LG
`Electronics, Inc., et al., C.A. No. 3:18-cv-2864
`
`2010
`
`2011
`
`2012
`
`2013
`
`2014
`
`Excerpts from the LG Defendants’ Amended Invalidity Contentions
`served November 15, 2019, Bell Northern Research, LLC v. LG
`Electronics, Inc., et al., C.A. No. 3:18-cv-2864
`
`Answer of Huawei Defendants dated October 31, 2018 (Dkt. No. 31),
`Bell Northern Research, LLC v. LG Electronics, Inc., et al., C.A. No.
`3:18-cv-1784
`
`Answer and Counterclaims of LG Defendants dated April 17, 2019
`(Dkt. No. 15), Bell Northern Research, LLC v. LG Electronics, Inc., et
`al., C.A. No. 3:18-cv-2864
`
`Excerpts from Huawei Defendants’ Invalidity Contentions served
`February 25, 2019, Bell Northern Research, LLC v. Huawei Device
`(Dongguan) Co. Ltd., et al., C.A. No. 3:18-cv-1784
`
`Excerpts from the LG Defendants’ Invalidity Contentions served August
`9, 2019, Bell Northern Research, LLC v. LG Electronics, Inc., et al.,
`C.A. No. 3:18-cv-2864
`
`2015
`
`Excerpts of comparison between IPR2019-01186, Paper 2 at 39-47 and
`LG’s Petition at 38-48.
`
`2016
`
`Declaration of Afzal Dean FILED UNDER SEAL
`
`2
`
`
`
`EXHIBIT
`2017
`
`DESCRIPTION
`Bell Northern Research, LLC, v. LG Electronics Inc., et al., Case No.
`18-CV-2864-CAB-BLM, Order on Joint Motion to Continue Discovery
`Dates and Mandatory Settlement Conference dated March 24, 2020
`
`2018
`
`2019
`
`2020
`
`Excerpt from Bell Northern Research, LLC’s Patent L.R. 3.1 Disclosure
`of Asserted Claims and Infringement Contentions dated June 11, 2018,
`Bell Northern Research, LLC v. LG Electronics, Inc., et al., C.A. 3:18-
`cv-02864-CAB-BLM
`
`Excerpt from Bell Northern Research, LLC’s Patent L.R. 3.6 Amended
`Disclosure of Asserted Claims and Infringement Contentions dated
`October 4, 2019, Bell Northern Research, LLC v. LG Electronics, Inc.,
`et al., C.A. 3:18-cv-02864-CAB-BLM
`
`Excerpt from Bell Northern Research, LLC’s Patent L.R. 3.6 Amended
`Disclosure of Asserted Claims and Infringement Contentions dated
`February 20, 2020, Bell Northern Research, LLC v. LG Electronics, Inc.,
`et al., C.A. 3:18-cv-02864-CAB-BLM
`
`
`
`
`
`3
`
`
`
`Dated: April 29, 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
`
`correct copy of the foregoing Patent Owner’s Updated Exhibit List, by electronic
`
`means on April 29, 2020 at the following address of record:
`
`Timothy W. Riffe
`riffe@fr.com
`Christopher C. Hoff
`hoff@fr.com
`R. Andrew Schwentker
`schwentker@fr.com
`PTABInbound@fr.com
`IPR18768-0183IP1@fr.com
`
`Dated: April 29, 2020
`
`
`
`Respectfully Submitted,
`
`/Steven W. Hartsell/
`Steven W. Hartsell (Reg. No. 58,788)
`Counsel for Patent Owner
`
`5
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`