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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
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`Intel Corporation
`Petitioner
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`v.
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`ParkerVision, Inc.
`Patent Owner
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`__________________________________________________
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`Case No. IPR2020-01265
`U.S. Patent No. 7,110,444
`__________________________________________________
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`PETITIONER’S IDENTIFICATION OF IMPROPER NEW EVIDENCE
`AND ARGUMENTS IN SUR-REPLY
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`Pursuant to the Board’s Order (Paper 31), Petitioner hereby identifies the
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`Case No. IPR2020-01265
`U.S. Patent No. 7,110,444
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`following arguments and evidence in Patent Owner’s Sur-Reply as exceeding the
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`proper scope of a sur-reply.
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`Petitioner’s Identification of Improper Arguments
`and Evidence in Patent Owner’s Sur-Reply (Paper 26)
`Paper 26 at page 1, line 5 parenthetical (“near zero”)
`Paper 26 at page 1, lines 7-11
`Paper 26 at page 7, line 10 parenthetical (“near zero”)
`Paper 26 at page 15, lines 3-6
`Paper 26 at page 15, lines 7-9
`Paper 26 at page 15, lines 7-9 (including the following
`figure on page 16)
`Paper 26 at page 16, lines 1-8 following the figure
`Paper 26 at page 17, line 7 parenthetical (“near zero”)
`Paper 26 at page 17, line 9 to page 18, line 2 (including
`footnote 14)1
`Paper 26 at page 18, lines 3-5 (including footnote 15)
`Paper 26 at page 18, lines 7-9
`Paper 26 at page 19, lines 1-4
`Paper 26 at page 20, lines 4-8
`Paper 26 at page 20, lines 9-13 (including footnote 17)
`Paper 26 at page 20, line 14 to page 21, line 6
`Paper 26 at page 21, lines 7-9
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`1 Footnotes are excluded from line ranges unless otherwise specified.
`2
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`Case No. IPR2020-01265
`U.S. Patent No. 7,110,444
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`Paper 26 at page 21, lines 10-15
`Paper 26 at page 21, line 19 to page 22, line 8
`Paper 26 at page 22, lines 9-13 (counting equation on line
`13 as one line)
`Paper 26 at page 22, line 14 to page 23, line 2 (including
`footnote 18)
`Paper 26 at page 23, lines 3-4 (including the following
`figure)
`Paper 26 at page 23, line 5 (first line following the figure)
`to page 24, line 2
`Paper 26 at page 24, lines 3-16 (including footnote 19)
`Paper 26 at page 25, lines 1-5 (counting equation on line
`5 as one line)
`Paper 26 at page 25, lines 6-8
`Paper 26 at page 27, lines 5-14 to page 28, line 3
`Paper 26 at page 28, lines 1-3
`Ex. 2022 (entire exhibit)2
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`2 Ex. 2022 is cited in Patent Owner’s Sur-Reply (Paper 26) at page 18, footnote
`14 and at page 21, line 14
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`3
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`Case No. IPR2020-01265
`U.S. Patent No. 7,110,444
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`Respectfully Submitted,
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`/Brian J. Lambson/
`Brian J. Lambson, Reg. No. 72,570
`Wilmer Cutler Pickering
` Hale and Dorr LLP
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`Dated: October 1, 2021
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`Case No. IPR2020-01265
`U.S. Patent No. 7,110,444
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`CERTIFICATE OF SERVICE
`I hereby certify that on October 1, 2021, I caused a true and correct copy of
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`the foregoing document to be served via electronic mail on the following counsel
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`of record for Patent Owner:
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`jcharkow@daignaultiyer.com
`cbiyer@daignaultiyer.com
`smandir@daignaultiyer.com
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`Respectfully submitted,
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`/Brian J. Lambson/
`Brian J. Lambson
`Registration No. 72,570
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