`
`
`
`Paper No. 21
`Filed: April 28, 2021
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`INTEL CORPORATION,
`Petitioner
`v.
`FG SRC LLC,
`Patent Owner
`____________________
`CASE NO.: IPR2020-01449
`PATENT NO. 7,149,867
`____________________
`PETITIONER’S MOTION TO SUBMIT SUPPLEMENTAL
`INFORMATION PURSUANT TO 37 C.F.R. § 42.123(a)
`
`
`
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`TABLE OF SUPPLEMENTAL INFORMATION EXHIBITS
`
`Description
`Exhibit No.
`Exhibit 1027 Declaration of Gordon MacPherson
`Exhibit 1028 Declaration of Eileen D. McCarrier
`Exhibit 1029 Declaration of Austin M. Schnell
`Exhibit 1030 Supplemental Declaration of Rajesh K. Gupta, Ph.D.
`Exhibit 1031 Supplemental Declaration of Jacob Robert Munford
`
`i
`
`
`
`
`
`I.
`
`INTRODUCTION
`
`Petitioner Intel Corporation moves under 37 C.F.R. § 42.123(a) and the
`
`Board’s authorization, see Paper 18, to submit Exhibits 1027–31 as supplemental
`
`information to confirm the public accessibility of the Zhang (Ex. 1003), Gupta (Ex.
`
`1004), and Chien (Ex. 1005) references.
`
`The Board instituted IPR on all presented grounds, which rely on the Zhang,
`
`Gupta, and Chien references. Id. 10–11. The Board found a reasonable likelihood
`
`that each reference was publicly accessible before the alleged priority date and, thus,
`
`prior art. Id. at 43–44. However, it noted that “[t]o the extent Patent Owner continues
`
`to challenge the printed publication status of these references after institution, the
`
`parties are requested to further develop the record on this issue.” Id. at 44. Patent
`
`Owner continues to challenge printed publication status. Thus, Intel moves to submit
`
`supplemental information to further develop the record as instructed by the Board.
`
`The proposed exhibits supplement, corroborate, and confirm the evidence that
`
`Petitioner submitted with its petition demonstrating that each reference was a
`
`conference paper published by The Institute of Electrical and Electronics Engineers,
`
`Incorporated (“IEEE”) and distributed to conference attendees, cataloged and made
`
`available in public libraries, and made publicly accessible on IEEE’s Xplore website,
`
`all before the alleged priority date. Thus, as detailed below, the Board should grant
`
`Petitioner permission to file Exhibits 1027–31 as supplemental information.
`
`1
`
`
`
`
`
`II. ARGUMENT
`
`A. The requirements of § 42.123(a) are met and the motion is consistent
`with the just, speedy, and inexpensive resolution of this proceeding.
`A party may file a motion to submit supplemental information if (1)
`
`authorization is requested within one month of the date trial is instituted; and (2) the
`
`supplemental information is relevant to a claim for which trial has been instituted.
`
`37 C.F.R. § 42.123(a). The requirements of § 42.123(a) are “construed within the
`
`overarching context of the PTAB’s regulations governing IPR and general trial
`
`proceedings,” Redline Detection, LLC v. Star Envirotech, Inc., 811 F.3d 435, 446–
`
`47 (Fed. Cir. 2015), including to “secure the just, speedy, and inexpensive resolution
`
`of every proceeding,” 37 C.F.R. § 42.1(b); see also Redline, 811 F. 3d at 448.
`
`The two requirements of § 42.123(a) are met. First, Intel requested
`
`authorization to file this motion on April 2, which is less than one month from
`
`institution of trial. Paper 18 at 2. Second, the supplemental information is relevant
`
`to a claim for which trial has been instituted because it relates to the prior art status
`
`of Zhang, Gupta, and Chien, and each of those references is part of an instituted
`
`ground challenging multiple claims of the ’867 patent. Paper 13 at 11.
`
`Intel’s Petition and accompanying evidence establish that Zhang, Gupta, and
`
`Chien are prior art because they were published by IEEE and publicly accessible
`
`prior to the critical date. See Paper 1 at 16–21; see also Paper 13 at 34–44. For
`
`example, Dr. Gupta, who authored or co-authored each reference, described the
`
`2
`
`
`
`
`
`MORPH/AMRM project that resulted in the Zhang, Gupta, and Chien references.
`
`Ex. 1010 ¶¶ 4–6; 15–26. He testified that each was made available to conference
`
`attendees, published in print by IEEE, and available on IEEE’s Xplore website, all
`
`before the critical date. Id. ¶¶ 18–26. Similarly, Mr. Munford reviewed the
`
`references and multiple libraries’ MARC records for each reference. Ex. 1012 ¶¶
`
`15–33. Mr. Munford noted that pandemic-related library closures and travel
`
`advisories prevented him from retrieving physical copies of the references, id. ¶ 14,
`
`but testified that, in his expert opinion after reviewing these materials, Zhang, Gupta,
`
`and Chien were publicly available in libraries shortly after each indicated publication
`
`date (November 18, 1997, May 15, 2000, and November 18, 1996, respectively). Id.
`
`¶¶ 20, 26, 32. The references themselves bear indicia that support these publication
`
`dates. See Exs. 1003, 1004, 1005. As the Board found, this evidence at least
`
`established a reasonable likelihood that each was prior art to the ’867 patent. Paper
`
`13 ¶¶ 40, 43.
`
`Intel moves to provide information that supplements the previously
`
`established prior art status for each of Zhang, Gupta, and Chien in response to Patent
`
`Owner’s continued challenge to that status. For example, the supplemental
`
`information
`
`includes
`
`testimony by Gordon MacPherson, Director, Board
`
`Governance & IP Operations of IEEE. See Exs. 1027. Mr. MacPherson’s declaration
`
`includes true and correct copies of the Zhang, Gupta, and Chien references available
`
`3
`
`
`
`
`
`through the IEEE Xplore website, along with the abstract page for each reference
`
`showing publication information, including the name, date, and location of
`
`conference, date added to IEEE Xplore, ISBN, ISSN, INSPEC accession number,
`
`DOI, title, author, abstract, and publisher. Ex. 1027 ¶¶ 9–10 (referencing Exs. A, B,
`
`and C to same). This supplements the information that Dr. Gupta and Mr. Munford
`
`provided. Ex. 1010 ¶¶ 18–19, 21–22, 24–25; Ex. 1012 ¶¶ 19, 25, 31. Mr.
`
`MacPherson testifies that articles and abstracts from the IEEE Xplore website show
`
`the date of publication and additional publication data as populated by metadata
`
`created and maintained as part of IEEE’s standard business practices. Ex. 1027 ¶ 10.
`
`Mr. MacPherson also confirms that IEEE’s standard practice for conference papers
`
`like Zhang, Gupta, and Chien was to make copies available no later than the last day
`
`of a conference, id. ¶¶ 11–13, as Dr. Gupta stated in his original declaration, Ex.
`
`1010 ¶¶ 18, 21, 24. Thus, MacPherson confirms that IEEE made the papers available
`
`to conference attendees, published the references in print, and made the references
`
`available through IEEE’s Xplore no later than the critical date, as Dr. Gupta and Mr.
`
`Munford stated in their original declarations.
`
`The submitted information also includes supplemental testimony from Rajesh
`
`K. Gupta, Ph.D., the author or co-author of each of the references. See Ex. 1030. Dr.
`
`Gupta confirms—as stated in his original declaration—that Exhibits 1003, 1004, and
`
`1005 are true and correct copies of his articles, which are the Zhang, Gupta, and
`
`4
`
`
`
`
`
`Chien references. Ex. 1030 ¶ 13; see also Ex. 1010 ¶¶ 20, 23, 26. Dr. Gupta presents
`
`supplemental testimony on the public accessibility of these references that is
`
`consistent with his prior testimony. For example, Dr. Gupta previously testified that
`
`each reference was published by IEEE, made available to conference attendees, and
`
`was made available through IEEE Xplore. Ex. 1010 ¶¶ 18–26. The proffered
`
`testimony provides additional information and clarification on each point. For
`
`example, he further confirms, based on his personal knowledge, that each article was
`
`included in the IEEE printed publication that was distributed to attendees of each
`
`respective conference, and that each article was subsequently made available online
`
`and in libraries. Ex. 1030 ¶¶ 5, 8, 11; see also Ex. 1010 ¶¶ 18–26.
`
`Finally, the supplemental information includes additional testimony by Jacob
`
`Robert Munford, an expert on material authentication and public accessibility, as
`
`well as declarations supporting the chain-of-custody of additional references that
`
`were retrieved from libraries at Mr. Munford’s direction. Exs. 1028, 1029, 1031. Mr.
`
`Munford further confirms the public accessibility and searchability of the references.
`
`Ex. 1031. For example, Mr. Munford reviewed library copies of each reference that
`
`were previously unavailable due to COVID-19 related library restrictions. Id. ¶¶ 17–
`
`19, 22–23, 38–40, 54–57. Mr. Munford testifies that the library copies, collection of
`
`MARC records (both prior records and supplemental records), and the copyright
`
`registrations for each reference confirm his testimony that each reference was
`
`5
`
`
`
`
`
`publicly available through libraries before the alleged priority date. Id. ¶¶ 20–69; see
`
`also Ex. 1012 ¶¶ 20, 26, 32. Mr. Munford also testifies that each reference’s public
`
`availability through libraries is corroborated by authenticated publication details
`
`listed on the IEEE Xplore website. Ex. 1031 ¶¶ 70–71. Mr. Munford further testifies
`
`that the references were publicly available through the IEEE Xplore platform before
`
`the alleged priority date based on the accessibility, searchability, keyword indexing,
`
`and cataloging provided by the Xplore during the time frame in which the references
`
`were available on that platform. Id. ¶¶ 72–88.
`
`This motion and the proposed exhibits are consistent with the efficient
`
`administration of this proceeding and the Board’s ability to complete this proceeding
`
`in a timely manner. The proposed exhibits merely confirm the accuracy of the
`
`publication date cited in the Petition; they do not change the nature of any of the
`
`instituted grounds, nor do they change the original assertion that the references were
`
`publicly available through conference distribution, IEEE publication availability in
`
`libraries, and access through IEEE Xplore all prior to the critical date, as initially
`
`presented in the Petition to support those grounds. In-Depth Geophysical, Inc. v.
`
`ConocoPhillips Co., IPR2019-00850, Paper 27 at 3 (PTAB Dec. 5, 2019). Petitioner
`
`has also not delayed in presenting this supplemental information. Intel already
`
`served Exhibits 1027-1031 on Patent Owner on March 31, 2021, and Intel requested
`
`authorization to file this motion less than a month after institution, see Ex. 3003.
`
`6
`
`
`
`
`
`Thus, the supplemental information allows for further development of the record on
`
`the issue of public accessibility, and if allowed into the record at this juncture, Patent
`
`Owner will have a full and fair opportunity to respond to the submitted evidence in
`
`its principal brief. E.g., ClearOne, Inc. v. Shure Acquisition Holdings, Inc.,
`
`IPR2019-00683, Paper 32 at 7 (PTAB Nov. 6, 2019); Palo Alto Networks, Inc. v.
`
`Juniper Network, Inc., IPR2013-00369, Paper 37 at 5 (PTAB Feb. 5, 2014).
`
`For similar reasons, Patent Owner will not be unfairly burdened or
`
`significantly prejudiced by granting this motion. The exhibits merely confirm the
`
`accuracy of the publication status of Zhang, Gupta, and Chien cited in the Petition.
`
`“Having now challenged the prior art status of these references, Patent Owner cannot
`
`complain that Petitioner seeks to rebut its assertions with additional evidence.”
`
`Nevro Corp. v. Boston Scientific Neuromodulation Corp., IPR2019-01315, Paper 20
`
`at 4–5 (PTAB Mar. 25, 2020); see also Baker Hughes Inc. v. Packers Plus Energy
`
`Services, Inc., IPR2016-00598, Paper 86 at 3 (PTAB Dec. 4, 2019) (“Having
`
`submitted evidence of public accessibility sufficient to demonstrate a reasonable
`
`likelihood of prevailing, Petitioner’s response to Patent Owner’s attack with
`
`additional evidence bolstering its public accessibility contention is foreseeable,
`
`reasonable, and not unduly prejudicial to Patent Owner.”). Moreover, Intel served
`
`Exhibits 1027-1031 on Patent Owner on March 31, 2021, and Intel files this motion
`
`well in advance of the deadline for Patent Owner’s Response. Thus, Patent Owner
`
`7
`
`
`
`
`
`is not prejudiced by granting this motion. E.g., Palo Alto Networks, Inc. v. Juniper
`
`Network, Inc., IPR2013-00369, Paper 37 at 5 (PTAB Feb. 5, 2014) (“Given that
`
`Patent Owner already has possession of the supplemental information, there is little,
`
`if any, prejudice to Patent Owner if the information is allowed into the record.
`
`Moreover, if we allow the supplemental information into the record at this juncture,
`
`Patent Owner will have sufficient time to address the supplemental information
`
`before filing its Patent Owner Response.”); Nevro, IPR2019-01315, Paper 20 at 5
`
`(“Patent Owner will have a full and fair opportunity to challenge, and respond to,
`
`this newly submitted evidence in the Patent Owner Response.”).
`
`The Board has granted similar opposed motions to submit supplemental
`
`information confirming the public accessibility of prior art used in the instituted
`
`grounds when authorization was requested within a month of institution. E.g., Palo
`
`Alto Networks, IPR2013-00369, Paper 37 at 3 (granting motion despite Patent
`
`Owner’s argument that supplemental information comprising nine exhibits could
`
`have been presented in Petition); see also Apple, Inc. v. Uniloc 2017, LLC, IPR2019-
`
`00251, Paper 23 at 5–6 (PTAB July 20, 2020) (granting motion despite Patent
`
`Owner’s argument that Petitioner failed to explain why information could not have
`
`been obtained earlier); Nevro, Paper 20 at 4–5 (granting motion despite Patent
`
`Owner’s argument that it would be prejudiced by supplemental information
`
`comprising twenty exhibits); In-Depth Geophysical, IPR2019-00850, Paper 27 at 3
`
`8
`
`
`
`
`
`(granting-in-part motion as it relates to public accessibility despite Patent Owner’s
`
`arguments because the supplemental information does not change the nature of the
`
`grounds and Patent Owner will have ample opportunity to respond in its Response);
`
`Baker Hughes, IPR2016-00598, Paper 86 at 3 (granting motion despite Patent
`
`Owner’s argument that the supplemental information is new evidence of public
`
`accessibility); ClearOne, IPR2019-00683, Paper 32 at 7 (granting-in-part motion as
`
`to thirteen exhibits related to public availability of two references despite Patent
`
`Owner’s arguments of prejudice that it injects new evidence after feedback from the
`
`POPR and Institution Decision); Apple Inc. v. VirnetX Inc., IPR2015-00810, Paper
`
`21 at 8 (PTAB Nov. 2, 2015) (granting motion despite Patent Owner’s argument that
`
`adding nine exhibits totaling almost 900 pages was prejudicial). Accordingly, the
`
`Board should grant Intel’s motion for similar reasons.
`
`B.
`
`Patent Owner’s anticipated arguments in opposition are unavailing.
`At the April 13 conference regarding Intel’s request for authorization to file
`
`this motion, see Paper 18, Patent Owner raised various arguments in opposition to
`
`the motion, but none of those arguments support denying Intel’s motion.
`
`For example, Patent Owner mischaracterizes Exhibits 1030 and 1031 as
`
`voluminous, comprising hundreds of pages of testimony that amounts to
`
`“replacement declarations” rather than supplemental declarations and citing Yamaha
`
`Golf Car Co. v. Club Car, LLC, IPR2017-02141, Paper 40 (PTAB Dec. 4, 2018), as
`
`9
`
`
`
`
`
`support. But the combined supplemental testimony in these exhibits is less than
`
`twenty-eight pages. Dr. Gupta’s supplemental declaration (Ex. 1030) comprises only
`
`five pages of testimony followed by appendices of numerous corroborating copies
`
`of Zhang, Gupta, and Chien. Similarly, Mr. Munford’s supplemental declaration
`
`(Ex. 1031) comprises only 31 pages of testimony, much of which includes prior
`
`testimony as context that shows how the supplemental information corroborates his
`
`prior analysis and conclusions. Compare Ex. 1012 ¶¶ 1–32 (discussing the basis for
`
`opinion and analyzing public accessibility of Zhang, Gupta, and Chien) with Ex.
`
`1031 ¶¶ 1–5, 7–14, 17, 20, 29–31, 33–34, 36, 46–48, 50-52, 63–65, 68–69
`
`(corroborating prior testimony with supplemental information). The remaining
`
`pages are appendices related to his curriculum vitae, MARC records, numerous
`
`corroborating copies of Zhang, Gupta, and Chien, and other corroborating
`
`information. Mr. Munford’s supplemental testimony therefore amounts to less than
`
`19 pages on physical library copies and their corresponding MARC records,
`
`copyright registration records, and IEEE Xplore search, cataloging, and indexing
`
`functionality. Ex. 1031 ¶¶ 6, 15–16, 18–19, 21–28, 32–35, 37–45, 49–51, 53–62,
`
`66–88. Thus, Patent Owner’s emphasis on page count is misleading. See Apple,
`
`IPR2015-00810, Paper 21 at 5–6 (granting motion despite PO’s argument that
`
`almost 900 pages of supplemental information was prejudicial because need to
`
`respond was more limited).
`
`10
`
`
`
`
`
`Moreover, Patent Owner’s reliance on Yamaha is misplaced. The petitioner in
`
`that case expressly sought to replace the technical expert’s original declaration with
`
`a new 122-page declaration and nine new prior art references to provide
`
`supplemental information on motivation to modify, point of novelty, and the state of
`
`the art—a “significant change from the evidence originally presented in support of
`
`the petition.” See Yamaha Golf, IPR2017-02141, Paper 40 at 5–7 (emphasis added).
`
`Here, in contrast, the supplemental testimony relates to publication status and only
`
`corroborates—and is consistent with—prior testimony that these references were
`
`publicly accessible through conference attendance, IEEE published copies available
`
`in libraries, and IEEE Xplore. See Ex. 1010 (Gupta) ¶¶ 18–26, Ex. 1012 (Munford)
`
`Id. ¶¶ 20, 26, 32. Thus, Yamaha Golf is inapposite.
`
`Patent Owner also misleadingly argues that the proposed exhibits are
`
`inefficient and burdensome by allegedly requiring five additional depositions. Two
`
`exhibits are merely chain-of-custody declarations related to the retrieval of library
`
`copies of Zhang, Gupta and Chien, with little to no substantive testimony that
`
`warrants cross examination. See Exs. 1028, 1029. Two exhibits are supplemental
`
`declarations by witnesses that provided original testimony with the petition, see Ex.
`
`1030, 1031, and each would only need to be cross examined once for their original
`
`and supplemental testimony. Thus, it is more efficient to address each at this juncture
`
`than in reply. Pacific Market Int’l, LLC. v. Ignite USA, LLC., IPR2014-00561, Paper
`
`11
`
`
`
`
`
`23 at 4 (PTAB Dec. 2, 2014) (“Making the Supplemental Declaration of record now
`
`increases the likelihood that the record will be developed more fully with a minimum
`
`number of depositions and without additional motion practice.”). The remaining
`
`exhibit comprises two pages of substantive testimony by one witness that acts as a
`
`custodian of records for IEEE. See Ex. 1027. Thus, the proposed exhibits only
`
`introduce one additional witness for potential cross examination and making these
`
`exhibits of record now is more efficient than if they are introduced later in reply.
`
`
`
`Patent Owner also incorrectly contends that the supplemental information
`
`introduces “new theories” of public availability. To the contrary, Intel established in
`
`the originally submitted evidence that each of Zhang, Gupta, and Chien were
`
`publicly accessible to conference attendees (Ex. 1010 ¶¶ 18, 21, 24), available as
`
`printed publications in libraries (Ex. 1010 ¶¶ 19, 22, 25; Ex. 1012 ¶¶ 20, 26, 32), and
`
`were publicly accessible through IEEE’s Xplore website (Ex. 1010 ¶¶ 19, 22, 26).
`
`The evidence submitted here corroborates that previously-submitted evidence and
`
`bases for establishing the public accessibility of Zhang, Gupta, and Chien.
`
`Finally, Patent Owner wrongly contends that Intel’s submission is untimely
`
`and that Intel must establish that the supplemental information could not have been
`
`reasonably obtained earlier. The Board has repeatedly noted that, unlike motions
`
`under § 42.123(b) or (c), a motion to file supplemental information under § 42.123(a)
`
`is not required to show why the supplemental information could not have been
`
`12
`
`
`
`
`
`reasonably obtained earlier. See, e.g., Hulu, LLC v. Sound View Innovations, LLC,
`
`IPR2018-01039, Paper 29, at 8 (PTAB Precedential Panel Dec. 20, 2019) (“After
`
`institution, there is also an opportunity for the petitioner to move to submit
`
`supplemental information under 37 C.F.R. § 42.123. Unless this motion is filed
`
`within one month of institution, the petitioner must show ‘why the supplemental
`
`information reasonably could not have been obtained earlier.’ 37 C.F.R. § 42.123(b)
`
`and (c)”); Apple, IPR2019-00251, Paper 23 at 6 (rejecting Patent Owner’s argument
`
`that § 42.123(a) requires Petitioner to address why information could not have been
`
`obtained earlier); Palo Alto Networks, IPR2013-00369, Paper 37 at 3 (PTAB Feb. 5,
`
`2014) (“We agree with Petitioner that whether ‘supplemental information
`
`reasonably could have been obtained earlier’ is a requirement under § 42.123(b) and
`
`(c)—not a requirement under § 42.123(a).”). Intel has not withheld evidence. To the
`
`contrary, Intel served Exhibits 1027-1031 on Patent Owner on March 31, 2021, and
`
`Intel files this motion well in advance of the deadline for Patent Owner’s Response.
`
`Intel could not have anticipated whether or how Patent Owner would challenge each
`
`reference’s public accessibility, and the Federal Circuit has confirmed that the
`
`interest of justice supports admitting evidence when the opponent has an opportunity
`
`to respond and produce contrary evidence. Telefonaktiebolaget LM Ericsson v. TCL
`
`Corp., 941 F.3d 1341, 1345–46 (Fed. Cir. 2019). Moreover, as explained in Mr.
`
`Munford’s original and supplemental declarations, libraries and other institutions
`
`13
`
`
`
`
`
`were closed due to the global pandemic at the time of the Petition, making physical
`
`copies of the references unobtainable at that time. See Exs. 1012, 1031. Thus, Intel’s
`
`motion is timely and complies with the requirements of § 42.123(a).
`
`III.
`
` CONCLUSION
`
`Accordingly, Petitioner respectfully requests that the Board grant Petitioner
`
`permission to file Exhibits 1027–31 as supplemental information.
`
`
`
`
`
`14
`
`
`
`
`
`Dated: April 28, 2021
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`By: /s/ Brian C. Nash
`
`
`Brian C. Nash (Reg. No. 58,105)
`Pillsbury Winthrop Shaw Pittman LLP
`401 Congress Avenue, Suite 1700
`Austin, TX 78701
`Telephone: (512) 580-9629
`Facsimile: (512) 580-9601
`Email: brian.nash@pillsburylaw.com
`
`Counsel for Petitioner Intel Corporation
`
`15
`
`
`
`
`
`CERTIFICATE OF COMPLIANCE
`
`I hereby certify
`
`that
`
`the
`
`foregoing MOTION TO SUBMIT
`
`SUPPLEMENTAL INFORMATION PURSUANT TO 37 C.F.R. § 42.123(a)
`
`complies with the page limitation of 37 C.F.R. § 42.24(a)(v) because it is no more
`
`than fifteen pages.
`
`I further certify that the foregoing Motion complies with the general format
`
`requirements of 37 C.F.R. § 42.6(a) and has been prepared using Microsoft Word
`
`2016 in 14-point Times New Roman proportional font.
`
`April 28, 2021
`
`By: /s/ Brian C. Nash
`
`
`Brian C. Nash (Reg. No. 58,105)
`Pillsbury Winthrop Shaw Pittman LLP
`401 Congress Avenue, Suite 1700
`Austin, TX 78701
`Telephone: (512) 580-9629
`Facsimile: (512) 580-9601
`Email: brian.nash@pillsburylaw.com
`
`
`
`
`
`16
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true copy of “PETITIONER’S MOTION TO
`
`SUBMIT SUPPLEMENTAL INFORMATION PURSUANT TO 37 C.F.R. §
`
`42.123(a)” was served electronically via e-mail on April 28, 2021, in its entirety on
`
`the following:
`
`Jay P. Kesan, Reg. No. 37,488
`DIMUROGINSBERG, PC
`DGKEYIP GROUP
`1750 Tyson’s Blvd. Suite 1500
`Tysons Corner, VA 22102
`jkesan@dimuro.com
`
`Ari Rafilson, Reg. No. 58,693
`Shore Chan DePumpo LLP
`901 Main Street, Suite 3300
`Dallas, TX 75202
`arafilson@shorechan.com
`
`
`Dated: April 28, 2021
`
`
`
`By: /s/ Brian C. Nash
`
`
`Brian C. Nash (Reg. No. 58,105)
`Pillsbury Winthrop Shaw Pittman LLP
`401 Congress Avenue, Suite 1700
`Austin, TX 78701
`Telephone: (512) 580-9629
`Facsimile: (512) 580-9601
`Email: brian.nash@pillsburylaw.com
`
`Counsel for Petitioner Intel Corporation
`
`17
`
`
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
