`U.S. Patent No. 6,651,134
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`
`QUALCOMM INC.,
`and STMICROELECTRONICS, INC.
`Petitioners
`
`
`
`v.
`
`MONTEREY RESEARCH, LLC,
`Patent Owner
`
`________________
`
`
`Case IPR2020-01492
`&
`IPR2021-007021
`
`U.S. Patent No. 6,651,134
`Title: MEMORY DEVICE WITH FIXED LENGTH NON
`INTERRUPTIBLE BURST
`Issue Date: November 18, 2003
`
`__________________
`
`MONTEREY RESEARCH, LLC NOTICE OF APPEAL
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`1 IPR2021-00702 was joined with IPR2020-01492 and resolved in a single Final
`Written Decision from which this appeal arises.
`
`
`
`Case IPR2020-01492 & IPR2021-00702
`U.S. Patent No. 6,651,134
`
`
`Pursuant to 35 U.S.C. §§ 141, 142, and 319, and in accordance with 37 C.F.R.
`
`§§ 90.2-90.3, Patent Owner Monterey Research, LLC (“Monterey”) appeals to the
`
`United States Court of Appeals for the Federal Circuit from the Final Written
`
`Decision of the Patent Trial and Appeal Board (“Board”) entered on March 4, 2022
`
`in IPR2020-01492 (Paper No. 33) and the same decision entered on March 4, 2022
`
`in IPR2021-00702 (Paper 10), which was joined with IPR2020-001492 (the “Final
`
`Written Decision”), and from all underlying findings, determinations, rulings,
`
`opinions, orders, and decisions regarding the inter partes review (Cases IPR2020-
`
`01492 and IPR2021-00702) of U.S. Patent No. 6,651,134 (the “’134 Patent”).
`
`
`
`In accordance with 37 C.F.R. § 90.2(a)(3)(ii), Monterey states that the issues
`
`on appeal include, but are not limited to: the Board’s determination that Claims 1-7
`
`and 9-21 of the ’134 Patent have been shown to be unpatentable; the Board’s
`
`construction of those claims; the Board’s consideration of the expert testimony, prior
`
`art, and other evidence in the record; and the Board’s factual findings, conclusions
`
`of law, or other determinations supporting or related to those issues, as well as all
`
`other issues decided adversely to Monterey in any orders, decisions, rulings, and
`
`opinions.
`
`
`
`This Notice of Appeal is being e-filed with the Clerk’s Office for the United
`
`States Court of Appeals for the Federal Circuit, along with payment of the required
`
`docketing fees. In addition, a copy of this Notice of Appeal is being filed
`
`1
`
`
`
`Case IPR2020-01492 & IPR2021-00702
`U.S. Patent No. 6,651,134
`
`simultaneously with the Patent Trial and Appeal Board and with the Director of the
`
`United States Patent and Trademark Office.
`
`
`
`Dated: May 6, 2022
`
`Respectfully submitted,
`
`/s/ Kayvan B. Noroozi
`Kayvan B. Noroozi
`NOROOZI PC
`11601 Wilshire Boulevard
`Suite 2170
`Los Angeles, CA 90025
`Telephone: (310) 975-7074
`Facsimile: (844) 975-7074
`
`Counsel for Appellant
`Monterey Research, LLC
`
`
`2
`
`
`
`Case IPR2020-01492 & IPR2021-00702
`U.S. Patent No. 6,651,134
`
`CERTIFICATE OF FILING
`
`The undersigned certifies that on May 6, 2022, in addition to filing the
`
`foregoing electronically through PTAB E2E, a copy of this Notice of Appeal was
`deposited with Priority Mail Express on May 6, 2022 for filing with the Director of
`the United States Patent and Trademark Office, at the following address:
`
`
`Director of the United States Patent and Trademark Office
`c/o Office of the General Counsel
`Mail Stop 8
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`The undersigned also certifies that on May 6, 2022, a copy of this Notice of
`
`Appeal was filed electronically through the United States Court of Appeals for the
`Federal Circuit’s CM/ECF system.
`
`
`Dated: May 6, 2022
`
`Respectfully submitted,
`
`
`
`
`
`
`/s/ Kayvan B. Noroozi
`Kayvan B. Noroozi
`NOROOZI PC
`11601 Wilshire Boulevard
`Suite 2170
`Los Angeles, CA 90025
`Telephone: (310) 975-7074
`Facsimile: (844) 975-7074
`
`Counsel for Appellant
`Monterey Research, LLC
`
`
`
`
`
`
`Case IPR2020-01492 & IPR2021-00702
`U.S. Patent No. 6,651,134
`
`CERTIFICATE OF SERVICE
`
`
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on May 6, 2022,
`a complete copy of the foregoing was served on counsel of record for all parties by
`filing this document through PTAB E2E, by filing this and by sending this document
`via electronic mail to the following addresses:
`
`Eagle H. Robinson
`Daniel S. Leventhal
`Richard S. Zembek
`Norton Rose Fulbright US LLP
`eagle.robinson@nortonrosefulbright.com
`daniel.leventhal@nortonrosefulbright.com
`richard.zembek@nortonrosefulbright.com
`
`
`Tyler R. Bowen
`Roque Thuo
`Perkins Coie LLP
`bowen-ptab@perkinscoie.com
`thuo-ptab@perkinscoie.com
`
`Dated: May 6, 2022
`
`Respectfully submitted,
`
`/Theodoros Konstantakopoulos/
`Theodoros Konstantakopoulos, Ph.D.
`(Reg. No. 74,155)
`tkonstantakopoulos@desmaraisllp.com
`DESMARAIS LLP
`230 Park Avenue
`New York, NY 10169
`Telephone: 212-351-3400
`Facsimile: 212-351-3401
`
`Counsel for Patent Owner
`Monterey Research, LLC
`
`
`
`
`
`
`
`
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