`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TCT MOBILE (US), INC.; TCT MOBILE (US) HOLDINGS, INC.;
`HUIZHOU TCL MOBILE COMMUNICATION CO. LTD.; AND TCL
`COMMUNICATION, INC.,
`
`Petitioner
`
`v.
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`FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC,
`
`Patent Owner
`
`Case No. IPR2021-00395
`U.S. Patent 7,239,111
`
`PETITIONER’S REQUEST FOR REFUND
`OF POST-INSTITUTION FEES
`
`
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`Petitioner TCT Mobile (US), Inc.; TCT Mobile (US) Holdings, Inc.;
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`Huizhou TCL Mobile Communication Co. Ltd.; and TCL Communication, Inc.
`
`(“TCT”) respectfully requests a refund of post-institution fees in the amount of
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`$22,500.
`
`On December 31, 2020, TCT filed a Petition for Inter Partes Review of U.S.
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`Patent No. 7,239,111. As required by 37 C.F.R. § 42.15(a), TCT deposited
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`$41,500 with the U.S. Patent and Trademark Office (“USPTO”) at the time of
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`filing the Petition in order to cover associated fees. TCT’s payment consisted of
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`$19,000 in fees associated with the request for Inter Partes Review, and a further
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`$22,500 in post-institution fees.
`
`On July 6, 2021, the U.S. Patent Trial and Appeal Board issued a Decision
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`Denying Institution of Inter Partes Review (Paper No. 8). TCT filed a Request for
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`Rehearing on July 20, 2021 (Paper No. 9). On August 31, 2021, the U.S. Patent
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`Trial and Appeal Board issued its Decision Denying the Request for Rehearing
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`(Paper No. 10). Thus, inter partes review was not instituted. Accordingly, TCT
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`requests a refund of the post-institution fees paid to the USPTO in connection with
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`this proceeding, totaling $22,500, to be paid to deposit account 15-0665
`
`(referencing Attorney Docket 46909.2005).
`
`1
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`
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`Dated: September 24, 2021
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`Respectfully submitted,
`
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`By:
`/Jeffrey Johnson/
`
`Jeffrey Johnson, Reg. No. 53,078
`Email: 3J6PTABDocket@orrick.com
`609 Main Street, 40th Floor
`Houston, TX 77002-3106
`Main: (713) 658-6400
`Fax: (713) 658-6401
`
`Robert J. Benson (to be admitted pro hac vice)
`Email: R75PTABDocket@orrick.com
`2050 Main Street, Suite 1100
`Irvine, CA 92614-8255
`Main: (949) 567-6700
`Fax: (949) 567-6710
`
`Attorneys for Petitioners
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`2
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`
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`CERTIFICATION OF SERVICE
`The undersigned certifies that on September 24, 2021, a copy of the
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`foregoing was served in its entirety by filing through the Patent Trial and Appeal
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`Board End to End System, as well as via electronic mail, upon the following
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`attorneys of record for the Patent Owner:
`
`Hong Annita Zhong
`Jason Sheasby
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067
`
`hzhong@irell.com
`jsheasby@irell.com
`fundamentalIPRs@irell.com
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`Attorneys for Patent Owner Fundamental Innovation Systems International LLC
`
` /Karen Johnson/
` Karen Johnson
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`3
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`