`_____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`In the Patent of: Yang, Xiu Zheng, Shulin (TW);
`Ren-Jr Chen, Hsinchu (TW);
`
`
`
`Chang-Lung Hsiao, Hsinchu (TW);
`
`
`
`Pang-An Ting, Fongyuan (TW)
`
`
`
`
`U.S. Patent No: 8,265,096
`Issue Date: September 11, 2012
`Appl. Serial No.: 12/168,855
`Filing Date: July 7, 2008
`Title: METHOD FOR CONSTRUCTING FRAME STRUCTURES
`
`
`
`
`
`
`PTAB Case No. IPR2021-00734
`Patent No. 8,265,096 B2
`_____________________
`
`PETITIONER ZYXEL COMMUNICATIONS CORPORATION’S SECOND
`UPDATED MANDATORY NOTICES
`
`
`
`
`
`
`Pursuant 37 C.F.R. § 42.8(a)(3), Petitioner ZyXEL Communications
`
`Corporation submits these updated mandatory notices:
`
`I.
`
`REAL PARTIES IN INTEREST (37 C.F.R. § 42.8(B)(1))
`No change.
`II. RELATED MATTERS (37 C.F.R. § 42.8(B)(2))
`Petitioner originally identified the Dell and ASUSTek litigations—UNM
`
`Rainforest Innovations v. Dell Technologies Inc. et al., No. 6:20-cv-00468 (W.D.
`
`Tex.), and UNM Rainforest Innovations v. ASUSTek Computer, Inc., No. 6:20-cv-
`
`00142 (W.D. Tex.)—as related matters in its petition. Paper 1 at 3. Petitioner submits
`
`these second updated mandatory notices to inform the Board that the district court
`
`has stayed the Dell and ASUSTek litigations. See June 22, 2021 Order in UNM
`
`Rainforest Innovations v. Dell Technologies Inc. et al., No. 6:20-cv-00468-ADA
`
`(granting motion to stay the Dell litigation “pending resolution of patent ownership
`
`issues in UNM Rainforest Innovations v. Industrial Technology Research Institute,
`
`et al., case number D-202-CV-2021-02803 in the Second Judicial District Court of
`
`Bernalillo County, New Mexico1.”); see also June 22, 2021 docket entry in UNM
`
`Rainforest Innovations v. ASUSTek Computer, Inc., No. 6:20-cv-00142-ADA
`
`(stating “Case Stayed (lad)”); see also Gilead Scis., Inc. v. Regents of U. of
`
`
`1 Petitioner informed the Board of this case brought by UNM in Petitioner’s first
`
`updated mandatory notices. See Paper 9 at 1.
`
`
`
`-1-
`
`
`
`Minnesota, IPR2017-01712, 2017 WL 4862066, at *1 (PTAB Oct. 25, 2017) (“As a
`
`reminder, the parties are required to update their mandatory notices with any changes
`
`in the district court action, including the change of venue or entry of a stay. See 42
`
`C.F.R. § 42.8.”) (emphasis added). Furthermore, ZyXel has also filed a motion to
`
`stay ZyXel litigation on the same grounds as the motions that were granted in Dell
`
`and ASUSTek litigations.
`
`III. NOTICE OF COUNSEL (37 C.F.R. § 42.8(B)(3))
`No change.
`
`IV. SERVICE INFORMATION (37 C.F.R. § 42.8(B)(4))
`No change.
`
`
`Dated: July 12, 2021
`
`Respectfully submitted,
`
`/s/ Jonathan I. Detrixhe
`Lead Counsel
`Jonathan I. Detrixhe (Reg. No. 68,556)
`Reed Smith LLP
`101 Second Street
`Suite 1800
`San Francisco, CA 94105
`Tel: 415.543.8700
`Fax: 415.391.8269
`jdetrixhe@reedsmith.com
`
`Back-up Counsel
`Jonah D. Mitchell (will seek pro hac vice
`admission)
`Christine M. Morgan (will seek pro hac vice
`admission)
`Reed Smith LLP
`
`-2-
`
`
`
`101 Second Street
`Suite 1800
`San Francisco, CA 94105
`Tel: 415.543.8700
`Fax: 415.391.8269
`jmitchell@reedsmith.com
`cmorgan@reedsmith.com
`
`Peter J. Chassman (Reg. No. 38,841)
`Reed Smith LLP
`811 Main Street
`Suite 1700
`Houston, TX 77002
`Tel: 713.469.3800
`Fax: 713.469.3899
`pchassman@reedsmith.com
`
`Ismail C. Kuru (will seek pro hac vice admission)
`Reed Smith LLP
`10 S. Wacker Dr. 40th Floor
`Chicago, IL, 60606
`Tel: 312.207.1000
`Fax: 312.207.6400
`ikuru@reedsmith.com
`
`
`Counsel for Petitioner
`
`
`
`-3-
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e)(4) and 42.25(b), the undersigned certifies
`
`that on July 12, 2021, a complete copy of Petitioner’s Second Updated Mandatory
`
`Notices was filed electronically through the Patent Trial and Appeal Board’s
`
`PTABE2E System and provided, via electronic service, to UNM Rainforest
`
`Innovations by serving the correspondence address of record as follows:
`
`Jay P. Kesan (jkesan@dimuro.com)
`
`Alfonso G. Chan (achan@shorechan.com)
`
`
`
`Dated: July 12, 2021
`
`Respectfully submitted,
`/ Jonathan I. Detrixhe /
`Jonathan I. Detrixhe (Reg. No. 68,556)
`Reed Smith LLP
`101 Second Street
`Suite 1800
`San Francisco, CA 94105
`Tel: 415.543.8700
`Fax: 415.391.8269
`jdetrixhe@reedsmith.com
`
`Counsel for Petitioner
`
`
`
`4
`
`
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