throbber
Trials@uspto.gov
`571-272-7822
`
`
` Paper 25
`
`Date: July 26, 2022
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`TCL INDUSTRIES HOLDINGS CO., LTD., HISENSE CO., LTD., and
`LG ELECTRONICS INC.,
`Petitioners,
`
`v.
`
`PARKERVISION, INC.,
`Patent Owner.
`____________
`
`IPR2021-00985 (Patent 7,292,835 B2)1
`IPR2021-00990 (Patent 7,110,444 B1)2
`____________
`
`Before MICHAEL R. ZECHER, BART A. GERSTENBLITH, and
`IFTIKHAR AHMED, Administrative Patent Judges.
`
`GERSTENBLITH, Administrative Patent Judge.
`
`
`ORDER3
`Denying Patent Owner’s Motion to Strike
`37 C.F.R. §§ 42.5(a), 42.23(b)
`
`
`1 LG Electronics Inc., who filed a petition in IPR2022-00246, is joined as
`petitioner in IPR2021-00985.
`2 LG Electronics Inc., who filed a petition in IPR2022-00245, is joined as
`petitioner in IPR2021-00990.
`3 This Order addresses issues that are substantially identical in each of the
`above-captioned proceedings. We exercise our discretion to issue one Order
`to be filed in each proceeding. The parties are not authorized to use this
`style heading in subsequent papers.
`
`
`
`
`

`

`IPR2021-00985 (Patent 7,292,835 B2)
`IPR2021-00990 (Patent 7,110,444 B1)
`
`
`I.
`INTRODUCTION4
`On June 1, 2022, Patent Owner, ParkerVision, Inc. (“ParkerVision”),
`submitted an email request for authorization to file a motion to strike
`arguments set forth in Petitioners’ Reply in each of the above-referenced
`proceedings.5 Specifically, ParkerVision’s email “submits that there is good
`cause to file the Motion to Strike, because TCL’s Reply raises a new theory
`regarding the claimed ‘storage module’ limitation and, in particular, how
`‘stor[ing] non-negligible amounts of energy from an input electromagnetic
`signal’ is supposedly met.”6 After receiving authorization in a conference
`call with the panel held June 14, 2022, ParkerVision filed Motions to Strike
`(IPR2021-00985, Paper 26 (“’985 Mot.”); IPR2021-00990, Paper 21),
`arguing that TCL is “proceeding in a new direction with a new approach,”
`which “is prohibited by 37 C.F.R. § 42.23(b) and the Consolidated Trial
`Practice Guidelines.” ’985 Mot. 1. Petitioners, TCL Industries Holdings
`Co., Ltd., Hisense Co., Ltd., and LG Electronics Inc. (collectively, “TCL”),
`
`
`4 As noted above, the issues raised in this Order are the substantially
`identical in each proceeding. Unless otherwise indicated, citations are to
`documents in IPR2021-00985 for convenience, with the understanding that
`the arguments and evidence discussed herein also are of record in IPR2021-
`00990.
`5 IPR2021-00985 (“’985 IPR”), Ex. 3006 (Email from J. Charkow, dated
`June 1, 2022); IPR2021-00990 (“’990 IPR”), Ex. 3005 (same).
`6 Independent claim 1 of U.S. Patent No. 7,292,835 B2 recites the term
`“storage module,” whereas independent claim 3 of U.S. Patent No.
`7,110,444 B1 recites the term “storage element.” The parties use these claim
`terms interchangeably throughout their Motions and Oppositions. Although
`in some instances we refer to “storage module” or “storage element,” the
`same discussion and analysis applies equally to both.
`2
`
`

`

`IPR2021-00985 (Patent 7,292,835 B2)
`IPR2021-00990 (Patent 7,110,444 B1)
`
`filed Oppositions to the Motions to Strike. IPR2021-00985, Paper 29 (“’985
`Opp.”); IPR2021-00990, Paper 24.
`
`II.
` ANALYSIS
`A. Background
`In the context of litigating its patents involving down-conversion
`technology, ParkerVision has asserted several different claim constructions
`related to the claim terms “storage element” and “storage module.” In
`particular, before the U.S. District Court for the Western District of Texas,
`ParkerVision proposed that the claim terms “storage element” and “storage
`module,” should be construed as an element or module “of an energy
`transfer system that stores non-negligible amounts of energy from an input
`electromagnetic signal for driving a low impedance load.” ’985 IPR,
`Ex. 1011 at 5 (Claim Construction Order, ParkerVision, Inc. v. Intel Corp.,
`No. W-20-CV-00108-ADA (W.D. Tex. Jan. 26, 2021)). The district court
`did not accept ParkerVision’s construction, opting instead to construe the
`terms as elements or modules “of an energy transfer system that stores
`non-negligible amounts of energy from an input electromagnetic signal.” Id.
`In the subject Petition, TCL noted that the district court did not
`include the phrase “for driving a low impedance load” in the construction of
`“storage element” or “storage module,” and encouraged us to avoid doing
`the same. ’985 IPR, Pet. 34–35. TCL, however, did not specifically recite
`or apply the district court’s construction of “storage module” in addressing
`the application of the prior art. See, e.g., id. at 60 (“first storage module” in
`
`3
`
`

`

`IPR2021-00985 (Patent 7,292,835 B2)
`IPR2021-00990 (Patent 7,110,444 B1)
`
`Ground 1), 75 (“first storage module” in Ground 2).7 Rather, in each
`instance, TCL identified a capacitor in the prior art as teaching the claimed
`“storage module.” See id. at 60, 63, 75, 78–79. TCL’s approach, in the
`Petition, is consistent with ParkerVision’s assertions in its district court
`complaint asserted against TCL Industries Holdings Co., Ltd. and other TCL
`entities, in which ParkerVision stated that TCL’s accused chips include “a
`first storage module (e.g., a module having one or more capacitors).”
`’985 IPR, Ex. 2002, 32 (Complaint for Patent Infringement, ParkerVision,
`Inc. v. TCL Indus. Holdings Co., No. 6:20-cv-00945 (W.D. Tex. Oct. 12,
`2020) (Doc. 1)).
` In IPR2020-01265, which involved related ParkerVision technology,
`ParkerVision proposed a construction for “storage element” that matched
`that of the district court. See, e.g., Intel Corp. v. ParkerVision, Inc.,
`IPR2020-01265, Paper 44 at 32 (PTAB Jan. 21, 2022) (citing, inter alia,
`ParkerVision’s Response in that case). After a detailed analysis, the Board
`did not agree with ParkerVision’s proposed construction; rather, the Board
`construed the term “storage element” to mean “an element of a system that
`stores non-negligible amounts of energy from an input EM signal.” Id. at
`41.
`
`B. Principles of Law
`The Consolidated Trial Practice Guide explains that a motion to strike
`is the preferred mechanism “[i]f a party believes that a brief filed by the
`opposing party raises new issues, is accompanied by belatedly presented
`
`
`7 The same is true for TCL’s analysis of “second storage module” in each
`ground. See ’985 IPR, Pet. 63 (Ground 1), 78–79 (Ground 2).
`4
`
`

`

`IPR2021-00985 (Patent 7,292,835 B2)
`IPR2021-00990 (Patent 7,110,444 B1)
`
`evidence, or otherwise exceeds the proper scope of reply or sur-reply.”
`Patent Trial and Appeal Board Consolidated Trial Practice Guide
`(“Consolidated Trial Practice Guide”) at 80 (Nov. 2019).8 TCL’s Reply may
`only respond to arguments raised in ParkerVision’s Response. See 37
`C.F.R. §42.23(b). In the Consolidated Trial Practice Guide, the Board
`expounded upon this principle stating, “Petitioner may not submit new
`evidence or argument in reply that it could have presented earlier, e.g. to
`make out a prima facie case of unpatentability.” Consolidated Trial Practice
`Guide at 73 (citing Belden Inc. v. Berk-Tek LLC, 805 F.3d 1064, 1077–78
`(Fed. Cir. 2015)). The Consolidated Trial Practice Guide further explains
`that “‘[r]espond,’ in the context of 37 C.F.R. § 42.23(b), does not mean
`proceed in a new direction with a new approach as compared to the positions
`taken in a prior filing,” and “[w]hile replies and sur-replies can help
`crystalize issues for decision, a reply or sur-reply that raises a new issue or
`belatedly presents evidence may not be considered.” Id. at 74.
`“In most cases, the Board is capable of identifying new issues or
`belatedly presented evidence when weighing the evidence at the close of
`trial, and disregarding any new issues or belatedly presented evidence that
`exceeds the proper scope of reply or sur-reply.” Consolidated Trial
`Practice Guide at 80. The Board has disregarded inappropriately presented
`argument and evidence in prior cases. See Intelligent Bio-Systems, Inc. v.
`Illumina Cambridge Ltd., 821 F.3d 1359, 1369–70 (Fed. Cir. 2016)
`(explaining that the Board did not abuse its discretion in refusing to consider
`reply brief arguments advocating a “new theory” of unpatentability under
`
`8 Available at https://www.uspto.gov/TrialPracticeGuideConsolidated.
`5
`
`

`

`IPR2021-00985 (Patent 7,292,835 B2)
`IPR2021-00990 (Patent 7,110,444 B1)
`
`37 C.F.R. § 42.23(b)); Apple Inc. v. e-Watch, Inc., IPR2015-00412, Paper 50
`at 44 (PTAB May 6, 2016) (“Accepting such belatedly presented new
`arguments would be unjust to the Patent Owner and we decline to do so.”).
`In this instance, in light of the issues raised by ParkerVision, we address
`the Motions now, prior to any final written decisions in these proceedings.
`
`C. Alleged New Arguments
`ParkerVision asserts that, “in the Petition, [TCL] merely identified
`capacitors as ‘storage modules,’” and now, in the Reply, “[TCL] argue[s] an
`entirely new direction in terms of what makes a capacitor a storage
`module—it ‘stores non-negligible amounts of energy.’” ’985 Mot. 1. In
`particular, ParkerVision identifies a list of arguments raised in TCL’s Reply
`that ParkerVision asserts are “new arguments regarding capacitors in the
`prior art references.” Id. These arguments essentially contend that, when
`the prior art teaches a capacitor within a circuit that successfully down-
`converts a signal, that constitutes proof that the capacitor stores non-
`negligible amounts of energy. Id. at 1–3.
`ParkerVision asserts that TCL “could have (and should have)
`addressed the language requiring that the ‘storage module’ ‘stores non-
`negligible amounts of energy’” in its Petition, but did not do so. ’985 Mot.
`4–5. Specifically, ParkerVision argues that TCL had the benefit of the
`district court’s claim construction order and ParkerVision’s Patent Owner’s
`Response in IPR2020-01265 prior to filing the Petition. Id. at 4.
`In response, TCL contends that “the Reply does not contain any ‘new
`theory,’” but rather “[e]xactly like the Petition, it explains how certain prior
`art references disclose ‘storage’ modules in the form of switched-capacitors
`used to down-convert an RF signal.” ’985 Opp. 1. Additionally, TCL
`
`6
`
`

`

`IPR2021-00985 (Patent 7,292,835 B2)
`IPR2021-00990 (Patent 7,110,444 B1)
`
`asserts that its Reply “highlights the inconsistencies between ParkerVision’s
`positions (i.e., those adopted during litigation versus its newfound position
`in the [Patent Owner Response]).” Id. Further, TCL contends that its Reply
`arguments respond to the “newfound energy-calculations theory” raised in
`ParkerVision’s Response. Id. at 2.
`We find that TCL’s Reply does not raise new arguments or evidence
`that is impermissible in a reply brief. First, although we recognize that the
`Petition does not include the term “non-negligible” when applying the prior
`art to the claims, the claims themselves do not recite “non-negligible.” Even
`though the district court’s claim construction order construed “storage
`module” to include the term “non-negligible,” we do not find it predictable
`that, at the time the Petition was filed, TCL should have anticipated
`ParkerVision’s arguments as to the meaning of “non-negligible” in the
`construction of “storage module.”
`In particular, we do not agree that the timing of the arguments raised
`in the multiple disputes between ParkerVision and other entities or the
`timing of various claim construction decisions warrant striking TCL’s Reply
`arguments from the record. As explained by TCL (see ’985 Opp. 5), the
`record before us reflects that ParkerVision first sought to present its
`calculation-based argument (re non-negligible energy) in a sur-reply brief in
`IPR2020-01265 four months after the Petition in this proceeding was filed.
`Similarly, the Board’s Final Written Decision construing “storage element,”
`in IPR2020-01265, was not issued until January 21, 2022, eight months after
`the instant Petition was filed. See IPR2020-01265, Paper 44 at 32. Thus,
`TCL had no ability to address the position expressed by ParkerVision or the
`construction of “storage element” adopted by the Board in IPR2020-01265
`
`7
`
`

`

`IPR2021-00985 (Patent 7,292,835 B2)
`IPR2021-00990 (Patent 7,110,444 B1)
`
`when it filed the instant Petition. From a timing perspective, TCL’s Reply
`was the first opportunity at which TCL could address these positions,
`assuming ParkerVision raised them in its Patent Owner Response in this
`proceeding.
`The lack of predictability regarding ParkerVision’s arguments is
`especially apparent in light of TCL’s Reply, which draws attention to
`different positions taken by ParkerVision in other litigation. ’985 Opp. 3
`(citing ParkerVision, Inc. v. Qualcomm, Inc., No. 3:11-cv-719-J-37TEM,
`2013 WL 633077, at *5–7 (M.D. Fla. Feb. 20, 2013); ParkerVision, Inc. v.
`Qualcomm, Inc., 621 F. App’x 1009, 1018 (Fed. Cir.), reh’g denied, 627 F.
`App’x 921 (Fed. Cir. 2015), cert. denied, 577 U.S. 1236 (2016)). TCL
`represents that, in the Middle District of Florida litigation, ParkerVision
`construed “non-negligible” to mean an amount of energy distinguishable
`from noise and further explained at trial how the meaning of the term should
`be applied to determine whether a non-negligible amount of energy was
`transferred. ’985 Opp. 3–4 (discussing inventor, Mr. David Sorrells,
`testimony that transferring a non-negligible amount of energy into the
`storage capacitor means that you have to transfer enough energy to
`overcome the noise in the system to be able to meet your specifications). Id.
`(citing ParkerVision, 621 F. App’x at 1019). Thus, we do not find that
`TCL’s Reply arguments discussing the word “non-negligible” were required
`to be presented in the Petition.
`At the time the Petition was filed, ParkerVision had not yet expressed
`its positions related to “storage modules” in this particular proceeding.
`Thus, we do not agree that TCL was somehow required to guess as to what
`ParkerVision’s next position would be regarding technology that is similar
`
`8
`
`

`

`IPR2021-00985 (Patent 7,292,835 B2)
`IPR2021-00990 (Patent 7,110,444 B1)
`
`to that involved in prior litigation, where Patent Owner raised different
`arguments and positions than those asserted here. The Petition set forth
`TCL’s position as to which structures teach the claimed “storage modules”
`and that position was substantially the same as ParkerVision’s assertion as to
`“storage modules” in its district court complaint filed against TCL Industries
`Holdings Co., Ltd. and other TCL entities.
`Second, we do not agree that TCL’s Reply arguments proceed in a
`new direction with a new approach as compared to the positions taken in the
`Petition. Rather, we agree with TCL that the Reply arguments “cite the
`same specific combinations of prior art (and specific figures and language
`therefrom) that are presented in the Petition.” ’985 Opp. 2 (citing Pet. Reply
`17–23). In particular, the same teachings of the prior art relied upon in the
`Petition are also relied upon in the Reply as showing the disclosure of a
`“storage module.” TCL’s Reply does not point to different structures or
`components in the prior art as compared to the Petition and ParkerVision
`does not contend to the contrary.
`In this regard, ParkerVision’s reliance on Intelligent Bio-Systems and
`SAS Institute is misplaced. ’985 Mot. 6 (quoting Consolidated Trial Practice
`Guide at 74) (citing Intelligent Bio-Sys., 821 F.3d at 1366, 1369–70; SAS
`Inst. Inc. v. Iancu, 138 S. Ct. 1348 (2018)). In Intelligent Bio-Systems, the
`U.S. Court of Appeals for the Federal Circuit found that “[the petitioner]
`supported its new theory of invalidity by reference to new evidence, citing ‘a
`number of non-patent literature references which were not relied upon to
`support unpatentability in the Petition.’” Intelligent Bio-Sys., 821 F.3d at
`1369 (quoting Intelligent Bio-Sys., Inc. v. Inc. v. Illumina Cambridge, Ltd.,
`IPR2013-00517, Paper 87 at 15–16 (PTAB Feb. 11, 2015)). The
`
`9
`
`

`

`IPR2021-00985 (Patent 7,292,835 B2)
`IPR2021-00990 (Patent 7,110,444 B1)
`
`circumstances presented in Intelligent Bio-Systems are not analogous to the
`facts presented here, where TCL’s Reply arguments do not present a new
`theory of invalidity, but rather rely on positions that ParkerVision itself
`previously presented in other litigation. Nor does SAS Institute support
`ParkerVision’s argument. SAS Institute reiterates that “the petition must
`identify ‘each claim challenged,’ the grounds for the challenge, and the
`evidence supporting the challenge.” SAS Inst., 138 S. Ct. at 1353 (citing 35
`U.S.C. § 312(a)(3)). TCL’s Petition satisfies those requirements. As the
`Federal Circuit recently explained, SAS Institute does not “delineate the
`scope of a petitioner’s ability to adapt unpatentability arguments on reply . . .
`in the face of a claim construction argument by the patent owner.” Wireless
`Protocol Innovations, Inc. v. TCT Mobile, Inc., No. 2021-2112, slip op. at 12
`(Fed. Cir. July 19, 2022) (nonprecedential). Nonetheless, we do not view
`the facts here as raising the question of whether a petitioner’s original
`unpatentability ground is undermined in a patent owner response (an issue
`that Wireless Protocol declined to address). See id. at 12–13. Rather, as
`explained above, TCL has not sought to change its original unpatentability
`ground asserted in the Petition. TCL’s Reply responds to the arguments
`asserted in ParkerVision’s Response, primarily by raising alleged
`inconsistencies with prior positions taken by ParkerVision. Accordingly,
`ParkerVision has not presented any caselaw in its Motion to Strike with
`comparable facts to those presented here to support the extraordinary relief
`requested.
`Additionally, we find the facts here more analogous to those in Apple
`Inc. v. Andrea Electric Corp., 949 F.3d 697, 706–07 (Fed. Cir. 2020), where
`the arguments raised in the petitioner’s reply brief were “responsive to” the
`
`10
`
`

`

`IPR2021-00985 (Patent 7,292,835 B2)
`IPR2021-00990 (Patent 7,110,444 B1)
`
`arguments raised in the patent owner’s response. See, e.g., ’985 Opp. 6
`(discussing case law supporting TCL’s inclusion of its arguments in its
`Reply). As noted above, TCL has not impermissibly shifted arguments;
`rather, TCL’s Reply challenges the same claims on the same grounds, and
`relies on the same prior art evidence and expert testimony cited in the
`Petition.
`
`D. Alleged Prejudice
`ParkerVision also contends that by presenting ParkerVision’s prior
`litigation positions in TCL’s Reply as opposed to the Petition, TCL has
`“deprived [ParkerVision] of the right to have its expert address this
`argument.” ’985 Mot. 7. ParkerVision asserts that, “[a]t this stage in the
`proceeding (sur-reply), [ParkerVision] is prohibited from filing an expert
`declaration and having its expert address Petitioners’ arguments. Thus,
`[ParkerVision] is prejudiced.” Id.
`Additionally, ParkerVision asserts that, even though TCL “raises its
`new theory through attorney argument instead of expert testimony,” that “is
`irrelevant” because ParkerVision “is entitled to have its expert address
`[TCL’s] theories regardless of the manner in which they make their
`arguments.” ’985 Mot. 7.
`In opposition, TCL asserts that “there is no prejudice because
`ParkerVision will not have to address anything in the Reply for the first time
`at the oral hearing.” ’985 Opp. 9 (citing Consolidated Trial Practice Guide
`at 81). TCL contends that ParkerVision has the right to file a sur-reply brief,
`“effectively mooting any supposed prejudice ParkerVision seeks to address
`in its motion to strike.” Id.
`
`11
`
`

`

`IPR2021-00985 (Patent 7,292,835 B2)
`IPR2021-00990 (Patent 7,110,444 B1)
`
`
`Additionally, TCL argues that “there ‘is a difference between
`evidence that brings unfair prejudice and evidence that is damning.’”
`’985 Opp. 9 (quoting United States v. Burt, 495 F.3d 733, 740 (7th Cir.
`2007)). TCL contends that because the Reply does not rely on new expert
`testimony or technical evidence, “there is nothing an expert would need to
`address.” Id. TCL asserts that the Reply “highlight[s] ParkerVision’s prior
`position (as memorialized by the Federal Circuit), but no amount of expert
`testimony can change the reality of ParkerVision’s previous position,
`affirmed on appeal, as to what is ‘non-negligible.’ Such prior position may
`be ‘damning,’ but highlighting it in a Reply is not unfairly prejudicial.” Id.
`We do not find that ParkerVision is prejudiced by TCL’s Reply
`arguments. First and foremost, as discussed above, the Reply arguments to
`which ParkerVision complains are those that reiterate ParkerVision’s prior
`positions on the meaning and application of “non-negligible” from other
`litigation. We do not find that ParkerVision is prejudiced by responding to
`these arguments in a sur-reply without expert rebuttal testimony. Second,
`for the reasons explained above, we find that the Reply arguments are
`appropriately included in a reply brief, and, therefore, there is no automatic
`“right” to have an expert address them. See 37 C.F.R. § 42.23(b) (“A sur-
`reply may only respond to arguments raised in the corresponding reply and
`may not be accompanied by new evidence other than the deposition
`transcripts of the cross-examination of any reply witness.”). In other words,
`a patent owner does not have an automatic “right” to submit new evidence in
`the form of expert testimony with a sur-reply brief. Third, ParkerVision has
`not explained in any detail why expert testimony is needed. TCL raised
`ParkerVision’s prior litigation position regarding “non-negligible” without
`
`12
`
`

`

`IPR2021-00985 (Patent 7,292,835 B2)
`IPR2021-00990 (Patent 7,110,444 B1)
`
`relying on new expert testimony and ParkerVision has not provided any
`specific reason why it requires expert testimony to respond in its Sur-reply.
`Fourth, ParkerVision has not requested that the Board waive any portion of
`37 C.F.R. § 42.23(b), for example, by requesting authorization to file an
`expert declaration with its Sur-reply (see 37 C.F.R. § 42.5(b) (“The Board
`may waive or suspend a requirement of parts 1, 41, and 42 and may place
`conditions on the waive or suspension.”)). Rather, ParkerVision instead
`opted to use the limited time available in this proceeding to challenge
`portions of TCL’s Reply via a motion to strike.
`Accordingly, for the reasons explained above, we do not find that
`ParkerVision has established that it will suffer prejudice if it cannot include
`an expert rebuttal declaration with its Sur-reply.
`
`E. Conclusion
`For the reasons set forth above, we conclude that TCL’s Reply does
`not raise new issues, is not accompanied by belatedly presented evidence,
`and does not otherwise exceed the proper scope of reply brief as set forth in
`37 C.F.R. § 42.23(b). Therefore, we deny ParkerVision’s Motions to Strike.
`
`III. DUE DATES
`In each proceeding, the parties stipulated to move DUE DATE 3 (the
`deadline for Patent Owner’s Sur-reply) to five days after the date of this
`Order. ’985 IPR, Paper 27 (Notice to Modify Trial Due Date 3); ’990 IPR,
`Paper 22 (same). The stipulations indicate that all other due dates remain
`unchanged. See, e.g., ’985 IPR, Paper 27 at 2. The Scheduling Order in
`each proceeding indicates that July 8, 2022 is DUE DATE 4 (Request for
`oral argument). See, e.g., ’985 IPR, Paper 15 at 10. As of the date of this
`
`13
`
`

`

`IPR2021-00985 (Patent 7,292,835 B2)
`IPR2021-00990 (Patent 7,110,444 B1)
`
`Order, which is later than July 8th, the parties have not filed requests for oral
`argument in either proceeding. To the extent the missed deadlines were
`unintentional or to the extent the parties need the Board’s authorization to
`move any deadlines not subject to change by stipulation, the parties should
`meet and confer and reach out to the Board (via a single, joint email) within
`five (5) business days of the entry of this Order to notify the Board of the
`specific changes requested.
`
`IV. ORDER
`
`Accordingly, it is
`ORDERED that ParkerVision’s Motions to Strike (IPR2021-00985,
`Paper 26; IPR2021-00990, Paper 21) are denied.
`
`
`
`14
`
`

`

`IPR2021-00985 (Patent 7,292,835 B2)
`IPR2021-00990 (Patent 7,110,444 B1)
`
`For PETITIONERS TCL Industries Holdings Co., Ltd. and Hisense Co.,
`Ltd.:
`
`Kristopher L. Reed
`Edward J. Mayle
`Matias Ferrario
`KILPATRICK TOWNSEND & STOCKTON LLP
`kreed@kilpatricktownsend.com
`tmayle@kilpatricktownsend.com
`mferrario@kilpatricktownsend.com
`
`
`For PETITIONER LG Electronics Inc.:
`
`Scott A. McKeown
`Steven Pepe
`Scott Taylor
`Matthew R. Shapiro
`ROPES & GRAY LLP
`scott.mckeown@ropesgray.com
`steven.pepe@ropesgray.com
`scott.taylor@ropesgray.com
`matthew.shapiro@ropesgray.com
`
`
`For PATENT OWNER:
`
`Jason S. Charkow
`Chandran B. Iyer
`Stephanie R. Mandir
`DAIGNAULT IYER LLP
`jcharkow@daignaultiyer.com
`ciyer@daignaultiyer.com
`smandir@daignaultiyer.com
`
`
`15
`
`

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