`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`TIANMA MICROELECTRONICS CO. LTD.,
`Petitioner,
`v .
`JAPAN DISPLAY INC.,
`Patent Owner
`_______________
`Case IPR No: IPR2021-01029
`Patent No. 9,310,654
`_______________
`
`DECLARATION OF ERIC J. KLEIN IN SUPPORT OF PATENT OWNER
`JAPAN DISPLAY INC.’S PRE-INSTITUTION SUR-REPLY
`
`US 8379078
`
`JAPAN DISPLAY INC. - EX. 2008
`TIANMA MICROELECTRONICS CO. LTD.
`v. JAPAN DISPLAY INC.
`IPR2021-01029
`
`
`
`Declaration of Eric J. Klein in support of Patent Owner’s Pre-Institution Sur-Reply
`
`I.
`
`INTRODUCTION
`
`1.
`
`I, Eric J. Klein, hereby declare under penalty of perjury that, to the best
`
`of my knowledge, the following statements are true and correct:
`
`2.
`
`I am with a partner at Vinson & Elkins LLP (“V&E”) and counsel to
`
`plaintiff Japan Display, Inc. (“Patent Owner”) in Japan Display Inc., Panasonic
`
`Liquid Crystal Display Co., Ltd. v. Tianma Microelectronics Co. Ltd., C.A. Nos.
`
`2:20-cv-00283-JRG, [LEAD CASE], 2:20-cv-00284-JRG, 2:20-cv-00285-JRG
`
`(E.D. Tex.).
`
`3.
`
`I submit this declaration in support of Patent Owner’s pre-institution
`
`sur-reply.
`
`4.
`
`I have personal knowledge of the facts provided in this declaration and
`
`can and will testify competently to them if called upon to do so.
`
`5.
`
`On October 12, 2021, the Court issued an order requiring the Patent
`
`Owner to narrow the asserted claims in the district court case to no more than eight
`
`claims from each patent and no more than a total of thirty-five claims by Monday,
`
`October 25, 2021. In its response to this Order, JDI will not drop U.S. Patent No.
`
`9,310,654 (i.e., the patent challenged in this proceeding).
`
`6.
`
`The parties are currently taking expert discovery and have agreed upon
`
`the following deposition dates:
`
`US 8379078
`
`–1–
`
`JAPAN DISPLAY INC. - EX. 2008
`TIANMA MICROELECTRONICS CO. LTD.
`v. JAPAN DISPLAY INC.
`IPR2021-01029
`
`
`
`Declaration of Eric J. Klein in support of Patent Owner’s Pre-Institution Sur-Reply
`
`Plaintiff’s Experts
`
`1)
`
`2)
`
`3)
`
`4)
`
`5)
`
`6)
`
`October 20, 2021 - Mr. Kubota (License)
`
`October 20, 2021 – Mr. Credelle (Invalidity)
`
`October 21, 2021 – Mr. Credelle (Invalidity)
`
`October 25, 2021 – Dr. Silzars (Infringement)
`
`October 26, 2021 – Dr. Silzars (Infringement)
`
`October 28, 2021 – Mr. Kemmerer (Damages)
`
`Defendant’s Experts
`
`7)
`
`8)
`
`9)
`
`10)
`
`11)
`
`12)
`
`13)
`
`14)
`
`15)
`
`16)
`
`17)
`
`18)
`
`October 21, 2021 – Mr. Katayama (License)
`
`October 21, 2021 – Mr. Flasck (Infringement)
`
`October 22, 2021 – Mr. Flasck (Infringement)
`
`October 28, 2021 – Mr. Flasck (Invalidity)
`
`October 29, 2021 – Mr. Flasck (Invalidity)
`
`October 21, 2021 – Dr. Smith (Invalidity)
`
`October 22, 2021 – Dr. Smith (Infringement)
`
`October 25, 2021 – Mr. Reed (Damages)
`
`November 2, 2021 – Dr. Schubert (Infringement)
`
`November 3, 2021 – Dr. Schubert (Infringement)
`
`November 16, 2021 – Dr. Schubert (Invalidity)
`
`November 17, 2021 – Dr. Schubert (Invalidity)
`
`US 8379078
`
`–2–
`
`JAPAN DISPLAY INC. - EX. 2008
`TIANMA MICROELECTRONICS CO. LTD.
`v. JAPAN DISPLAY INC.
`IPR2021-01029
`
`
`
`Declaration of Eric J. Klein in support of Patent Owner’s Pre-Institution Sur-Reply
`
`This declaration and my opinions herein are made to the best of my knowledge
`
`and understanding, and based on the material available to me, at the time of signing
`
`this declaration. I declare that all statements made herein on my own knowledge are
`
`true and that all statements made on information and belief are believed to be true,
`
`and further, that these statements were made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under 18 U.S.C. § 1001.
`
`Respectfully submitted,
`
`Dated: October 22, 2021
`
`/Eric J. Klein/
`Eric J. Klein
`
`US 8379078
`
`–3–
`
`JAPAN DISPLAY INC. - EX. 2008
`TIANMA MICROELECTRONICS CO. LTD.
`v. JAPAN DISPLAY INC.
`IPR2021-01029
`
`
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