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U.S. Patent No. 10,621,228
`Patent Owner’s Updated Exhibit List
`IPR2021-01413
`
`
`
`Paper No.
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS, LLC
`Petitioner
`v.
`
`MEMORYWEB, LLC
`Patent Owner
`
`Patent No. 10,621,228
`
`Inter Partes Review No. IPR2021-01413
`
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`PATENT OWNER’S UPDATED EXHIBIT LIST
`
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`
`
`

`

`U.S. Patent No. 10,621,228
`Patent Owner’s Updated Exhibit List
`IPR2021-01413
`
`
`LISTING OF EXHIBITS
`
`
`Description
`
`Exhibit No.
`
`2001
`
`2002
`
`2003
`
`2004
`
`2005
`
`2006
`
`2007
`
`2008
`
`2009
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`2010
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`2011
`
`2012
`
`2013
`
`2014
`
`WITHDRAWN
`
`Japanese Unexamined Patent Application Publication No. 2001-
`160058 and Certified English Translation (“Fujiwara”)
`
`Japanese Unexamined Patent Application Publication No. 2007-
`323544 and Certified English Translation (“Takakura”)
`
`U.S. Patent No. 9,552,376 (“the ’376 patent”)
`
`U.S. Patent No. 10,423,658 (“the ’658 patent”)
`
`U.S. Patent No. 11,163,823 (“the ’823 patent”)
`
`’376 patent Prosecution History
`
`Reserved
`
`Transcript of October 15, 2019 Deposition of Kevin Jakel
`(IPR2019-00482)
`
`Non-confidential Brief of Barkan Wireless IP Holdings on
`Appeal from IPR2018-01186
`
`3 Questions for Unified Patents CEO Post-Oil States (Part II)
`
`Brief of Amicus Curiae Unified Patents Inc. in Cuozzo Speed
`Technologies, LLC v. Michelle K. Lee et al.
`
`Unified Patents September 3, 2021 Press Release regarding
`MemoryWeb IPR
`
`Unified Patents September 9, 2021 email regarding MemoryWeb
`IPR
`
`1
`
`

`

`U.S. Patent No. 10,621,228
`Patent Owner’s Updated Exhibit List
`IPR2021-01413
`
`
`Exhibit No.
`
`Description
`
`2015
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`2016
`
`2017
`
`2018
`
`2019
`
`2020
`
`2021
`
`2022
`
`2023
`
`2024
`
`2025
`
`2026
`
`2027
`
`2028
`
`2029
`
`Unified Patent’s website link (Benefits for Large Company
`Members)
`
`Unified Patent’s website link (Unified Patents’ Collaborative
`Deterrence Approach)
`
`Unified Patent’s website link (Zones)
`(https://www.unifiedpatents.com/npe)
`
`Unified Patent’s website link (Success)
`(https://www.unifiedpatents.com/success)
`
`Unified Patent’s website link (FAQs)
`(https://www.unifiedpatents.com/faq)
`
`U.S. Patent App. Pub. No. 2010/0058212 A1 to Belitz et al.
`(“Belitz”)
`
`U.S. Patent No. 9,098,531 (“the ‘531 patent”)
`
`U.S. Patent No. 11,017,020 (“the ‘020 patent”)
`
`U.S. Patent No. 11,170,042 (“the ‘042 patent”)
`
`Jaffe et al., Generating Summaries and Visualization for Large
`Collections of Geo-Referenced Photographs (“Jaffe”)
`
`U.S. Patent Pub. No. 2009/0113350 (“Hibino”)
`
`U.S. Patent Pub. No. 2006/0165380 (“Tanaka”)
`
`Member Email Dated September 7, 2021 (CONFIDENTIAL)
`
`Email List for Member Email Dated September 7, 2021
`(CONFIDENTIAL)
`
`News Update Dated March 14, 2022 (CONFIDENTIAL)
`
`2
`
`

`

`U.S. Patent No. 10,621,228
`Patent Owner’s Updated Exhibit List
`IPR2021-01413
`
`
`Exhibit No.
`
`Description
`
`2030
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`2031
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`2032
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`2033
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`2034
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`2035
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`2036
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`2037
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`2038
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`2039
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`2040
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`2041
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`2042
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`Email List for News Update Dated March 14, 2022
`(CONFIDENTIAL)
`
`Unified Patents Web Page at www.unifiedpatents.com/npe/
`
`Email Dated October 24, 2021 (CONFIDENTIAL)
`
`Samsung Membership Report September 2021 Slide Deck
`(CONFIDENTIAL)
`
`Unified US Challenges Spreadsheet (CONFIDENTIAL)
`
`Transcript of the Deposition of Dr. Benjamin Bederson Dated
`May 24, 2022 Volumes. I and II.
`
`Transcript of the Deposition of Kevin Jakel Dated May 26, 2022
`(CONFIDENTIAL)
`
`Defendants’ Opening Claim Construction Brief Dated March 28,
`2022, WDTX Case No. 6:21-cv-00411-ADA
`
`Declaration of Professor Glenn Reinman, Ph.D. in Support of
`Patent Owner Response
`
`September 24, 2021 Letter from Bita Rahebi to Daniel J.
`Schwartz
`
`Japanese Unexamined Patent Application Publication No. 2007-
`323544 and Certified English Translation (“Takakura”)
`
`Cambridge English Dictionary entry for “Responsive”
`
`Cambridge English Dictionary entry for “Causing”
`
`3
`
`

`

`U.S. Patent No. 10,621,228
`Patent Owner’s Updated Exhibit List
`IPR2021-01413
`
`
`Exhibit No.
`
`Description
`
`Dictionary.com entry for “Causing”
`
`Views # 1 - 3 Visual
`
`U.S. Patent No. 11,061,524 to Bederson et al.
`
`Transcript of the Deposition of Dr. Benjamin Bederson Dated
`September 29, 2022
`
`Patent Owner’s Demonstrative Exhibit
`
`2043
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`2044
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`2045
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`2046
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`2047
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`
`
`4
`
`

`

`U.S. Patent No. 10,621,228
`Patent Owner’s Updated Exhibit List
`IPR2021-01413
`
`
`Respectfully submitted,
`
`Dated: December 14, 2022
`
`
`
`
`
`By: /Jennifer Hayes/
`Jennifer Hayes
`Reg. No. 50,845
`Nixon Peabody LLP
`300 South Grand Avenue,
`Suite 4100,
`Los Angeles, CA 90071-3151
`Tel. 213-629-6179
`Fax 866-781-9391
`
`1
`
`

`

`U.S. Patent No. 10,621,228
`Patent Owner’s Updated Exhibit List
`IPR2021-01413
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Patent Owner’s
`
`Updated Exhibit List together with Patent Owner’s Demonstrative Exhibit filed
`
`herewith was served on December 14, 2022, upon the following parties via
`
`electronic service:
`
`
`
`
`
`
`
`ellyar@unifiedpatents.com
`
`michelle@unifiedpatents.com
`
`Counsel for Petitioner, Unified Patents, LLC
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By:
`
`/s/ Jennifer Hayes
`Lead Counsel for Patent Owner
`
`1
`
`

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