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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`MICRON TECHNOLOGY, INC.,
`Petitioner
`
`v.
`
`VERVAIN, LLC,
`Patent Owner
`_____________
`
`Case: IPR2021-01549
`U.S. Patent No. 9,997,240
`_____________
`
`
`
`PATENT OWNER’S CURRENT LIST OF EXHIBITS
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`Exhibit
`
`EXHIBIT LIST
`
`Description
`
`Ex. 2001 Declaration of Dr. Sunil Khatri
`
`Ex. 2002 Chen et al., Ultra MLC Technology Introduction,
`Advantech Technical White Paper (Oct. 5, 2012)
`(“Chen”)
`
`Ex. 2003 Excerpts from Micheloni et al., Inside NAND Flash
`Memories (1st ed. 2010) (“Micheloni”)
`
`Ex. 2004 U.S. Patent No. 10,950,300 to G.R. Mohan Rao (“’300
`Patent”)
`
`Ex. 2005 Microsoft Computer Dictionary definition for “data
`integrity”
`
`Ex. 2006 Hargrave’s Communications Dictionary definition for
`“data integrity”
`
`Ex. 2007 https://www.law360.com/articles/1381597/albright-says-
`he-ll-very-rarely-put-cases-on-hold-for-ptab
`
`Ex. 2008 Docket Sheet for Case. No. 6:21-cv-487-ADA; Vervain v.
`Micron Technology et al.; U.S. District Court, Western
`District of Texas.
`
`Ex. 2009 Exhibit C-3, Invalidity Claim Chart for the ’240 Patent
`based on U.S. Patent Application Pub. No. 2011/0099460
`(“Dusija”)
`
`Ex. 2010 Exhibit C-18, Invalidity Claim Chart for the ’240 Patent
`based on U.S. Patent Application Pub. No. US
`2008/0140918 (“Sutardja”)
`
`Ex. 2011 Micron’s Preliminary Invalidity Contentions for U.S.
`Patent Nos. 8,891,298; 9,196,385; 9,997,240; and
`10,950,300; Case. No. 6:21-cv-487-ADA; Vervain v.
`
`1
`
`
`
`Previously
`Submitted
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`X
`
`

`

`
`
`X
`
`
`
`X
`
`X
`
`X
`
`
`
`X
`
`
`
`
`
`Micron Technology et al.; U.S. District Court, Western
`District of Texas.
`
`Ex. 2012 Claim Construction Order in Vervain v. Micron Tech.,
`Inc., No. 6:21-cv-487-ADA (W.D. Tex.) and Vervain v.
`Western Digital Corp., No. 6:21-cv-488-ADA (W.D.
`Tex.) (Jan. 24, 2022)
`
`Ex. 2013 Intentionally Omitted
`
`Ex. 2014 Declaration of Dr. Sunil Khatri in Support of Patent
`Owner’s Response
`
`Ex. 2015 Transcript of June 10, 2022 Deposition of Dr. David Liu
`
`Ex. 2016 U.S. Patent No. 8,285,940
`
`Ex. 2017-
`2019
`
`Intentionally omitted
`
`Ex. 2020 Transcript of November 1, 2022 Deposition of Dr. David
`Liu
`
`Ex. 2021 Intentionally Omitted
`
`Ex. 2022 Patent Owner’s Demonstrative
`
`
`Dated: January 9, 2023
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`/s/ Alan Whitehurst
`Alan Whitehurst
`Reg. No. 43,263
`
`
`
`
`
`
`
`2
`
`

`

`
`
`CERTIFICATION OF SERVICE
`
`
`
`The undersigned hereby certifies that the foregoing PATENT OWNER’S
`
`CURRENT LIST OF EXHIBITS has been served on Petitioner via email on the
`
`following counsel of record for Petitioner:
`
`Jeremy Jason Lang (Lead Counsel)
`PTABDocketJJL2@orrick.com
`Christopher Childers (Back-up Counsel)
`PTABDocketC4C8@orrick.com
`Parth Sagdeo (Back-up Counsel)
`PTABDocketP2S7@orrick.com
`Jared Bobrow (Back-up Counsel)
`PTABDocketJ3B3@orrick.com
`Orrick
`1000 Marsh Road
`Menlo Park, CA 94025-1015
`Telephone: (650) 614-7400
`Facsimile: (650) 614-7401
`
`
`
`
`Dated: January 9, 2023
`
`By: /s/ Alan Whitehurst
`Alan Whitehurst
`Reg. No. 43,263
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`

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