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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________
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`UNIFIED PATENTS, LLC
`Petitioner
`
`v.
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`MEMORYWEB, LLC
`Patent Owner
`____________
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`Case No. IPR2021-01413
`Patent 10,621,228
` ____________
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`PETITIONER’S UPDATED MANDATORY NOTICES
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`MemoryWeb Ex. 2029
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
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`
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`IPR2021-01413
`U.S. Patent 10,621,228
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`Pursuant to 37 C.F.R. § 42.8(b)(1), Unified Patents, LLC (“Unified” or
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`“Petitioner”) certifies that Unified is the sole real party-in-interest and certifies that
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`no other party exercised control or could exercise control over Unified’s
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`participation in this proceeding, filing this petition, or conduct in any ensuing trial.
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`On March 8, 2023, the Board issued an order finding “that Apple, Inc. and Samsung
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`Electronics Co., Ltd. are Real Parties in Interest to this Proceeding[.]” Paper 56, 34.
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`Unified disagrees with this finding and is in the process of seeking review of it. The
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`Order required Petitioner to update its mandatory notices consistent with the order.
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`Id. This filing is a response to that requirement.
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`Petitioner does not waive any rights to seek review, appeal, or otherwise
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`challenge the findings of Paper 56 by this filing.
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`The Board has approved of similar actions taken by other petitioners when a
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`finding regarding real party-in-interest has been contested. Proppant Express
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`Investments, LLC, et al. v. Oren Techs., LLC, IPR2018-00733, Paper 34, 6 (PTAB
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`Feb. 20, 2019) (“we see nothing wrong with this approach as the identification
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`fulfills the key purposes of identifying the real parties in interest—namely,
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`‘identifying potential conflicts, and to assure proper application of the statutory
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`estoppel provisions.’”); Intel Corp. v. Hera Wireless S.A., IPR2018-01372, Paper 24
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`1
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`MemoryWeb Ex. 2029
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
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`
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`IPR2021-01413
`U.S. Patent 10,621,228
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`(PTAB Jan. 9, 2019) (allowing Petitioner to update Mandatory Notices “without
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`conceding that they would be determined to be real parties in interest under the
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`governing legal standard”); Office Patent Trial Practice Guide, 77 Fed. Reg. 48,756,
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`48,759 (Aug. 14, 2012).
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`Date: March 10, 2023
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`Respectfully submitted,
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` /Roshan Mansinghani/
`Roshan Mansinghani
`Reg. No. 62,429
`Counsel for Petitioner
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`2
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`MemoryWeb Ex. 2029
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
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`CERTIFICATE OF SERVICE
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`IPR2021-01413
`U.S. Patent 10,621,228
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`The undersigned hereby certifies
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`that a copy of
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`the
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`foregoing
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`PETITIONER’S UPDATED MANDATORY NOTICES was served on March 10,
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`2023, via electronic mail, as agreed to by counsel, upon the following counsel for
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`Patent Owner:
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`Date: March 10, 2023
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`Jennifer Hayes
`Nixon Peabody LLP
`300 South Grand Avenue, Suite 4100
`Los Angeles, CA 90071-3151
`jenhayes@nixonpeabody.com
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`George Dandalides
`Nixon Peabody LLP
`70 West Madison, Suite 5200
`Chicago, IL 60602-4224
`gdandalides@nixonpeabody.com
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`Matthew A. Werber
`Nixon Peabody LLP
`70 West Madison, Suite 5200
`Chicago, IL 60602-4224
`mwerber@nixonpeabody.com
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`/Ashley F. Cheung/
`Ashley F. Cheung
`Paralegal
`Unified Patents, LLC
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`MemoryWeb Ex. 2029
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
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