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U.S. Patent No. 10,621,228
`Patent Owner’s Unopposed Request for
`Entry of Corrected Patent Owner’s Response
`IPR2022-00222
`
`
`Paper No.
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD. et al,
`Petitioner
`v.
`
`MEMORYWEB, LLC
`Patent Owner
`
`Patent No. 10,621,228
`
`Inter Partes Review No. IPR2022-00222
`
`
`
`
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`
`UNOPPOSED REQUEST FOR ENTRY OF CORRECTED PATENT
`OWNER’S RESPONSE
`
`
`
`
`1
`
`

`

`U.S. Patent No. 10,621,228
`Patent Owner’s Unopposed Request for
`Entry of Corrected Patent Owner’s Response
`IPR2022-00222
`
`Exhibit No.
`
`Description
`
`2001
`
`2002
`
`2003
`
`2004
`
`2005
`
`2006
`
`2007
`
`2008
`
`2009
`
`2010
`
`2011
`
`2012
`
`2013
`
`
`
`
`
`Withdrawn
`
`Japanese Unexamined Patent Application Publication No. 2001-
`160058 and Certified English Translation (“Fujiwara”)
`
`Withdrawn
`
`U.S. Patent No. 6,714,215 (“Flora”)
`
`Supplemental Declaration of Kevin Jakel, Unified Patents, LLC v.
`MemoryWeb, LLC, IPR2021-01413 (Dec. 30, 2021) (redacted
`version)
`
`3 Questions for Unified Patents CEO Post-Oil States (Part II)
`
`Petition for Inter Partes Review, Apple Inc. v. MemoryWeb, LLC,
`IPR2022-00031, Paper 1 (PTAB Oct. 30, 2021)
`
`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
`
`Unified Patent’s website link (FAQs)
`(https://www.unifiedpatents.com/faq)
`
`Case Readiness Status Report, MemoryWeb, LLC v. Samsung
`Electronics Co., Ltd. and Samsung Electronics America, Inc., Case
`No. 21-cv-411 (W.D. Tex.) (Sept. 3, 2021)
`
`Amended Complaint, MemoryWeb, LLC v. Samsung Electronics
`Co., Ltd. and Samsung Electronics America, Inc., Case No. 21-cv-
`
`2
`
`

`

`U.S. Patent No. 10,621,228
`Patent Owner’s Unopposed Request for
`Entry of Corrected Patent Owner’s Response
`IPR2022-00222
`
`Exhibit No.
`
`Description
`
`411 (W.D. Tex.) (Nov. 24, 2021)
`
`Excerpts from Defendant Samsung Electronics Co. Ltd. and
`Samsung Electronics America, Inc.’s Initial Invalidity Contentions,
`MemoryWeb, LLC v. Samsung Electronics Co., Ltd. and Samsung
`Electronics America, Inc., Case No. 21-cv-411 (W.D. Tex.) (Jan.
`31, 2022)
`
`Joint Motion for Entry of Agreed Scheduling Order, MemoryWeb,
`LLC v. Samsung Electronics Co., Ltd. and Samsung Electronics
`America, Inc., Case No. 21-cv-411 (W.D. Tex.) (Oct. 1, 2021)
`
`MV3 Partners LLC v. Roku Inc., 6:18-cv-00308, (W.D. Texas) D.I.
`83
`
`IAM, “The last thing anyone should think about WDTX is that it is
`patent plaintiff friendly, says Albright” (Apr. 7, 2020)
`
`Pages from The Way Back Machine The Wayback Machine-
`https://web.archive.org/web/20000510141416/http://www.photo.net
`:80
`
`Cluster Map, Thumbnail, First Combination Comparison
`
`Japanese Unexamined Patent Application Publication No. 2007-
`323544 and Certified English Translation (“Takakura”)
`
`Patent Owner Response, Unified Patents, LLC v. MemoryWeb, LLC,
`IPR2021-01413, Paper 30 (Redacted Version)
`
`Transcript of the deposition of Dr. Philip Greenspun dated August
`26, 2022
`
`Declaration of Professor Glenn Reinman, Ph.D
`
`3
`
`2014
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`2015
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`2016
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`2017
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`2018
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`2019
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`2020
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`2021
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`2022
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`2023
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`

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`U.S. Patent No. 10,621,228
`Patent Owner’s Unopposed Request for
`Entry of Corrected Patent Owner’s Response
`IPR2022-00222
`
`Exhibit No.
`
`Description
`
`2024
`
`
`
`Corrected Patent Owner’s Response
`
`
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`
`4
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`

`

`U.S. Patent No. 10,621,228
`Patent Owner’s Unopposed Request for
`Entry of Corrected Patent Owner’s Response
`IPR2022-00222
`
`
`Patent Owner, MemoryWeb, LLC, respectfully requests entry of the
`
`Corrected Patent Owner Response, filed herewith at Exhibit 2024. The Board
`
`authorized filing of this request on November 3, 2022.
`
`The Patent Owner Response (Paper 19) inadvertently referenced the wrong
`
`exhibit number when citing a deposition transcript in three places (“EX2002” vs.
`
`“EX2022”). See POR pages 32, 39, 59. The Corrected Patent Owner Response
`
`corrects those three errors. No other changes have been made. Petitioner,
`
`Samsung, does not oppose this request.
`
`The undersigned attorney welcomes a telephone call should the Board have
`
`any requests or questions.
`
`For the foregoing reasons, Patent Owner respectfully requests entry of the
`
`Corrected Patent Owner Response.
`
`Respectfully Submitted,
`
`November 7, 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
`
`
`
`
`
`5
`
`

`

`U.S. Patent No. 10,621,228
`Patent Owner’s Unopposed Request for
`Entry of Corrected Patent Owner’s Response
`IPR2022-00222
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Patent
`
`Owner’s Unopposed Request for Entry of Corrected Patent Owner’s
`
`Response, and the exhibit filed therewith, were served on November 7, 2022, by
`
`email:
`
`axf-ptab@fr.com
`
`in@fr.com
`
`jjm@fr.com
`
`cgreen@fr.com
`
`IPR39843-0117IP1@fr.com
`
`PTABInbound@fr.com
`
`Counsel for Petitioner, Samsung Electronics Co., LTD.
`
`By: /s/ Jennifer Hayes
`Counsel for Patent Owner
`
`6
`
`
`
`
`
`
`

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