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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________________________
`
`
`APPLE INC.,
`
`Petitioner
`
`v.
`
`CPC PATENT TECHNOLOGIES PTY, LTD.,
`
`Case IPR2022-00602
`
`U.S. Patent No. 9,665,705
`____________
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`PETITIONER’S UPDATED EXHIBIT LIST
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`IPR2022-00602
`U.S. Patent No. 9,665,705
`
`to
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`APPENDIX OF EXHIBITS
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`Exhibit 1001 U.S. Patent No. 9,665,705 to Burke (“the ’705 Patent”)
`Exhibit 1002 File History for the ’705 Patent (“the ’818 Application File
`History”)
`Exhibit 1003 Declaration of Dr. Andrew Sears
`Exhibit 1004 U.S. Patent Application Publication No. 2004/0123113
`Mathiassen et al. (“Mathiassen”)
`Exhibit 1005 U.S. Patent No. 6,766,456 to McKeeth (“McKeeth”)
`Exhibit 1006 U.S. Patent No. 6,509,847 to Anderson (“Anderson”)
`Exhibit 1007 U.S. Patent No. 6,927,668 to Odle et al. (“Odle”)
`Exhibit 1008 Exhibit intentionally left blank
`Exhibit 1009 Merriam Webster, Webster’s New Collegiate Dictionary, 1981
`Exhibit 1010 U.S. Patent No. 6,612,928 to Bradford, et al. (“Bradford”)
`Exhibit 1011 Anil Jain, et al., Biometric Identification, Communication of the
`ACM, February 2000
`Exhibit 1012 Henry C. Lee, et al., Advances in Fingerprint Technology, Second
`Edition, CRC Press, copyright 2001
`Exhibit 1013 P. Jonathon Phillips, et al., An Introduction to Evaluating
`Biometric Systems, National
`Institute of Standards and
`Technology, IEEE, copyright 2000
`Exhibit 1014 U.S. Patent Publication No. 2003/0117261 to Gunsch (“Gunsch”)
`Exhibit 1015 U.S. Patent Publication No. 2003/0036825 to Kim (“Kim”)
`Exhibit 1016 U.S. Patent No. 6,140,939 to Flick (“Flick”)
`Exhibit 1017 U.S. Patent No. 6,164,403 to Wuidart (“Wuidart”)
`Exhibit 1018 U.S. Patent No. 7,239,227 to Gupta, et al. (“Gupta”)
`Exhibit 1019 U.S. Patent No. 6,877,097 to Hamid, et al. (“Hamid”)
`Exhibit 1020 U.S. Patent Publication No. 2001/0049785 to Kawan, et al.
`(“Kawan”)
`Exhibit 1021 U.S. Patent Publication No. 2002/0091937 to Ortiz (“Ortiz”)
`Exhibit 1022 U.S. Patent Publication No. 2003/0046552 to Hamid (“Hamid
`’552”)
`Exhibit 1023 U.S. Patent Publication No. 2002/0063154 to Hoyos, et al.
`(“Hoyos”)
`Exhibit 1024 U.S. Patent No. 6,484,260 to Scott, et al. (“Scott”)
`Exhibit 1025 U.S. Patent No. 7,404,086 to Sands, et al. (“Sands”)
`Exhibit 1026 Ross Tester, A Rolling Code 4-Channel UHF Remote Control:
`What is “Code Hopping” or “Rolling Code”, Silicon Chip.com.au,
`July 2002
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`

`

`Code,
`
`IPR2022-00602
`U.S. Patent No. 9,665,705
`Exhibit 1027 Brent A. Miller, et al., Bluetooth Revealed: The Insider’s Guide to
`an Open Specification for Global Wireless Communications, 2001
`Exhibit 1028 U.S. Patent No. 7,284,266 to Morris, et al. (“Morris”)
`Exhibit 1029 Bricolage:
`Data
`Compression
`– Morse
`https://perl.plover.com/Huffman/huffman.html, 1998
`Exhibit 1030 U.S. Patent No. 6,323,565 to Williams, Jr., et al. (“Williams”)
`Exhibit 1031 U.S. Patent No. 7,020,270 to Ghassabian (“Ghassabian”)
`Exhibit 1032 U.S. Patent Publication No. 2003/0048260 to Matusis (“Matusis”)
`Exhibit 1033
`International Publication WO 02/27455
`to Mathiassen
`(“Mathiassen ’455”)
`Exhibit 1034 European Patent Application No. 88301738.6 to Araki et al.
`(“Araki”)
`Exhibit 1035 U.S. Patent No. 7,152,045 to Hoffman (“Hoffman”)
`Exhibit 1036 U.S. Patent No. 6,833,785 to Brown, et al. (“Brown”)
`Exhibit 1037 U.S. Patent Publication No. 2004/0015450 to Zingher, et al.
`(“Zingher”)
`Exhibit 1038 U.S. Patent No. 6,498,970 to Colmenarez, et al. (“Colmenarez”)
`Exhibit 1039 U.S. Patent No. 6,100,811 to Hsu, et al. (“Hsu”)
`Exhibit 1040 U.S. Patent No. 4,638,292 to Mochida, et al. (“Mochida”)
`Exhibit 1041 K-9 Car Alarm Owner’s Guide and Installation Instructions, K-9
`Mundial, Omega Research and Development, 2000
`Exhibit 1042 U.S. Patent No. 7,110,580 to Bostrom (“Bostrom”)
`Exhibit 1043 U.S. Patent No. 7,336,174 to Maloney (“Maloney”)
`Exhibit 1044 Microsoft Press Computer Dictionary, second edition, Microsoft
`Press, 1994
`Exhibit 1045 Microsoft Computer Dictionary, fifth edition, Microsoft Press,
`2002
`Exhibit 1046 OnStar Features, OnStar,
`https://web.archive.org/web/20000619021703/http://www.onstar.
`com/features/3button.htm June 19, 2000
`Exhibit 1047 U.S. Patent No. 6,420,975 to DeLine, et al. (“DeLine”)
`Exhibit 1048 Exhibit Intentionally left blank
`Exhibit 1049 PC Basics: Get a Great Start, Survive and Thrive, 2002
`Exhibit 1050 U.S. Patent Publication 2003/0160692 to Nonaka (“Nonaka”)
`Exhibit 1051 U.S. Patent No. 5,307,048 to Sonders (“Sonders”)
`Exhibit 1052 Merriam Webster’s Collegiate Dictionary, tenth edition, 1998
`Exhibit 1053 Alan Gatherer, et al., The Application of Programmable DSPs in
`Mobile Communications: Biometric Systems applied to Mobile
`Communications, 2002
`
`
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`2
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`

`

`IPR2022-00602
`U.S. Patent No. 9,665,705
`Exhibit 1054 McGraw-Hill, Dictionary of Electrical and Computer Engineering,
`2003
`Exhibit 1055 U.S. Patent No. 6,970,970 to Jung et al. (“Jung”)
`Exhibit 1056 Exhibit Intentionally left blank
`Exhibit 1057 Exhibit Intentionally left blank
`Exhibit 1058 Exhibit Intentionally left blank
`Exhibit 1059 Exhibit Intentionally left blank
`Exhibit 1060 Exhibit Intentionally left blank
`Exhibit 1061 Exhibit Intentionally left blank
`Exhibit 1062 Exhibit Intentionally left blank
`Exhibit 1063 Exhibit Intentionally left blank
`Exhibit 1064 Exhibit Intentionally left blank
`Exhibit 1065
` Case No. 6:21-cv-00166-ADA Scheduling Order (Dkt No. 37)
`Exhibit 1066 Case No. 6:21-cv-00165-ADA Motion to Transfer Venue (Dkt No.
`22
`Exhibit 1067 Federal Court Management Statistics–Comparison Within Circuit,
`June 30, 2021 (Average time to trial statistics)
`Exhibit 1068 Scott McKeown, District Court Trial Dates Tend to Slip After PTAB
`Discretionary Denials, July 24, 2020
`Exhibit 1069 Case No. 1:21-cv-00896-ADA, Order Setting Jury Selection and
`Trial (Dkt No. 423)
`Judge Albright’s Second Amended Standing Order Regarding
`Motions for Inter-District Transfer, August 18, 2021
`Exhibit 1071
`In re Apple Inc., No 20-135 Order (Dkt No. 55)
`Exhibit 1072 Case No. 6:21-cv-00165 (W.D. Tex.), Plaintiff CPC Patent
`Technologies Pty Ltd.’s Proposed Claim Constructions (“CPC’s
`Initial Constructions”)
`Exhibit 1073 Case No. 6:21-cv-00165 (W.D. Tex.), Plaintiff CPC Patent
`Technologies Pty Ltd.’s Proposed Updated Claim Constructions
`(“CPC’s Initial Updated Constructions”)
`* Note that document was served without a cover page
`Exhibit 1074 Case No. 6:21-cv-00165 (W.D. Tex.), Joint Claim Construction
`Statement
`Exhibit 1075 Case No. 6:21-cv-00165 (W.D. Tex.), Plaintiff CPC Patent
`Technologies Pty Ltd.’s Response to Defendant Apple Inc.’s Claim
`Construction Brief
`Exhibit 1076 Case No. 6:21-cv-00165 (W.D. Tex.), Plaintiff CPC Patent
`Technologies Pty Ltd.’s Sur-Reply to Defendant Apple Inc.’s
`Claim Construction Brief
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`Exhibit 1070
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`3
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`

`

`IPR2022-00602
`U.S. Patent No. 9,665,705
`Exhibit 1077 Case No. 6:21-cv-00165 (W.D. Tex.), Claim Construction Order,
`Dated February 10, 2022
`Exhibit 1078 Case No. 6:21-cv-00166 (W.D. Tex.), Email from Peter Tong, Law
`Clerk to J. Albright, to the Parties Re Meet & Confer, Dated
`February 10, 2022
`Exhibit 1079 Case No. 6:21-cv-00165 (W.D. Tex.), Email from George
`Summerfield, CPC Counsel, to the Court Re Narrowed Claims and
`Agreed-Upon Constructions, Dated February 14, 2022
`Exhibit 1080 Case No. 6:21-cv-00166 (W.D. Tex.), Claim Construction Order,
`Dated January 25, 2022 (“HMD Claim Construction Order”)
`Exhibit 1081 Order on Motion to Transfer
`Exhibit 1082 Order on Motion to Expedite
`Exhibit 1083 Order rescheduling the hearing for August 29, 2022
`Exhibit 1084 Trial Statistics
`Exhibit 1085 Order continuing Fintiv trial
`Exhibit 1086 CPC/HMD Order Extending Schedule
`Exhibit 1087 J. Albright Statistics
`Exhibit 1088 Case No. 5:22-cv-02553-EJD (N. Ca.), Order Further Staying Case
`Exhibit 1089 Deposition Transcript of Dr. William C. Easttom, III on February
`27, 2023
`Exhibit 1090 Supplemental Declaration of Dr. Andrew Sears
`Exhibit 1091 Petitioner’s Demonstratives
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`IPR2022-00602
`U.S. Patent No. 9,665,705
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`Respectfully submitted,
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`ERISE IP, P.A.
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`
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`BY: /s/ Jennifer C. Bailey
`Jennifer C. Bailey Reg. No. 52,583
`Adam P. Seitz, Reg. No. 52,206
`7015 College Blvd., Suite 700
`Overland Park, KS 66211
`P: (913) 777-5600
`F: (913) 777-5601
`jennifer.bailey@eriseip.com
`adam.seitz@eriseip.com
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`ATTORNEYS FOR PETITIONER
`APPLE INC.
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`IPR2022-00602
`U.S. Patent No. 9,665,705
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`CERTIFICATE OF SERVICE ON CPC
`UNDER 37 C.F.R. § 42.6
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on June 22,
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`2023, the foregoing Petitioner Updated Exhibit List and EX1091 were served via
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`electronic filing with the Board and via Electronic Mail on the following
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`practitioners of record for CPC:
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`Darlene F. Ghavimi-Alagha (Darlene.Ghavimi@klgates.com)
`Brian P. Bozzo (brian.bozzo@klgates.com)
`George C. Summerfield (George.Summerfield@klgates.com)
`Jonah Heemstra (Jonah.Heemstra@klgates.com)
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`/s/ Jennifer C. Bailey
`Jennifer C. Bailey, Reg. No. 52,583
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`ATTORNEY FOR PETITIONER
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