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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`
`
`SAMSUNG ELECTRONICS CO., LTD, MICRON TECHNOLOGY, INC.,
`MICRON SEMICONDUCTOR PRODUCTS, INC., and
`MICRON TECHNOLOGY TEXAS LLC
`Petitioner,
`
`v.
`
`NETLIST, INC.,
`Patent Owner.
`
`
`___________________
`
`Case No. IPR2022-00996
`Patent No. 11,016,918
`___________________
`
`
`PATENT OWNER’S MOTION TO SUBMIT SUPPLEMENTAL
`INFORMATION PURSUANT TO 37 C.F.R. §42.123(b)
`
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`Case No. IPR2022-00996
`Patent No. 11,016,918
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`TABLE OF CONTENTS
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`Page
`Nature of Supplemental Information Sought to be Submitted ..................... 1
`I.
`Relevance of the Supplemental Information ................................................ 2
`II.
`III. The Supplemental Information Could Not Be Obtained Earlier .................. 4
`IV. Admission of the Supplemental Information is in Interest-of-Justice .......... 5
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`11267144
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`Case No. IPR2022-00996
`Patent No. 11,016,918
`
`TABLE OF AUTHORITIES
`
` Page(s)
`
`Cases
`Environment Designs, Ltd. v. Union Oil Co. of Cal.,
`713 F.2d 693, 218 USPQ 865 (Fed. Cir. 1983) .................................................... 3
`Kingston Tech. Co., Inc. v. Spex Techs., Inc.,
`No. IPR2017-01021, Paper 31 (PTAB May 29, 2018) ........................................ 5
`Regulations
`37 C.F.R. §42.123(b) ................................................................................................. 1
`Fed. R. Evid. 801(2) ................................................................................................... 2
`Fed. R. Evid. 804(3) ................................................................................................... 2
`
`11267144
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`Case No. IPR2022-00996
`Patent No. 11,016,918
`Netlist respectfully moves to submit the deposition transcript excerpts
`
`attached to this motion as supplemental information under 37 C.F.R. §42.123(b).
`
`I.
`
`Nature of Supplemental Information Sought to be Submitted
`The supplemental information consists of testimony from Micron’s corporate
`
`representative, Boe Holbrook, given in a parallel litigation between Patent Owner
`
`and Petitioner Micron in which the ’918 patent is at issue. See Attachment A, 1;
`
`EX2071, 1.
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`Mr. Holbrook has been with Micron since 2002 and his title is Senior Manager
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`in the Module Development Group. EX2065, ¶2; see also Attachment A, 10:17-21.
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`In the parallel litigation, Micron designated Mr. Holbrook as its 30(b)(6) corporate
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`representative on over a dozen topics, including non-infringement EX2066, 29
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`(Topic #89); EX2067 (Micron’s counsel designating Mr. Holbrook for Topic #89).
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`In order to testify on “all facts and circumstances” relating to non-infringement of
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`the ’918 patent, Mr. Holbrook reviewed the ’918 patent: “Q. You understand that
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`Micron is accused of infringing a number of Netlist patents in this case. Correct? A.
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`I understand that. Q. And did you review those patents in preparation for your
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`testimony? A. Yes, sir.” Mr. Holbrook testified he led the design of memory
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`modules at Micron: “Q. Is there anyone more senior than you in module
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`development? A. No, sir.” Attachment A, 10:17-19.
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`Case No. IPR2022-00996
`Patent No. 11,016,918
`The testimony is non-hearsay under FRE 801(2) as Mr. Holbrook testified on
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`the operation and structure of DDR5 modules that are covered by the ’918 patent.
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`EX2066, 13 (Topics #14-17); EX2067 (showing Mr. Holbrook was designated for
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`same topics). The testimony is admissible against Samsung under FRE 804(3) for
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`the same reason, coupled with the fact that the statement removes a prior art design
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`in which information is sent in packetized form from the scope of the ’918 patent
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`claims, which harms Mr. Holbrook’s employers’ interest.
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`II. Relevance of the Supplemental Information
` The ’918 patent recites “edge connections configured to couple power, data,
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`address, and control signals between the memory modules and the host system.” See
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`e.g., EX1001, Cl. 1. The Petitioners point to signals transiting from the AMB to the
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`DRAM chips in FBDIMMs as satisfying this element: “A0-A15,” “RAS, CAS, WE,
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`CS”). Pet., 21-25. The claims, however, require the recited signals to pass from the
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`host system to the memory module via the memory module’s edge connections.
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`Samsung’s expert, Dr. Wolf, testified that, across the edge in FBDIMM, “the
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`information is sent to the advanced memory before in the form of serialized packets.”
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`EX2030, 10:7-11. In order to backfill, in its reply Samsung changed arguments and
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`maintained that the serialized packets sent across the edge constitute the required
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`signals. Paper 25, 7-9. In addition to being an improper new argument, it is
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`contradicted by Mr. Holbrook.
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`Case No. IPR2022-00996
`Patent No. 11,016,918
`Mr. Holbrook is not an expert in FBDIMMs, which makes his testimony
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`particularly relevant because the standard is a POSA. See Environment Designs, Ltd.
`
`v. Union Oil Co. of Cal., 713 F.2d 693, 218 USPQ 865, 868-69 (Fed. Cir. 1983)
`
`(noting the statutory requirement that obviousness be evaluated with respect to a
`
`person having ordinary skill in the art, “not to the judge, or to a layman, or to those
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`skilled in remote arts, or to geniuses in the art at hand”). Mr. Hobrook satisfies
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`Petitioners’ definition of a POSA at the time of the invention as he was employed
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`with Micron since 2002 as a “Senior Electrical Engineer” working in the field of
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`design/development of memory systems. Pet., 8-9; EX2065, ¶2; EX2070.
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`Consistent with the admissions of Samsung’s expert he testified that signals (which
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`are required by the claims) and encoded data are different:
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`Q. What's the difference between a signal and an encoded
`packet of data?
`A. So a signal, from my understanding, is a single, defined
`signal, a 1 or a 0. Encoded data, group of data, would be a
`group of 1s and 0s that would be encoded by a device.
`Attachment A, 52:13-18.
`
`Q. But you understand that there is a difference between
`encoded data and data signals in terms of how you’re
`controlling memory devices on a module.
`A. So how memory devices are controlled on a module in
`respect to FBDIMM, yes, I understand that.
`Id., 53:7-13.
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`Case No. IPR2022-00996
`Patent No. 11,016,918
`At the hearing, Samsung argued that the claims must cover packetized transfer
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`of information as opposed to signals because the specification list a large number of
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`form factors, one of which is FB-DIMM. EX1079, 37. But Mr. Holbrook’s
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`testimony corroborates that “form factor” in this context refers to the shape of the
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`module, not how information is passed, because the claims recite the use of signals
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`which is different from the packets used to supply AMBs. Mr. Holbrook’s testimony
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`also corroborates the specification, which makes no provision for an AMD-like
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`structure that can convert packetized information to signals, but in all discussions
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`describes signals passing across the edge that need not be decoded or converted.
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`EX1001, 22:1-6 (described “standard DIMM interface 1022” of FIG. 12).
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`III. The Supplemental Information Could Not Be Obtained Earlier
`Mr. Holbrook was not made available to testify until August 30, 2023
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`(EX2068), and therefore the information could not have been obtained earlier.
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`Netlist served its 30(b)(6) notice on May 15, 2023. EX2066. Micron did not respond
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`to Netlist’s notice until June 27, 2023, merely objecting to each of Netlist’s topics
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`without designating a single witness. Micron finally provided Mr. Holbrook’s
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`availability for deposition on August 3, 2023, informing Netlist that Mr. Holbrook
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`would not be available for deposition until August 30, 2023. Micron did not provide
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`its final designations for its 30(b)(6) witnesses until August 9, 2023—nearly 3
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`months after Netlist served its 30(b)(6) notice. EX2067.
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`Case No. IPR2022-00996
`Patent No. 11,016,918
`After the deposition, Micron further delayed by improperly designating the
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`entire transcript as confidential under the district court’s protective order. The next
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`day, Netlist asked for the relevant testimony be de-designated (EX2069). Netlist
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`further acted diligently in expediently raising this issue with the Board on September
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`5, 2023 (EX3002) after Micron’s delay in de-designating the relevant testimony.
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`To the extent Samsung argues that Netlist should have sought discovery from
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`Mr. Holbrook in the IPR, this was an impossibility as he was not designated to
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`provide testimony on non-infringement of the patents (and thus Micron’s
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`understanding of the patents) until August 9, 2023.
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`IV. Admission of the Supplemental Information is in Interest-of-Justice
`As the Board has recognized in past cases, evidence that a party has taken
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`inconsistent positions on the same issues here and in related district court litigation
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`is relevant to the Board’s determination and should be considered in the interests-
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`of-justice. See, e.g., Kingston Tech. Co., Inc. v. Spex Techs., Inc., No. IPR2017-
`
`01021, Paper 31, at 2, 4-5 (PTAB May 29, 2018).
`
`Here, Samsung itself has submitted and relied on evidence from parallel
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`district court proceedings. See, e.g., EX1071-1073, EX1077; Pet., 9, 27, 40, 69, 73,
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`87, 126 (discussing alleged positions and statements made by Netlist in EX1071 and
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`EX1073); Paper 25 (Petitioner Reply), 2, 8, 25, 37 (discussing Netlist’s district court
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`technology tutorial).
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`Case No. IPR2022-00996
`Patent No. 11,016,918
`
`
`Dated: October 4, 2023
`
`Respectfully submitted,
`
`By /Jonathan Lindsay/
`H. Annita Zhong (Reg. No. 66,530)
`Jonathan Lindsay (Reg. No. 45,810)
`Jason Sheasby (pro hac vice)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067
`Tel: (310) 277-1010
`Fax: (310) 203-7199
`Attorneys for Patent Owner
`Netlist, Inc.
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`ATTACHMENT A
`ATTACHMENT A
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`Case 2:22-cv-00293-JRG Document 150-2 Filed 09/14/23 Page 2 of 17 PageID #: 12113
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` UNITED STATES DISTRICT COURT
`
` FOR THE EASTERN DISTRICT OF TEXAS
`
` MARSHALL DIVISION
`
` ---oOo---
`
` NETLIST, INC.,
`
` Plaintiff,
`
` vs. No. 2:22-cv-203-JRG-RSP
`
` MICRON TECHNOLOGY, INC.;
`
` MICRON SEMICONDUCTOR
`
` PRODUCTS, INC.; MICRON
`
` TECHNOLOGY TEXAS LLC,
`
` Defendants.
`
` ____________________________/
`
`
`
` REMOTE VIDEOTAPED DEPOSITION OF
`
` BOE HOLBROOK
`
` 30(B)(6) DESIGNEE, MICRON
`
` _________________________________
`
` WEDNESDAY, AUGUST 30, 2023
`
` REPORTED BY: HOLLY THUMAN, CSR No. 6834, RMR, CRR
`
` JOB NUMBER 6066631
`
`Veritext Legal Solutions
`Calendar-CA@veritext.com 866-299-5127
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`Case 2:22-cv-00293-JRG Document 150-2 Filed 09/14/23 Page 3 of 17 PageID #: 12114
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` --o0o--
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` Remote videotaped deposition of BOE HOLBROOK,
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` taken by the Plaintiff, with the witness located in
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` Boise, Idaho, commencing at 10:16 A.M. Mountain Time,
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` on WEDNESDAY, AUGUST 30, 2023, before me, HOLLY THUMAN,
`
` CSR, RMR, CRR.
`
` --o0o--
`
` APPEARANCES
`
` (ALL APPEARANCES REMOTE)
`
` FOR THE PLAINTIFF:
`
` IRELL & MANELLA LLP
`
` 1800 Avenue of the Stars, Suite 900
`
`12
`
` Los Angeles, California 90067-4276
`
` By: JASON G. SHEASBY, Attorney at Law
`
`13
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`14
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`15
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` JSheasby@irell.com
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` FOR DEFENDANTS:
`
` WINSTON & STRAWN LLP
`
` 333 S. Grand Avenue, 38th Floor
`
`16
`
` Los Angeles, California 90071
`
` By: DAVID ENZMINGER, Attorney at Law
`
`17
`
` DEnzminger@winston.com
`
` By: MATTHEW HOPKINS, Attorney at Law
`
` MHopkins@winston.com
`
` ALSO PRESENT:
`
` TONY NOKES, Videographer
`
` CARRISA NARCISO, Tech Concierge
`
` BECKY CARRIZOSA, In-house counsel, Micron
`
`18
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` I N D E X
` INDEX OF EXAMINATIONS
` EXAMINATION BY: PAGE
` MR. SHEASBY 8
` MR. ENZMINGER 167
` MR. SHEASBY 171
` --o0o--
` EXHIBITS MARKED FOR IDENTIFICATION
` NO. DESCRIPTION PAGE
` Exhibit 1 JEDEC Standard JESD82-31A, August 16
` 2019 (SAM-NET00332467 through -665)
`
` Exhibit 2 JEDEC Standard JESD82-32A, August 17
` 2019 (MICNL203-00012556 through -755)
` Exhibit 3 Micron document, "3-Dimensional Stack 37
` (3DS) DDR4 SDRAM"
`
` Exhibit 5 Micron document "DDR4 SDRAM LRDIMM" 55
` (MICNL203-00001364 through -391)
` Exhibit 6 Micron document, "DDR5 SDRAM RDIMM 91
` Addendum" (MICNL203-00000678 through
` -685)
` Exhibit 7 Master Revision Control Document 90
` 3408.01
`
` Exhibit 8 Micron document, "DDR5 SDRAM SODIMM 90
` Core" (MICNL203-00000562 through
` -580)
`
` Exhibit 9 Master Revision Control Document 90
` 3163.01
` Exhibit 10 Master Revision Control Document 92
` 3405.1
`
` (Cont'd)
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` (Exhibits, cont'd)
` Exhibit 12 Press release, May 7, 2012, "Micron 110
` Announces Its First Fully Functional
` DDR4 DRAM Module"
` Exhibit 14 Presentation deck, "Micron/Netlist 112
` Partnership Opportunity, April 2015"
` (NL-MIC-203_00041942 through -2004)
` Exhibit 16 Micron document, "DDR4 SDRAM LRDIMM" 99
` (MICNL203-00001364 through -391)
`
` Exhibit 17 US Patent 10,949,339, Lee et al. 105
`
` Exhibit 18 Page from presentation deck with 108
` diagrams headed "Micron" Nd "Netlist
` Patents"
`
` Exhibit 19 Texas Instruments presentation deck, 124
` "Alternative HDLR Dimm Concept,"
` October 6, 2008
` (NETLIST_SAMSUNG_EDTX00056236 through
` -245)
`
` Exhibit 20 Document marked as Exhibit 19, with 126
` highlights
` Exhibit 21 Page from presentation deck with 133
` headings for Micron, Netlist Patents,
` and TI JEDEC Presentation
` Exhibit 23 Presentation deck, "Micron/Netlist 142
` Partnership Opportunity, April 2015"
` (NL-MIC-203_00041942 through -2004)
` Exhibit 25 Minutes of Meeting No. 164, JC-40 144
` Digital Logic Committee, December 9,
` 2010 (SAM-NET00078119 through -134)
` Exhibit 26 Richtek document, "DDR5 VR on DIMM 148
` PMIC" (MICNL203-00059886 through
` -60009)
` Exhibit 27 Minutes of Meeting No. 193, JC-40 156
` Digital Logic Committee, June 4-6,
` 2018 (SAM-NET00246201 through -225)
` (Cont'd)
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` (Exhibits, cont'd)
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` Exhibit 29 Presentation slide, "4.3.1.0, 158
`
` #2259.39, Micron, Voltage Regulators
`
` for DDR5 DIMMs"
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` Exhibit 30 Minutes of Meeting No. 59, JC-45 162
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` Module Committee, June 4-6, 2018
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` (NETLIST_SAMSUNG_EDTX00158253 through
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` -287)
`
` --o0o--
`
` INSTRUCTIONS TO WITNESS/REQUESTS TO MARK TRANSCRIPT
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` PAGE LINE
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` Instruction not to answer 76 23
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` Instruction not to answer 175 15
`
` Instruction not to answer 175 24
`
` --o0o--
`
` REPORTER'S NOTE: Exhibits Numbers 4, 11, 15, 22, 24,
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` and 28 were not used.
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` EXAMINATION BY MR. SHEASBY 10:18:58
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` BY MR. SHEASBY: 10:18:58
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` Q. Good morning, sir. Can you state your 10:18:59
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` full name for the record? 10:19:00
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` A. Full name is Boe Holbrook. 10:19:01
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` Q. And, sir, you've been designated to speak 10:19:03
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` on behalf of the entire Micron defendant 10:19:06
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` corporation as to a number of technical topics. Is 10:19:09
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` that correct? 10:19:11
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` A. That's correct. 10:19:12
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` Q. Is there anyone more senior than you in 10:22:20
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` module development? 10:22:23
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` A. No, sir. 10:22:24
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` Q. And how long have you been at Micron? 10:22:25
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` A. 21 years. 10:22:27
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` Q. I've marked as Exhibit 1 what is the 10:34:46
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` DDR -- DDR4RCD. 10:34:49
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` Do you see that? 10:34:51
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`Case 2:22-cv-00293-JRG Document 150-2 Filed 09/14/23 Page 10 of 17 PageID #: 12121
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` Q. By the way, just so -- before we do that, 11:08:23
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` Exhibit 1 is the RCD specification. 11:08:26
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` Do you see that? 11:08:29
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` A. Yes, I see that. 11:08:31
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`Case 2:22-cv-00293-JRG Document 150-2 Filed 09/14/23 Page 11 of 17 PageID #: 12122
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` Q. And "CS" stands for chip-select. Is that 11:42:56
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` correct? 11:43:01
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` A. That's correct. 11:43:02
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` Q. And in JEDEC DDR parlance, chip-selects 11:43:03
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` select a rank. Is that correct? 11:43:07
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` A. Yes. That's correct. 11:43:13
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`Case 2:22-cv-00293-JRG Document 150-2 Filed 09/14/23 Page 12 of 17 PageID #: 12123
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` Q. A rank is one or more -- well, let me ask 11:43:14
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` it this way: 11:43:16
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` How many ranks can there be on DDR 11:43:18
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` devices? 11:43:21
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` A. So modules? 11:43:22
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` Q. Yes, sir. 11:43:24
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` A. Logic -- or, excuse me, physical ranks 11:43:26
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` supported by the RCD would be four physical ranks. 11:43:29
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` Q. And in JEDEC DDR parlance, a rank is two 11:43:37
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` or more memory devices. Is that correct? 11:43:41
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` A. A rank is defined as a group that 11:43:43
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` comprises a full 64-bit data bus. So it would be, 11:43:47
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` at a minimum, the number of devices that are 11:43:55
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` Q. And, historically, how many has that been? 11:44:01
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` A. So for a x8-based module, that would be 11:44:04
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` eight devices. For a x4-based, so four DQs in a 11:44:13
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` DRAM -- x8 is going to be 8 DQs. So four DQs, 11:44:20
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` x4 configuration, that would be 16 DRAM. 11:44:24
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`Case 2:22-cv-00293-JRG Document 150-2 Filed 09/14/23 Page 13 of 17 PageID #: 12124
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` Q. And, by the way, do you know what the 11:46:45
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` difference is -- between a signal and an encoded 11:46:47
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` packet of data is in JEDEC? 11:46:50
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` A. JEDEC definition, I do not know what that 11:46:57
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` would be; but I understand what a signal would be 11:47:00
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` versus an encoded packet of data. 11:47:03
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` Q. What's the difference between a signal and 11:47:07
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` an encoded packet of data? 11:47:10
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` A. So a signal, from my understanding, is a 11:47:12
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` single, defined signal, a 1 or a 0. Encoded data, 11:47:16
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` group of data, would be a group of 1s and 0s that 11:47:23
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` would be encoded by a device. 11:47:28
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` Q. Do you remember FBDIMMs? 11:47:32
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` A. I am familiar with FBDIMMs. 11:47:36
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` Q. A little before your time? 11:47:39
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` A. A little bit. 11:47:42
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` Q. And you know that they use an advanced 11:47:43
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` memory buffer. 11:47:45
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` Do you remember that? 11:47:47
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`Case 2:22-cv-00293-JRG Document 150-2 Filed 09/14/23 Page 14 of 17 PageID #: 12125
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` A. Yes, sir. 11:47:48
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` Q. And in an advanced memory buffer, they 11:47:48
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` use -- that uses encoded data as opposed to data 11:47:52
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` signals. Correct? 11:47:55
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` A. I wouldn't know. AMB and FBDIMM was not 11:48:00
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` my area of expertise. 11:48:04
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` Q. But you understand that there is a 11:48:06
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` difference between encoded data and data signals in 11:48:08
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` terms of how you're controlling memory devices on a 11:48:12
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` module. 11:48:15
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` A. So how memory devices are controlled on a 11:48:18
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` module in respect to FBDIMM, yes, I understand 11:48:21
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` that. 11:48:28
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`Page 53
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`Case 2:22-cv-00293-JRG Document 150-2 Filed 09/14/23 Page 15 of 17 PageID #: 12126
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` CERTIFICATE OF REPORTER
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` I, HOLLY THUMAN, a Certified Shorthand Reporter,
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` hereby certify that the witness in the foregoing
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` deposition was by me duly sworn to tell the truth, the
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` whole truth, and nothing but the truth in the
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` within-entitled cause; that said deposition was taken
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` down in shorthand by me, a disinterested person, at the
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` time and place therein stated; and that the testimony
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` of said witness was thereafter reduced to typewriting
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` by computer, to the best of my ability via remote
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` videoconferencing, under my direction and supervision;
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` That before completion of the deposition review of
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` the transcript [] was [X] was not requested/offered.
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` If requested, any changes made by the deponent (and
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` provided to the reporter) during the period allowed are
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` appended hereto.
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` I further certify that I am not of counsel or
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` attorney for either or any of the parties to the said
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` deposition, nor in any way interested in the event of
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` this cause, and that I am not related to any of the
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` parties thereto.
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` DATED: 9/05/2023
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` <%11978,Signature%>
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` HOLLY THUMAN, CSR
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`Page 181
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`Case 2:22-cv-00293-JRG Document 150-2 Filed 09/14/23 Page 16 of 17 PageID #: 12127
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`JASON G. SHEASBY, ESQ.
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`JSheasby@irell.com
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` September 5, 2023
`
`RE: NETLIST, INC. vs. MICRON TECHNOLOGY, INC.
`
`AUGUST 30, 2023-BOE HOLBROOK-30(B)(6)-JOB NO.6066631
`
`The above-referenced transcript has been
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`completed by Veritext Legal Solutions and
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`review of the transcript is being handled as follows:
`
`__ Per CA State Code (CCP 2025.520 (a)-(e)) – Contact Veritext
`
` to schedule a time to review the original transcript at
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` a Veritext office.
`
`__ Per CA State Code (CCP 2025.520 (a)-(e)) – Locked .PDF
`
` Transcript - The witness should review the transcript and
`
` make any necessary corrections on the errata pages included
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` below, notating the page and line number of the corrections.
`
` The witness should then sign and date the errata and penalty
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` of perjury pages and return the completed pages to all
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` appearing counsel within the period of time determined at
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` the deposition or provided by the Code of Civil Procedure.
`
`__ Waiving the CA Code of Civil Procedure per Stipulation of
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` Counsel - Original transcript to be released for signature
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` as determined at the deposition.
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`__ Signature Waived – Reading & Signature was waived at the
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` time of the deposition.
`
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`Page 182
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`Case 2:22-cv-00293-JRG Document 150-2 Filed 09/14/23 Page 17 of 17 PageID #: 12128
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`__ Federal R&S Requested (FRCP 30(e)(1)(B)) – Locked .PDF
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` Transcript - The witness should review the transcript and
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` make any necessary corrections on the errata pages included
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` below, notating the page and line number of the corrections.
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` The witness should then sign and date the errata and penalty
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` of perjury pages and return the completed pages to all
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` appearing counsel within the period of time determined at
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` the deposition or provided by the Federal Rules.
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`_X_ Federal R&S Not Requested - Reading & Signature was not
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` requested before the completion of the deposition.
`
`Veritext Legal Solutions
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`Page 183
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`
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`Case No. IPR2022-00996
`Patent No. 11,016,918
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify, pursuant to 37 C.F.R. section 42.6, that on October 4, 2023,
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`a complete copy of the foregoing document PATENT OWNER’S MOTION TO
`
`SUBMIT SUPPLEMENTAL INFORMATION PURSUANT TO 37 C.F.R.
`
`§42.123(b) and Exhibits 2065-2071 were served by electronic mail, as agreed to
`
`by the parties, upon the following:
`
`Eliot D. Williams, Reg. No. 50,822
`Theodore W. Chandler, Reg. No. 50,319
`Ferenc Pazmandi, Reg. No. 66,216
`Brianna L. Potter, Reg. No. 76,748
`DLSamsungNetlistIPRs@BakerBotts.com
`
`Juan C. Yaquian
`Michael Rueckheim
`Winston-IPR-Netlist@winston.com
`
`
`/Susan M. Langworthy/
` Susan M. Langworthy
`
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