`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
`v.
`NETLIST, INC.,
`Patent Owner
`
`Patent No. 11,016,918
`Issued: May 25, 2021
`Filed: December 30, 2020
`Inventors: Chi-She Chen, Jeffrey C. Solomon, Scott H. Milton, Jayesh Bhakta
`
`Title: Flash-DRAM Hybrid Memory Module
`Inter Partes Review No. IPR2022-00096
`
`PETITIONER’S UPDATED MANDATORY NOTICES
`
`
`
`Pursuant to 37 C.F.R. § 42.8(a)(3), Petitioner hereby provides the following
`
`updates to its mandatory notices in Paper No. 1:
`
`Related Matters (37 C.F.R. § 42.8(b)(2))
`
`The following judicial or administrative matters would affect, or be affected
`
`by, a decision in this proceeding concerning U.S. Patent No. 11,016,918.
`
`The following proceedings are currently pending:
`
` Samsung Electronics Co., Ltd. et al. v. Netlist, Inc., No. 1:21-cv-
`
`01453 (D. Del. filed Oct. 15, 2021)
`
` Netlist, Inc. v. Samsung Electronics Co., Ltd. et al., No. 2:21-cv-
`
`00463 (E.D. Tex. filed Dec. 20, 2021)
`
` [NEW] Petitioner stipulated as follows: “Samsung stipulates
`
`that, if the Patent Trial and Appeal Board institutes an IPR
`
`proceeding for U.S. Patent No. 11,016,918 on the grounds
`
`presented in Samsung’s petition in IPR2022-00996, Samsung
`
`will not pursue an invalidity defense in the Eastern District of
`
`Texas action (C.A. No. 21-463-JRG) that the patent claims
`
`subject to the instituted IPR are invalid based on grounds that
`
`were raised or reasonably could have been raised in the IPR.”
`
`See Exhibit 1074.
`
`1
`
`
`
` Samsung Electronics Co., Ltd. v. Netlist, Inc., IPR2022-00999 (U.S.
`
`Patent No. 11,232,054)
`
`
`
`[NEW] Netlist, Inc. v. Micron Technology, Inc., No. 2:22-cv-00203
`
`(E.D. Tex. filed June 13, 2022)
`
` Application No. 17/582,797
`
`The following proceeding is no longer pending:
`
` SK hynix Inc. et al. v. Netlist, Inc., IPR2017-00692 (U.S. Patent No.
`
`8,874,831)
`
`Dated: October 11, 2022
`
`Respectfully submitted,
`
`/ Eliot D. Williams /
`Eliot D. Williams
`Reg. No. 50,822
`BAKER BOTTS L.L.P.
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`T: (650) 739-7511
`F: (650) 739-7611
`
`Theodore W. Chandler
`Reg. No. 50,319
`BAKER BOTTS L.L.P.
`1801 Century Park East, Suite 2400
`Los Angeles, CA 90067
`T: (213) 202-5702
`F: (213) 202-5732
`
`Ferenc Pazmandi
`Reg. No. 66,216
`
`2
`
`
`
`BAKER BOTTS L.L.P.
`101 California Street, Suite 3200
`San Francisco, CA 94111
`T: (415) 291-6255
`F: (415) 291-6355
`
`Brianna L. Potter
`Reg. No. 76,748
`BAKER BOTTS L.L.P.
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`T: (650) 739-7556
`F: (650) 739-7656
`
`Counsel for Petitioner
`Samsung Electronics Co., Ltd.
`
`3
`
`
`
`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), I certify that on this 11th day of October,
`
`2022, Petitioner’s Updated Mandatory Notices was served by email on the
`
`following counsel for Patent Owner:
`
`Hong Annita Zhong (Reg. No. 66,530)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067
`Phone: (310) 277-1010
`Fax: (310) 203-7199
`Email: hzhong@irell.com
`NetlistIPR@irell.com
`
`Jason Sheasby (not admitted)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067
`Phone: (310) 277-1010
`Fax: (310) 203-7199
`Email: jsheasby@irell.com
`
`Dated: October 11, 2022
`
`Respectfully submitted,
`
`/ Eliot D. Williams /
`Eliot D. Williams
`Reg. No. 50,822
`BAKER BOTTS L.L.P.
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`T: (650) 739-7511
`F: (650) 739-7611
`Counsel for Petitioner Samsung
`Electronics Co., Ltd.
`
`4
`
`
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