UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ASSA ABLOY AB, ASSA ABLOY INC., ASSA ABLOY RESIDENTIAL
`GROUP, INC., AUGUST HOME, INC., HID GLOBAL CORPORATION,
`ASSA ABLOY GLOBAL SOLUTIONS, INC.,
`Petitioner,
`
`v.
`
`CPC PATENT TECHNOLOGIES PTY LTD.,
`Patent Owner.
`
`Case IPR2022-01006
`Patent 9,665,705
`
`PATENT OWNER’S UPDATED EXHIBIT LIST
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ASSA ABLOY AB, ASSA ABLOY INC., ASSA ABLOY RESIDENTIAL
`GROUP, INC., AUGUST HOME, INC., HID GLOBAL CORPORATION,
`ASSA ABLOY GLOBAL SOLUTIONS, INC.,
`Petitioner,
`
`v.
`
`CPC PATENT TECHNOLOGIES PTY LTD.,
`Patent Owner.
`
`Case IPR2022-01006
`Patent 9,665,705
`
`PATENT OWNER’S UPDATED EXHIBIT LIST
`
`
`
`Pursuant to 37 C.F.R. § 42.63(e), Patent Owner CPC Patent Technologies
`
`Pty Ltd. hereby submits the following current list of its exhibits.
`
`EXHIBIT
`
`DESCRIPTION
`
`2001
`
`2002
`
`2003
`
`2004
`
`2005
`
`2006
`
`2007
`
`2008
`
`2009
`2010
`
`Affidavit in Support of Patent Owner’s Motion for Pro Hac Vice
`Admission of Steven M. Coyle Pursuant to 37 C.F.R. § 42.10(c)
`Affidavit in Support of Patent Owner’s Motion for Pro Hac Vice
`Admission of Nicholas A. Geiger Pursuant to 37 C.F.R. § 42.10(c)
`Complaint filed in CPC Patent Technologies Pty Ltd. v. Apple,
`Inc., No. 6:21-cv-00165 (W.D. Tex., Waco Division) (without
`exhibits)
`Affidavit of Service of Complaint filed in CPC Patent
`Technologies Pty Ltd. v. Apple, Inc., No. 6:21-cv-00165 (W.D.
`Tex., Waco Division)
`Letter dated October 18, 2021 from Patent Owner’s counsel to
`Yale Residential regarding ’705 and ’208 Patents with attached
`claim charts
`Letter dated November 4, 2021 from Patent Owner’s counsel to
`Yale Residential
`Complaint for declaratory judgment filed in ASSA ABLOY AB et
`al. v. CPC Patent Technologies Pty. Ltd. and Charter Pacific Corp
`Ltd., Civ. 3:22-cv-694 (D. Conn.) (without exhibits)
`Declaration of Kevin J. Dart filed in ASSA ABLOY AB et al. v.
`CPC Patent Technologies Pty. Ltd. and Charter Pacific Corp Ltd.,
`Civ. 3:22-cv-694 (D. Conn.) (without exhibits)
`Apple Developer Program License Agreement
`Email thread between Petitioners and Patent Owner’s respective
`counsel regarding additional discovery
`
`2
`
`
`
`EXHIBIT
`
`DESCRIPTION
`
`2011
`
`2012
`
`2013
`
`2014
`
`2015
`
`2016
`
`2017
`
`2018
`
`2023
`2024
`2025
`
`Yale product literature (Yale Assure Lock Touchscreen with Wi-Fi
`and Bluetooth) downloaded from
`[https://shopyalehome.com/products/yale-assure-lock-touchscreen-
`with-wi-fi-and-bluetooth?variant=39341913079940]
`Yale product literature (Yale Access Upgrade Kit with Wi-Fi for
`Assure Locks) downloaded from
`[https://shopyalehome.com/products/yale-access-ugrade-kit-for-
`assure-locks-with-wifi?variant=34110396006532]
`Yale product literature (Facial and Fingerprint Lock Verification
`for Yale Assure Smart Locks) downloaded from
`[https://shopyalehome.com/blogs/yale-home-blog/new-facial-and-
`fingerprint-lock-verification-for-yale-assure-smart-locks]
`August product literature (August Smart Lock Pro + Connect)
`downloaded from [https://august.com/products/august-smart-lock-
`pro-connect]
`August product literature (New Biometric Verification Feature for
`August Smart Locks) downloaded from
`[https://august.com/blogs/home/introducing-biometric-
`verification-for-august-and-yale-locks]
`Apple literature regarding MiFi Program downloaded from
`https://mfi.apple.com/
`Apple literature regarding MiFi Program (How the Program
`Works) downloaded from https://mfi.apple.com/en/how-it-
`works.html.
`Apple literature regarding MiFi Program (Frequently Asked
`Questions) downloaded from https://mfi.apple.com/en/faqs.html.
`Apple Inc. iPhone SDK Agreement (dated 10/20/2008)
`Yale Access on the Apple App Store
`August Home on the Apple App Store
`
`3
`
`
`
`EXHIBIT
`
`DESCRIPTION
`
`2026
`
`2027
`
`2028
`
`2029
`
`2030
`
`2031
`
`2032
`2033
`
`2034
`2035
`
`2036
`
`Apple literature regarding Apple HomeKit (“Developing apps and
`accessories for the home”) downloaded from
`https://developer.apple.com
`Apple literature regarding Apple HomeKit and Yale Assure Lock
`Yale product literature (Yale Assure Lock SL Touchscreen
`Deadbolt – Black – Apple) downloaded from
`https://www.apple.com/shop/product/HPAR2ZM/A/yale-assure-
`lock-sl-touchscreen-deadbolt-black
`August product literature regarding Apple HomeKit (HomeKit
`FAQ) downloaded from https://support.august.com/august-smart-
`lock-homekit-enabled-faq-rJv088y0_z
`Revised Affidavit in Support of Patent Owner’s Motion for Pro
`Hac Vice Admission of Steven M. Coyle Pursuant to 37 C.F.R. §
`42.10(c)
`Revised Affidavit in Support of Patent Owner’s Motion for Pro
`Hac Vice Admission of Nicholas A. Geiger Pursuant to 37 C.F.R.
`§ 42.10(c)
`Declaration of Samuel Russ, Ph.D. Regarding U.S. Patent No.
`9,665,705
`Curriculum Vitae of Samuel Russ, Ph.D.
`Joint Claim Construction Statement in CPC Patent Technologies
`Pty Ltd v. Apple Inc., WDTX-6-21-cv-00165-ADA, Dkt. No. 57
`(“Apple Joint CC Statement”)
`Deposition of Stuart Lipoff (Feb. 14, 2023)
`S. Liu and M. Silverman, "A practical guide to biometric security
`technology," in IT Professional, vol. 3, no. 1, pp. 27-32, Jan.-Feb.
`2001. doi: 10.1109/6294.899930.
`D. Currie, “Shedding some light on Voice Authentication”, Global
`Information Assurance Certification Paper (2003)
`
`4
`
`
`
`EXHIBIT
`
`DESCRIPTION
`
`2037
`
`2038
`
`2039
`
`2040
`2041
`
`F.S. Rovati, et al., “Spatial-Temporal Motion Estimation for Image
`Reconstruction and Mouse Functionality with Optical or
`Capacitive Sensors”, IEEE Transactions on Consumer Electronics,
`Vol. 49, No. 3, August 2003, pp. 711-718
`Haider: S. Haider, A. Abbas and A. K. Zaidi, "A multi-technique
`approach for user identification through keystroke dynamics," Smc
`2000 conference proceedings. 2000 ieee international conference
`on systems, man and cybernetics. 'cybernetics evolving to systems,
`humans, organizations, and their complex interactions' (cat. no.0,
`Nashville, TN, USA, 2000, pp. 1336-1341 vol.2.
`Umphress: David Umphress, Glen Williams, Identity verification
`through keyboard characteristics, International Journal of Man-
`Machine Studies, Volume 23, Issue 3, 1985, Pages 263-273
`Deposition of Stuart Lipoff, vol. 2 (June 28, 2023)
`Patent Owner’s Hearing Demonstrative Exhibit
`
`Dated: September 25, 2023
`
`Respectfully submitted,
`
` /Andrew C. Ryan/
`Andrew C. Ryan (Reg. No. 43,070)
`
`5
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on September 25, 2023, I caused a true and correct copy
`
`of the foregoing to be served on the following counsel of record for Petitioner by
`
`electronic mail to the following addresses:
`
`Dion Bregman
`Andrew Devkar
`James J. Kritsas
`Morgan, Lewis & Bockius LLP
`1400 Page Mill Road
`Palo Alto, CA 94304
`HID-IPRs@morganlewis.com
`
`Dated: September 25, 2023
`
`By: /Andrew C. Ryan/
`Andrew C. Ryan
`Reg. No. 43,070
`
`6
`
`
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