`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`CISCO SYSTEMS, INC., MICROSOFT CORPORATION, AMAZON.COM,
`INC., AMAZON WEB SERVICES, INC., AND
`AMAZON.COM SERVICES LLC
`Petitioners,
`
`v.
`
`LS CLOUD STORAGE TECHNOLOGIES LLC
`Patent Owner.
`
`Patent No. 10,154,092
`
`_______________
`
`Inter Partes Review No. IPR2023-007331
`____________________________________________________________
`
`PETITIONERS’ UPDATED MANDATORY NOTICES
`
`1 This proceeding is joined with IPR2023-00120
`
`
`
`IPR2023-00733
`
`Petitioners Amazon.com, Inc., Amazon Web Services, Inc., and
`
`Amazon.com Services LLC. (collectively “Amazon’) hereby files mandatory
`
`notices pursuant to 37 C.F.R. § 42.8(a)(3). Petitioner’s Motion for Joinder with the
`
`IPR2023-00120 proceeding was granted on September 1, 2023 (Paper 10). Per the
`
`Board’s order dated December 8, 2023 (Paper 14), Amazon is authorized to make
`
`any such filings related to IPR2023-00120 in the instant proceeding due to the
`
`technical architecture of the P-TACTS system.
`
`A.
`
`Real Party-in-Interest (37 C.F.R. § 42.8(b)(1))
`
`The real parties-in-interest are Amazon.com, Inc., Amazon Web Services,
`
`Inc., and Amazon.com Services LLC.
`
`B.
`
`Related Matters (37 C.F.R. § 42.8(b)(2))
`
`In accordance with the Office Patent Trial Practice Guide (77 Fed. Reg.
`
`48,756, at 48,760 (Aug. 14, 2012)), Amazon identifies the following related
`
`matters:
`
` Patent Owner asserted the ’092 Patent against Petitioner in the following
`
`case in the Waco Division of the Western District of Texas:
`
`LS Cloud Storage Technologies, LLC v. Amazon.com, Inc., 6:22-cv00316
`
`(W.D. Tex. 2022).
`
`1
`
`
`
`IPR2023-00733
`
`
`
`
`
` That case was transferred to the Austin Division as LS Cloud Storage
`
`Technologies, LLC v. Amazon.com, Inc., 1:22-cv-01167 (W.D. Tex. 2022),
`
`by agreement of the parties on October 31, 2022.
`
` Amazon was first served with a complaint alleging infringement of the ’092
`
`Patent on March 28, 2022.
`
`Amazon does not concede that the identified matters would affect, or be
`
`affected by, a decision in the present Inter Partes Review of U.S. Patent No.
`
`10,154,092.
`
`Lead and Back-Up Counsel (37 C.F.R. § 42.8(b)(3))
`
`C.
`
`
`Backup Counsel
`Regan Rundio
`Reg. No. 75,308
`MORRISON & FOERSTER LLP
`300 Colorado St., Suite 1800
`Austin, TX 78701
`Telephone: (512) 617-0650
`Email: RRundio@mofo.com
`
`
`Lead Counsel
`Brian C. Nash
`Reg. No. 58,105
`MORRISON & FOERSTER LLP
`300 Colorado St., Suite 1800
`Austin, TX 78701
`Telephone: (512) 617-0650
`Email: BNash@mofo.com
`
`
`Backup Counsel
`Alex S. Yap
`Reg. No. 60,609
`MORRISON & FOERSTER LLP
`707 Wilshire Blvd., Suite 6000
`Los Angeles, CA 90017
`Telephone: (213) 892-5688
`Email: AYap@mofo.com
`
`
`
`
`2
`
`
`
`IPR2023-00733
`
`
`
`
`
`An updated Power of Attorney is being filed concurrently with these
`
`Mandatory Notices.
`
`D.
`
`Service Information (37 C.F.R. § 42.8(b)(4))
`
`Please direct all correspondence regarding this proceeding to the counsel at
`
`the addresses listed above. Amazon consents to service by electronic mail at the
`
`following addresses: BNash@mofo.com; RRundio@mofo.com;
`
`AYap@mofo.com, and Amazon-LSCloud@mofo.com.
`
`
`
`
`Dated: December 11, 2023
`
`
`
` By: /s/ Brian C. Nash
`Brian C. Nash, Reg. No. 58,105
`MORRISON & FOERSTER LLP
`300 Colorado St., Suite 1800
`Austin, TX 78701
`Telephone: (512) 617-0650
`Email: BNash@mofo.com
`
`Counsel for Petitioners
`
`
`
`3
`
`
`
`IPR2023-00733
`
`Certificate of Service (37 C.F.R. § 42.6(e)(4))
`
`I hereby certify that the attached PETITIONERS’ UPDATED
`
`MANDATORY NOTICES were served as of the below date on the Patent Owner
`
`via email (by agreement) at the following correspondence address:
`
`William P. Ramey, III (Registration No. 44,295)
`Jacob B. Henry (Registration No. 61,093)
`RAMEY LLP
`5020 Montrose Blvd., Ste. 800
`Houston, Texas 77006
`wramey@rameyfirm.com
`jhenry@rameyfirm.com
`uspto@rameyfirm.com
`
`Dated: December 11, 2023
`
`By: /s/ Brian C. Nash
`Brian C. Nash
`
`4
`
`
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