`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TCL INDUSTRIES HOLDINGS CO., INC.,
`Petitioner,
`
`v.
`
`ATI TECHNOLOGIES ULC
`Patent Owner.
`
`Case No. IPR2024-00366
`U.S. Patent No. 8,760,454
`
`PATENT OWNER’S RESPONSE
`TO PETITIONER’S MOTION FOR JOINDER
`
`
`
`Case No. IPR2024-00366
`U.S. Patent No. 8,760,454
`
`On January 2, 2024, Petitioner filed a Motion for Joinder seeking joinder of
`
`the present proceeding with Realtek Semiconductor Corp. v. ATI Technologies ULC,
`
`Case No. IPR2023-00922. Patent Owner does not oppose joinder of these
`
`proceedings, under the conditions set forth in Petitioner’s motion, in which
`
`Petitioner agrees to an “understudy” role, and the additional constraints that, as long
`
`as Realtek remains a party:
`
`TCL will not rely on expert testimony beyond that submitted by Realtek;
`
`TCL will not separately file or serve objections or discovery requests, will not
`
`receive separate cross examination or redirect time, and will not separately cross
`
`examine or redirect any witness;
`
`TCL will not file substantive papers;
`
`TCL agrees that Realtek will make all final decisions and will retain
`
`responsibility for oral argument (including telephone hearings and appeals);
`
`and TCL will not seek or receive separate time and will not separately argue
`
`during oral argument, including telephone hearings and appeals.
`
`Patent Owner believes these conditions are in keeping with Petitioner’s
`
`representation that it will agree to an understudy role, and are conditions that the
`
`Board has found to be proper in these circumstances. See, e.g., Keysight
`
`Technologies, Inc. v. Centripetal Networks, Inc., IPR2022-01199, Paper 13 at 62.
`
`1
`
`
`
`Case No. IPR2024-00366
`U.S. Patent No. 8,760,454
`Patent Owner attempted to secure TCL’s agreement but did not receive a
`
`response.
`
`Dated: February 2, 2024
`
`/William A. Meunier/
`William A. Meunier (Reg. No. 41,193)
`Mintz, Levin, Cohn, Ferris, Glovsky and
`Popeo, P.C.
`One Financial Center
`Boston, Massachusetts 02111
`Phone: 617-348-1845
`Fax: 617-542-2241
`Emails: WAMeunier@mintz.com
`
`2
`
`
`
`Case No. IPR2024-00366
`U.S. Patent No. 8,760,454
`CERTIFICATE OF SERVICE
`
`I certify that a copy of Patent Owner’s Response to Petitioner’s Motion for
`
`Joinder is being served by electronic mail on the following counsel of record:
`
`Lead Counsel
`John Schnurer
`Reg. No. 52,196
`Perkins Coie LLP
`11452 El Camino Real, Suite 300
`San Diego, California 92130
`Telephone: (858) 720-5700
`Facsimile: (858) 720-5799
`Email: schnurer-ptab@perkinscoie.com;
`
`Backup Counsel
`Yun (Louise) Lu
`Reg. No. 72,766
`Perkins Coie LLP
`11452 El Camino Real, Suite 300
`San Diego, California 92130
`Telephone: (858) 720-5700
`Facsimile: (858) 720-5799
`Email: lu-ptab@perkinscoie.com;
`
`Kevin J. Patariu
`Reg. No. 63,210
`Perkins Coie LLP
`11452 El Camino Real, Suite 300
`San Diego, California 92130
`Telephone: (858) 720-5700
`Facsimile: (858) 720-5799
`Email: patariu-ptab@perkinscoie.com;
`
`Kyle R. Canavera
`Reg. No. 72,167
`Perkins Coie LLP
`11452 El Camino Real, Suite 300
`San Diego, California 92130
`Telephone: (858) 720-5700
`Facsimile: (858) 720-5799
`Email: canavera-
`ptab@perkinscoie.com;
`
`Dated: February 2, 2024
`
`/William A. Meunier/
`William A. Meunier (Reg. No. 41,193)
`
`3
`
`
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