throbber
Jeffrey B. Plies
`DECHERT LLP
`300 West 6th Street, Suite 2010
`Austin, Texas 78701
`Telephone: (512) 394-3000
`jeffrey.plies@dechert.com
`
`S. Michael Song
`DECHERT LLP
`2440 W. El Camino Real, Suite 700
`Mountain View, California 94040
`Telephone: (650) 813-4800
`michael.song@dechert.com
`
`Counsel for Defendants
`Samsung Electronics Co., Ltd.,
`and Samsung Electronics America, Inc.
`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`THETA IP, LLC.
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
`
`Defendants
`
`Robert L. Masterson
`DECHERT LLP
`Cira Centre, 2929 Arch Street
`Philadelphia, Pennsylvania 19104
`Telephone: (215) 994-4000
`robert.masterson@dechert.com
`
`Case No. 2:16-cv-00527-JRG-RSP
`
`JURY
`
`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.’S INVALIDITY CONTENTIONS
`
`IPR2023-00817
`Theta EX2010
`
`

`

`• U.S. Patent No. 6,807,406, filed Oct. 17, 2000, issued Oct. 19, 2004 to Razavi et
`al. (the “’406 Patent”);
`
`• U.S. Patent No. 6,819,938, filed June 20, 2002, issued Nov. 16, 2004 to Sahota
`(the “’938 Patent”);
`
`• U.S. Patent No. 6,944,427, filed Jan. 31, 2003, issued Sep. 13, 2005 to Haub et al.
`(the “’427 Patent”);
`
`• U.S. Patent No. 6,965,655, filed June 20, 2000, issued Nov. 15, 2005 to Mostov et
`al. (the “’655 Patent”);
`
`• U.S. Patent No. 7,054,605, filed Jan. 16, 2002, issued May 30, 2006 to Groe (the
`“’605 Patent”);
`
`• U.S. Patent No. 7,016,654, filed Apr. 30, 2002, issued Mar. 21, 2006 to Bugeja
`(the “’654 Patent”);
`
`• U.S. Patent No. 7,274,760, filed Aug. 2, 2001, issued Sep. 25, 2007 to Tsividis et
`al. (the “’760 Patent”);
`
`• U.S. Patent No. 7,299,021, filed Sep. 13, 2002, issued Nov. 20, 2007 to Parssinen
`et al. (the “’021 Patent”);
`
`• U.S. Patent Application 20040042572, filed Aug. 2, 2001 by Tsividis et al. (the
`“’572 Application”);
`
`• PCT Publication No. WO 02/056470, published July 18, 2002 by Palaskas et al.
`(the “’470 Application”); and
`
`• Farbod Behbahani et al., “Adaptive Analog IF Signal Processor for a Wide-Band
`CMOS Wireless Receiver,” 36 IEEE J. Solid State Circuits 1205-17 (2001)
`(“Behbahani 2001”).
`
`The identified prior art references further include any other references listed in this
`
`document or the accompanying claim charts.
`
`III.
`
`CLAIM CHARTS PREPARED PER PATENT RULE 3-3(B) AND (C)
`
`Pursuant to P. R. 3-3(b) and (c), Samsung provides the following charts identifying where
`
`specifically in each alleged item of prior art each limitation of each asserted claim is found.
`
`4
`
`IPR2023-00817
`Theta EX2010
`
`

`

`Dated: November 28, 2016
`
`DECHERT LLP
`
`/s/ Jeffrey B. Plies
`Jeffrey B. Plies
`DECHERT LLP
`300 West 6th Street, Suite 2010
`Austin, Texas 78701
`Telephone: (512) 394-3000
`jeffrey.plies@dechert.com
`
`S. Michael Song
`DECHERT LLP
`2440 W. El Camino Real, Suite 700
`Mountain View, California 94040
`Telephone: (650) 813-4800
`michael.song@dechert.com
`
`Robert L. Masterson
`DECHERT LLP
`Cira Centre, 2929 Arch Street
`Philadelphia, Pennsylvania 19104
`Telephone: (215) 994-4000
`robert.masterson@dechert.com
`
`Counsel for Defendants
`Samsung Electronics Co., Ltd.,
`and Samsung Electronics America, Inc.
`
`14
`
`IPR2023-00817
`Theta EX2010
`
`

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