`Case 5:19-cv-00036—RWS Document 267-2 Filed 04/07/20 Page 1 of 3 PageID #: 9856
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`EXHIBIT A
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`EXHIBIT A
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`
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`Case 5:19-cv-00036-RWS Document 267-2 Filed 04/07/20 Page 2 of 3 PageID #: 9857
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
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`APPLE INC.,
`Petitioner
`
`v.
`
`MAXELL LTD.,
`Patent Owner
`
`
`
`Case No. IPR2020-00204
`Patent No. 6,928,306
`
`
`
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,928,306
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`
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`Case 5:19-cv-00036-RWS Document 267-2 Filed 04/07/20 Page 3 of 3 PageID #: 9858
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`U.S. Patent 6,928,306
`IPR2020-00204
`
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`non-English language prior art. This searching was comprehensive and involved
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`time-intensive tasks such as translating foreign language documents and analyzing
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`the same. Additionally, Apple prepared and served invalidity contentions in the
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`Maxell litigation on August 14, 2019, which involved a significant time investment
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`beyond the prior art searching already undertaken. Immediately upon completing the
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`invalidity contentions, Apple began preparing the IPRs for the ten asserted patents,
`
`including the ’306 Patent. This work included additional prior art searching (beyond
`
`the prior art searching performed for the invalidity contentions), identifying and
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`retaining experts, and preparing corresponding petitions and expert declarations. As
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`the Board can appreciate, these tasks are time intensive and require a certain
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`specialty and expertise. This is especially true given filing a petition that is not well-
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`supported, precise, and thorough risks not complying with the requirements for IPR.
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`Since the Maxell litigation was filed, Apple has worked diligently to prepare and file
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`this Petition, has not delayed filing of this Petition, either intentionally or otherwise,
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`and does no obtain any tactical advantage from any delay.
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`Given the extremely time-intensive process for preparation of any petition, let
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`alone petitions for ten patents (all but three of which are unrelated), Apple’s time to
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`filing of this Petition is reasonable. Maxell filed litigation asserting ten patents and
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`should expect that Apple would file IPRs. Maxell would reap an inequitable
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`advantage were the Board to exercise its discretion to not institute under § 314(a)
`
`
`
`46
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`
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