AZar et al., “Routing Strategies for Fast Networks,” May 1992, INFOCOM ’92, Eleventh Annual Joint Conference of the IEEE Computer and Communications Societies, vol.

* Cho et al., “A Flood Routing Method for Data Networks,” Sep. 1997, Proceedings of 1997 International Conference on Information, Communications, and Signal Processing, vol.

* Komine et al., “A Distributed Restoration Algorithm for Multiple—Link and Node Failures of Transport Networks,” Dec. 199 Global Telecommunications Conference, 1990, and Exhibition, IEEE, vol.

Examples of client/server middleware systems include remote procedure calls (“RPC”), database servers, and the common object request broker architecture (“CORBA”).

In one embodiment, the distance that the edge connection request message travels is established by the portal computer to be approximately twice the estimated diameter of the broadcast channel.

Assignee: BOEING COMPANY, THE Assignor: HOLT, FRED B. BOURASSA, VIRGIL E. Correspondent: PERKINS COIE LLP

Assignee: BOEING COMPANY, THE Assignor: HOLT, FRED B. BOURASSA, VIRGIL E. Correspondent: PERKINS COIE LLP

MORRIS, NICHOLS, ARSHT & TUNNELL LLP Jack B. Blumenfeld (#1014) Rodger D. Smith II (#3778) Jeremy A. Tigan (#5239) Stephen J. Kraftschik (#5623) 1201 North Market Street P.O.

Similarly, Pure’s speculation as to the tax consequences of the Data Domain acquisition are irrelevant, as they do not change the language chosen by the parties in the actual contract provisions and do not concern standing to assert a patent.

Indeed, the economic “value” of licensed rights may change dramatically over time as new markets open up and new businesses are created that leverage the patented technology.

In the interest of CallWave being your mind, if you know, in fact, that you don't 10:51:44 4 able to assemble a coherent strategy with respect need that entire breadth, that's where it gets to 10:51:44 5 to validity, that's going to be severely impeded be strategic surrender of claim scope; right?

opportunity to do that, your Honor, even to the 10:54:27 3 THE COURT: The IPR, presumably extent that the issues only involve validity, 10:54:30 4 whoever brought that, is that a matter of public which is simply not supported by the balancing 10:54:36 5 record?

But the bigger point that I'd like to try to make on behalf of CallWave, Your Honor, is these are interested parties who are coordinating their participation in the IPR and the litigation, not the least through the use of the same individual on both forums to represent two, at least two of the defendants.

The defendants are not going to get any confidential information from the plaintiff that makes any difference in terms of what happens in the pending IPR potentially future proceedings in which they would actually be involved.

11:02:19 12 of Deutsche Bank, the attorneys for Pepper The second harm is sometimes the 11:02:26 13 Hamilton who get confidential information who loss or the risk that two sets of lawyers will go 11:02:33 14 would be involved in proceeding before the PTO on off in slightly different directions if there is 11:02:37 15 any kind of re-exam are competitive decision a limitation on communication.

In adjudicating disputes over what kind of prosecution bar should be entered, a court must first consider whether there is an “unacceptable risk of inadvertent disclosure or competitive use of confidential information, determined by the extent to which affected counsel is involved in “competitive decisionmaking” with its client.

In evaluating the potential for harm that is key to the second prong of the analysis, a court should consider factors such as “the extent and duration ofcounsel’s past history in representing the client before the [United States Patent and Trademark Office, or ‘PTO’], the degree of the client’s reliance and dependence on that past history, and the potential difficulty the client might face if forced to rely on other counsel for the pending litigation or engage other counsel to represent it before the PTO.” Id. at 1381.‘ In Deutsche Bank Trust Co.

Nov. 17, 2015) (explaining that the “[d]efendants bear the burden to show good cause for the protective [order] provisions, for which they advocate” including the “post-grant proceedings bar” that they sought); Inventor Holdings, LLC v. Wal-Mart Stores Inc., Civil Action No. 1:13-cv-00096 (GMS), 2014 WL 4370320, at *2 (D. Del.

Aug. 27, 2014) (Lukoff, Special Master) (“[D]eterrnining the existence and extent of an exemption shifts the burden to the party seeking to have its counsel participate in post-grant proceedings at the PTO.”); EPL Holdings, LLC v. Apple Inc. , No. C-12-043 06 JST (JSC), 2013 WL 2181584, at *2 (ND.

54 at 4) As a result, were LG’s proposal adopted, and if TSST-K wished to have its lead technical counsel be fully apprised of all relevant documents in this case (including those designated as “Protected Information” by the Protective Order), it would be required to jettison in the IPR proceedings the very lawyers who have already shepherded it through a substantial portion of that matter.

Production of information subject to privacy protections, 1 The three Defendant Groups are: (1) Activision|Blizzard, Inc. (“Activision”); (2) Electronics Arts, Inc. (“EA”); and (3) Take-Two Interactive Software, Inc., Rockstar Games, Inc., and 2K Sports, Inc. (collectively, “Take-Two”).

Defendants shall produce to Plaintiff the core technical documents related to the accused product(s) and accused networking functionalities (to the extent such documents exist), including but not limited to operation manuals, product literature, schematics, and specifications as follows: i. December 16, 2015: for specific games and version identified in Original Complaint as to Take-Two and EA and the First Amended Complaint as to Activision.3 ii.

Plaintiff shall produce to Defendant(s) an initial claim chart relating each accused product to the asserted claims each product allegedly infringes as follows: i. February 17, 2016: for specific games and version identified in Original Complaint as to Take-Two and EA and the First Amended Complaint as to Activision, as well as any other versions of those games for which core technical documents were produced prior to December 16, 2015. ii.

By no later than twenty-four hours prior to the conference/argument, any party opposing the application for relief may file a letter, not to exceed three pages, outlining that party’s reasons for its opposition.

The parties are not required to prepare privilege logs or otherwise schedule documents withheld from production to the extent they (1) relate to activities undertaken in compliance with the duty to preserve information under Fed. R. Civ.

If an objection is made, the following rules apply: (i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

The court for the district where compliance is required—and also, after a motion is transferred, the issuing court—may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.

“Accused Products” shall mean any product or service manufactured, used, sold, offered for sale or imported into the United States by or on behalf of any Defendants that Acceleration Bay alleges infringes the Asserted Patents.

All documents provided to Boeing, Panthesis, Inc., Acceleration Bay, and/or their counsel by you or your fellow Named Inventor relating to the subject matter of any of the Asserted Patents, including, but not limited to any article, book, publication, notebook, specification, memorandum, manual, abstract, or note.

All documents authored, collected, or received by you or your fellow Named Inventor relating to the subject matter of any of the Asserted Patents, including, but not limited to any article, book, publication, notebook, specification, software, or note.