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9 Reply: Petitioners Reply to Patent Owners Preliminary Response

Document IPR2015-01525, No. 9 Reply - Petitioners Reply to Patent Owners Preliminary Response (P.T.A.B. Nov. 4, 2015)
Patent Owner cites information that shows a parent-subsidiary relationship between SEC and Petitioner Samsung Display Corporation (“Samsung Display”), which the Board has consistently held does not establish that the parent is an RPI to an IPR.
Attorney Docket No. P252866.US.01 “war.” In Galderma, the Board’s decision turned on the fact that the same person who was President and CEO of both the unnamed parent and subsidiary petitioner had a significant degree of effective control over the IPR.
The term “directly or indirectly controlled” refers simply to the parties’ general parent-subsidiary relationship where “control” means a controlling share of stock, which, as stated above, is not enough to establish that the parent is an RPI in this IPR.
The information proffered by Patent Owner is much different than that in the decisions they cite, which showed that executives held positions simultaneously at both the unnamed parent and subsidiary petitioner and exercised control over the IPR(s).
The Board’s observation in TRW that “the statements in press releases on which Patent Owner relies do not establish or suggest that the parent funds, directs, or controls the IPR petition or proceeding, or that the subsidiary is a proxy for the parent” applies with equal force in this case.
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7 Preliminary Response: Preliminary Response

Document IPR2015-01525, No. 7 Preliminary Response - Preliminary Response (P.T.A.B. Oct. 22, 2015)

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11 Reply: Patent Owners Sur Reply to Petitioners Reply

Document IPR2015-01525, No. 11 Reply - Patent Owners Sur Reply to Petitioners Reply (P.T.A.B. Nov. 12, 2015)

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4 Notice: Related Matters

Document IPR2015-01525, No. 4 Notice - Related Matters (P.T.A.B. Jul. 16, 2015)

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10 Reply: Certificate of Service

Document IPR2015-01525, No. 10 Reply - Certificate of Service (P.T.A.B. Nov. 6, 2015)

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18 Notice: Petitioners Notice of Deposition of Michael PC Watts, PhD

Document IPR2015-01416, No. 18 Notice - Petitioners Notice of Deposition of Michael PC Watts, PhD (P.T.A.B. May. 25, 2016)

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17 Notice: Petitioners Objections to Patent Owners Evidence

Document IPR2015-01416, No. 17 Notice - Petitioners Objections to Patent Owners Evidence (P.T.A.B. Apr. 15, 2016)

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16 Reply: Patent Owner Response Under 37 CFR 42120

Document IPR2015-01416, No. 16 Reply - Patent Owner Response Under 37 CFR 42120 (P.T.A.B. Apr. 8, 2016)

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22 Declaration: Patent Owners Motion to Exclude Petitioners Reply Evidence

Document IPR2015-01416, No. 22 Declaration - Patent Owners Motion to Exclude Petitioners Reply Evidence (P.T.A.B. Aug. 22, 2016)

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20 Declaration: Patent Owners Objections to Petitioners Reply

Document IPR2015-01416, No. 20 Declaration - Patent Owners Objections to Petitioners Reply (P.T.A.B. Jul. 14, 2016)

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11 Reply: Patent Owners Sur Reply to Petitioners Reply

Document IPR2015-01416, No. 11 Reply - Patent Owners Sur Reply to Petitioners Reply (P.T.A.B. Nov. 12, 2015)

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10 Reply: Petitioners Reply to Patent Owners Preliminary Response

Document IPR2015-01416, No. 10 Reply - Petitioners Reply to Patent Owners Preliminary Response (P.T.A.B. Nov. 4, 2015)

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2 Power of Attorney: Power of Attorney

Document IPR2015-01416, No. 2 Power of Attorney - Power of Attorney (P.T.A.B. Jun. 16, 2015)

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1 Petition: Petition for Inter Partes Review of USP 5850275

Document IPR2015-01416, No. 1 Petition - Petition for Inter Partes Review of USP 5850275 (P.T.A.B. Jun. 16, 2015)

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21 Declaration: Patent Owners Request for Oral Hearing

Document IPR2015-01416, No. 21 Declaration - Patent Owners Request for Oral Hearing (P.T.A.B. Aug. 22, 2016)

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