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Displaying 129-143 of 394 results

15 Notice: POs Notice of Taking Deposition of Dr Douglas Reindl

Document IPR2015-00882, No. 15 Notice - POs Notice of Taking Deposition of Dr Douglas Reindl (P.T.A.B. Nov. 20, 2015)
Patent RE44,815 Reissue Date: March 25, 2014 Title: SYSTEM AND METHOD FOR CHILLING INLET AIR
PLEASE TAKE NOTICE THAT Patent Owner TAS ENERGY, INC. (“TAS”) by and through its counsel, will take the deposition of Dr. Douglas Reindl with regard to Inter Partes Review No. IPR2015-00882 for Patent RE44,815.
Per the agreement of counsel, this deposition will take place on December 1, 2015, beginning at 9:00 a.m. Eastern Standard Time.
The deposition testimony will be recorded by videographic and stenographic means, and real time transcription services may be utilized.
King Registration No. 69,721 Counsel for Patent Owner
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10 Preliminary Response: Preliminary Response of Patent Owner TAS Energy, Inc

Document IPR2015-01665, No. 10 Preliminary Response - Preliminary Response of Patent Owner TAS Energy, Inc (P.T.A.B. Nov. 19, 2015)
Such features included passing chilled water at a low flow rate through a specially circuited cooling coil located near the turbine air inlet thus causing an abnormally large temperature rise—more than 20 to 35 degrees Fahrenheit.
This straightforward statement made in the ’815 patent’s own specification cannot be somehow twisted into the notion that “a duplex chiller inlet in fluid communication with the warm water port of the thermal energy storage tank” was known in the prior art in the context of the invention, let alone in the references cited by Trane.
But that is exactly what is missing from the Petition—Trane has not carried its burden to explain why “a person of ordinary skill at the time of the invention would have selected and combined those prior art elements in the normal course of research and development to yield the claimed invention.” Unigene Labs., Inc. v. Apotex, Inc., 655 F.3d 1352, 1360 (Fed. Cir. 2011).
But again, Trane cannot meet its burden of proving obviousness because it does not even begin to explain why “a person of ordinary skill at the time of the invention would have selected and combined those prior art elements in the normal course of research and development to yield the claimed invention.” Unigene Labs., 655 F.3d at 1360.
“A given reference is ‘publicly accessible’ upon a satisfactory showing that such document has been disseminated or otherwise made available to the extent that persons interested and ordinarily skilled in the subject matter or art exercising reasonable diligence, can locate it.” SRI Int'l, Inc. v. Internet Sec.
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14 Notice: Notice of Stipulated Amendment to Scheduling Order

Document IPR2015-00882, No. 14 Notice - Notice of Stipulated Amendment to Scheduling Order (P.T.A.B. Oct. 26, 2015)
The parties hereby advise the Board that they have agreed to change due dates 1-3 of the scheduling order as follows: Milestone Prior Schedule New Schedule Impact DD1: PO Response/Motion to Amend DD2: P Reply / Opp.
To MTA DD3: Reply to MTA DD4: MFO/MTE/Request for Oral Argument DD5: Response to MFO/Opp.
DD6: Reply to MTE DD7: Oral Argument 12/1/2015 12/15/2015 +2 weeks 2/9/2016 3/9/2016 2/23/2016 +2 weeks 3/15/2016 +6 days 3/30/2016 3/30/2016 None 4/13/2026 4/20/2016 5/4/2016 4/13/2016 None 4/20/2016 None 5/4/2016 None Pursuant to Appendix A-2 of the Trial Practice Guide, these changes may be made by stipulation because they do not impact due dates 6 or 7.
Dated: October 26, 2015 Respectfully submitted, By: /Thomas B. King/ Thomas B.
King Registration No. 69,721 Counsel for Patent Owner By: /Steven J. Schwarz/ Steven J. Schwarz Registration Number 47,070 Counsel for Petitioner
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13 Notice: Expunged

Document IPR2015-00882, No. 13 Notice - Expunged (P.T.A.B. Oct. 26, 2015)
BLANK BLANK
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8 Notice: Mandatory Notice by TAS Energy, Inc

Document IPR2015-01665, No. 8 Notice - Mandatory Notice by TAS Energy, Inc (P.T.A.B. Sep. 11, 2015)
Patent RE44,815 Reissue Date: March 25, 2014 Title: SYSTEM AND METHOD FOR CHILLING INLET AIR
TAS Energy, Inc. is the patent owner by assignment.
TAS Energy, Inc. may be served on counsel of record.
Patent Owner consents to service by email.
King Registration No. 69,721 Counsel for Patent Owner Patent Owner’s Mandatory Notice
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7 Notice: Mandatory Notice by TAS Energy, Inc

Document IPR2015-01665, No. 7 Notice - Mandatory Notice by TAS Energy, Inc (P.T.A.B. Sep. 2, 2015)
Patent RE44,815 Reissue Date: March 25, 2014 Title: SYSTEM AND METHOD FOR CHILLING INLET AIR
TAS Energy, Inc. is the patent owner by assignment.
TAS Energy, Inc. may be served on counsel of record.
Patent Owner consents to service by email.
King Registration No. 69,721 Counsel for Patent Owner Patent Owner’s Mandatory Notice
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5 Notice: Certificate of Service of Petition for Inter Partes Review

Document IPR2015-01665, No. 5 Notice - Certificate of Service of Petition for Inter Partes Review (P.T.A.B. Aug. 20, 2015)
CERTIFICATE OF SERVICE Pursuant to 37 CFR §§ 42.6(e)(4)(i) et seq. and 42.105(b), the undersigned certifies that a complete and entire copy of this Petition for Inter Partes Review and all supporting exhibits was served on August 3, 2015, by overnight delivery to the following address of record for the subject patent and address for TAS Energy, Inc.
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3 Power of Attorney: Power of Attorney

Document IPR2015-01665, No. 3 Power of Attorney - Power of Attorney (P.T.A.B. Aug. 4, 2015)
§ I hereby appoint Practitioner(s) associated with the following Customer Number
as my/our attomey(s) or agerit(s), and to transact all business in the Patent Trial & Appeal Board of the United States Patent and Trademark Office connected therewith for the petition for Inter Partes Review of U.S. Patent No. RE44,815 referenced in the associated transmittal.
(title of signer) of: Real Party in Interest, TRAN E U'S' INC‘ Review.
to this Petition for Inter Partes
NOTE: Signature - This form must be signed in accordance with 37 CFR 1.33.
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2 Power of Attorney: Power of Attorney

Document IPR2015-01665, No. 2 Power of Attorney - Power of Attorney (P.T.A.B. Aug. 3, 2015)
as my/our attorney(s) or agent(s), and to transact all business in the Patent Trial & Appeal Board of the United States Patent and Trademark Office connected therewith for the petition for Inter Partes Review of U.S. Patent No. RE44,815 referenced in the associated transmittal.
109886 I I hereby appoint Practitioner(s) associated with the following Customer Number
to this Petition for Inter Partes
Coman SIGNATURE of Petitioners
NOTE: Signature - This form must be signed in accordance with 37 CFR 1.33.
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10 Preliminary Response: Expunged

Document IPR2015-00886, No. 10 Preliminary Response - Expunged (P.T.A.B. Jun. 25, 2015)
BLANK BLANK
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9 Preliminary Response: Patent Owner TAS Energy Incs Preliminary Response

Document IPR2015-00886, No. 9 Preliminary Response - Patent Owner TAS Energy Incs Preliminary Response (P.T.A.B. Jun. 25, 2015)
Thus, Stellar is asking the Board to find that a hypothetical person of ordinary skill in the art would have connected the two technologies together, notwithstanding the fact that actual practitioners failed to do so, including Andrepont, who Dr. Reindl agreed was a “leader in the field of turbine inlet air cooling.” Ex. 2101 at 50:15-17.
Stellar does not identify any economic benefits other than the ones disclosed by Mornhed when he states that series chilling will “almost double the capacity of existing distribution piping or, alternatively, reduce pumping power to a fraction.” Ex. 1116 at 4.
Moreover, the aspects of series chillers mentioned in Mornhed (increased capacity, decreased pumping power, and other economic benefits) do not apply to Andrepont for the reasons stated above.
Notwithstanding TAS’ arguments that this analysis was conclusory, the Board found that Mornhed’s discussion of the economic benefits of series chilling, such as reduced piping and pumping costs (which were not mentioned in GE’s Petition), presented a sufficient basis on which to institute the IPR.
Notwithstanding the capacity differences between the systems, Stellar asserts that combining or replacing “the chiller package C-1 of Andrepont with the Trane Duplex™ chiller” would have been “merely simple substitution of one known element for another to obtain predictable results.” Pet. at 48.
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9 Preliminary Response: Patent Owner TAS Energys Incs Preliminary Response

Document IPR2015-00882, No. 9 Preliminary Response - Patent Owner TAS Energys Incs Preliminary Response (P.T.A.B. Jun. 25, 2015)
TAS requests that the Board, in reviewing the Petition, reject those arguments in which Stellar attempts to leverage the term “comprising” to extend the claims’ scope to the point where they encompass the prior art, but read out express claim limitations in the process.
But without reconciling the differences between TIC and district cooling or supporting its assertions with evidence and meaningful expert testimony, Stellar’s argument amounts to little more than a conclusory paraphrasing of language from KSR that falls far short of the required detailed analysis.
Inc., IPR2014- 00529, Paper No. 8, at 15 (according “no probative weight” to an expert declaration that “does not provide any factual basis for its assertions.”) Finally, Stellar invokes the “simple substitution” language of KSR, stating that the proposed combination “requires mere simply substitution of one known element for another to obtain predictable results of variable flow with a reasonable Patent Owner’s Preliminary Response
asking the Board to find that a hypothetical person of ordinary skill in the art would have connected the two technologies together, notwithstanding the fact that actual practitioners failed to do so, including Andrepont, who Dr. Reindl agreed was a “leader in the field of turbine inlet air cooling.” Ex. 2001 at 50:15-17.
Stellar argues that it would have been obvious to make such a “simple substitution” because Dharmadhikari attributes a number of benefits to its chiller arrangement, including “reduced investment cost, increased plant efficiency, and the ability to modulate operating mode according to energy demands.” Pet. at 45 (citing Ex. 1021 at 8).
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4 Notice: Mandatory Notice by TAS Energy, Inc

Document IPR2015-00886, No. 4 Notice - Mandatory Notice by TAS Energy, Inc (P.T.A.B. Apr. 8, 2015)

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1 Power of Attorney: Power of Attorney

Document IPR2015-00886, No. 1 Power of Attorney - Power of Attorney (P.T.A.B. Mar. 17, 2015)

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4 Notice: Mandatory Notice by TAS Energy, Inc

Document IPR2015-00882, No. 4 Notice - Mandatory Notice by TAS Energy, Inc (P.T.A.B. Apr. 8, 2015)

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