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17 Notice: Joint Stipulation to Modify Schedule

Document IPR2020-00255, No. 17 Notice - Joint Stipulation to Modify Schedule (P.T.A.B. Aug. 26, 2020)
Pursuant to a joint stipulation of Petitioner and Patent Owner (“Parties”), and in accordance with the guidance provided in the Scheduling Order (Paper 14), the Parties hereby stipulate to modify DUE DATES 1-3 as follows: • DUE DATE 1 will be changed from October 13, 2020 to November 3, 2020.
A revised DUE DATE APPENDIX is attached showing the changes made relative to the latest schedule in redline.
1 The Scheduling Order lists Due Dates 2-4 as January 5, 2020, February 12, 2020, and March 4, 2020, respectively.
The Parties understand this to be a typographical error, with the correct original dates for Due Dates 2-4 being January 5, 2021, February 12, 2021, and March 4, 2021, respectively.
____/ Kenneth J. Weatherwax/________ Kenneth J. Weatherwax, Reg. No. 54,528 LOWENSTEIN & WEATHERWAX LLP Lead Counsel for Patent Owner Date: August 26, 2020
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15 Objection: Patent Owners Objections to Evidence

Document IPR2020-00255, No. 15 Objection - Patent Owners Objections to Evidence (P.T.A.B. Aug. 11, 2020)
Pursuant to 37 C.F.R. § 42.64(b)(1) and the Federal Rules of Evidence (“FRE”), Patent Owner objects to the following documents submitted by Petitioner Apple Inc.
The document or documents are relied upon as evidence of prior art or of common knowledge or understanding of persons in the art at the priority date at issue, but are inadmissible because they have not been shown to qualify as prior art under, inter alia, 35 U.S.C. § 311(b), and there is a lack of supporting documentation to demonstrate common knowledge or understanding as of the priority date.
Exhibit 3002 Under FRE 201, this document was not introduced with an opportunity to be heard on the propriety of taking notice of it or the tenor of the matter noticed, or an opportunity for further evidentiary submissions by the parties if additional evidence were necessary regarding this subject matter.
Intelligent Bio-Systems, Inc. v. Illumina Cambridge, Ltd., 821 F.3d 1359, 1369 (Fed. Cir. 2016) (“It is of the utmost importance that petitioners in the IPR proceedings adhere to the requirement that the initial petition identify with particularity the evidence that supports the grounds for the challenge to each claim.
… [T]he expedited nature of IPRs bring with it an obligation for petitioners to make their case in their petition to institute.”).
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11 Reply: Petitioners Reply to Patent Owners Preliminary Response

Document IPR2020-00255, No. 11 Reply - Petitioners Reply to Patent Owners Preliminary Response (P.T.A.B. Jun. 11, 2020)
In determining whether to exercise its discretion to institute IPRs, the Board has recently focused on whether the same invalidity issues raised within a petition Proceeding No.: IPR2020-00255 Attorney Docket: 39521-0088IP2 are expected to be resolved in district court, prior to that petition’s projected final written decision date.
At the same time, “the Board’s cases addressing earlier trial dates as a basis for denial under NHK have sought to balance considerations such as system efficiency, fairness, and patent quality.” Apple Inc. v. Fintiv, Inc., IPR2020-00019 Pap.
Mar. 11, 2015)( “the most important factor bearing on whether to grant a stay … is the prospect that the inter partes review proceeding will result in simplification of the issues”)(Bryson); Uniloc USA, Inc. v. Samsung Elecs.
Fintiv Factor 3: Seven's Conduct Dictated the Timing of Apple's Petitions, which Outweighs the Forced Investment in Litigation In its complaint, Seven asserted sixteen patents, which contain over five- hundred fifty claims.
It is no wonder that Apple needed the time taken to prepare its twenty-one petitions, as it was faced with the immense burden of understanding the five-hundred fifty claims contained in these patents and the potential prior art that might be relevant to them.
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28 Motion: Joint Request to Treat Settlement as BCI

Document IPR2020-00255, No. 28 Motion - Joint Request to Treat Settlement as BCI (P.T.A.B. Dec. 2, 2020)
Pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(b)-(c), Petitioner Apple Inc. (“Apple” or “Petitioner”) and Patent Owner SEVEN Networks, LLC (“SEVEN” or “Patent Owner”) (collectively “the Parties”), jointly request that the Settlement and License Agreement (Exhibit 2100) submitted concurrently herewith be treated as business confidential information and kept separate from the files of the involved patent and inter partes review proceeding, and only made available to Federal Government agencies upon written request or to any other person upon written request and a showing of good cause.
The Agreement describes the confidential terms resolving the Parties’ disputes, which constitutes confidential information under the Board’s rules.
By: /Kenneth J. Weatherwax/ Kenneth J. Weatherwax Registration No. 54,528 Counsel for Patent Owner
Respectfully submitted,
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27 Motion: Joint Motion to Terminate

Document IPR2020-00255, No. 27 Motion - Joint Motion to Terminate (P.T.A.B. Dec. 2, 2020)
17, 2020) 2021 Madeline Holcombe, Fauci says second wave is ‘not inevitable’ as coronavirus cases climb in some states, CNN HEALTH (Jun.
For the Board’s convenience, it is noted that a Joint Motion substantially identical to this one is being filed today in each of the sixteen cases.
The Settlement Agreement, Exhibit 2100, has been made in writing, and a true and correct copy shall be filed with this Office as business confidential information pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(b)-(c).
The Parties certify that there are no collateral agreements or understandings made in connection with, or in contemplation of, the termination of this inter partes review.
For the foregoing reasons, the Parties jointly and respectfully request that the Board terminate the instant proceeding.
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26 Notice: Fourth Joint Stipulation to Modify Schedule

Document IPR2020-00255, No. 26 Notice - Fourth Joint Stipulation to Modify Schedule (P.T.A.B. Nov. 27, 2020)
Pursuant to a joint stipulation of Petitioner and Patent Owner (“Parties”), and in accordance with the guidance provided in the Scheduling Order (Paper 14), the Parties hereby stipulate to modify DUE DATE 1 as follows: • DUE DATE 1 will be changed from November 30, 2020 to December 14, 2020.
A revised DUE DATE APPENDIX is attached showing the changes made relative to the latest schedule in redline.
This stipulation does not affect or otherwise modify the dates for DUE DATES 2-8.
As further agreed by the Parties, Patent Owner files this Notice on behalf of both Parties.
____/ Kenneth J. Weatherwax /_______ Kenneth J. Weatherwax, Reg. No. 54,528 LOWENSTEIN & WEATHERWAX LLP Lead Counsel for Patent Owner Date: November 27, 2020
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25 Notice: Third Joint Stipulation To Modify Schedule

Document IPR2020-00255, No. 25 Notice - Third Joint Stipulation To Modify Schedule (P.T.A.B. Oct. 30, 2020)
Pursuant to a joint stipulation of Petitioner and Patent Owner (“Parties”), and in accordance with the guidance provided in the Scheduling Order (Paper 14), the Parties hereby stipulate to modify DUE DATE 1 as follows: • DUE DATE 1 will be changed from November 17, 2020 to November 30, 2020.
A revised DUE DATE APPENDIX is attached showing the changes made relative to the latest schedule in redline.
This stipulation does not affect or otherwise modify the dates for DUE DATES 2-8.
As further agreed by the Parties, Patent Owner files this Notice on behalf of both Parties.
____/ Kenneth J. Weatherwax /_______ Kenneth J. Weatherwax, Reg. No. 54,528 LOWENSTEIN & WEATHERWAX LLP Lead Counsel for Patent Owner Date: October 30, 2020
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24 Notice: Second Joint Stipulation To Modify Schedule

Document IPR2020-00255, No. 24 Notice - Second Joint Stipulation To Modify Schedule (P.T.A.B. Oct. 15, 2020)
Pursuant to a joint stipulation of Petitioner and Patent Owner (“Parties”), and in accordance with the guidance provided in the Scheduling Order (Paper 14), the Parties hereby stipulate to modify DUE DATE 1 as follows: • DUE DATE 1 will be changed from November 3, 2020 to November 17, 2020.
A revised DUE DATE APPENDIX is attached showing the changes made relative to the latest schedule in redline.
This stipulation does not affect or otherwise modify the dates for DUE DATES 2-8.
As further agreed by the Parties, Patent Owner files this Notice on behalf of both Parties.
____/ Kenneth J. Weatherwax /_______ Kenneth J. Weatherwax, Reg. No. 54,528 LOWENSTEIN & WEATHERWAX LLP Lead Counsel for Patent Owner Date: October 15, 2020
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20 Motion: Petitioners Motion for Pro Hac Vice Admission of Jonathan Bright

Document IPR2020-00255, No. 20 Motion - Petitioners Motion for Pro Hac Vice Admission of Jonathan Bright (P.T.A.B. Sep. 15, 2020)
4-2 Preliminary Claim Construction and Extrinsic Evidence in Seven Networks, LLC, v. Apple Inc. (Case No. 2:19-cv-115) (E.D.
APPLE-1049 Seven’s Notice of Compliance re Service of Preliminary Claim Construction and Extrinsic Evidence, Case No. 2:19-CV-115- JRG, E.D.
Bright is a patent litigation attorney with more than six years of experience representing clients in cases involving, inter alia, graphical user interfaces, nonvolatile memories, digital cameras, wireless communication standards, and semiconductor technology.
Bright also has particular experience and familiarity with the substantive and technical issues involved in this inter partes review proceeding.
Accordingly, Apple submits that there is good cause under 37 C.F.R. § 42.10(c) for the Board to recognize Jonathan Bright as counsel pro hac vice during this proceeding.
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16 Motion: Motion for Pro Hac Vice Admission of Nathan Lowenstein

Document IPR2020-00255, No. 16 Motion - Motion for Pro Hac Vice Admission of Nathan Lowenstein (P.T.A.B. Aug. 12, 2020)

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7 Notice: Patent Owners First Updated Mandatory Notices

Document IPR2020-00255, No. 7 Notice - Patent Owners First Updated Mandatory Notices (P.T.A.B. Jan. 27, 2020)

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23 Notice of Deposition: Patent Owner First Amended Notice of Deposition

Document IPR2020-00255, No. 23 Notice of Deposition - Patent Owner First Amended Notice of Deposition (P.T.A.B. Oct. 8, 2020)

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21 Notice: Petitioners Updated Mandatory Notices

Document IPR2020-00255, No. 21 Notice - Petitioners Updated Mandatory Notices (P.T.A.B. Sep. 15, 2020)

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10 Exhibit List: Petitioners Exhibit List

Document IPR2020-00255, No. 10 Exhibit List - Petitioners Exhibit List (P.T.A.B. May. 29, 2020)

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9 Preliminary Response: Patent Owners Preliminary Response

Document IPR2020-00255, No. 9 Preliminary Response - Patent Owners Preliminary Response (P.T.A.B. May. 18, 2020)

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