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No. 1-1 COMPLAINT ( Filing fee $ 400 receipt number 0542-13216469), filed by NEODRON LTD.,. (Attachments: ...

Document NEODRON LTD., v. Samsung Electronics Co., Ltd. et al, 6:20-cv-00121, No. 1-1 (W.D.Tex. Feb. 14, 2020)
Inventor: Harald Philipp , Ramble (GB) (73) Assignee: Atmel Corporation, San Jose, CA (US) ( *) Notice: Subject to any disclaimer , the term of this patent is extended or adjusted under 35 U.S.C. 154(b) by 827 days.
The word 'key' as ge;ierally used in this Disclosure and as specifically used in the Claims attached hereto refers to a touchable portion of a mechanical to electrical transducing device that is non bistable in nature.
Capacitive sensors , unlike bistable electromechanical switches which are either open or closed, provide a signal that varies with the degree of touch or extent or coupling between a user's finger and a sensing element of a keyboard.
The addition of counter s 14, or of the logical function equivalent thereof, when used in the accordance with the teachings of this disclosure, can remove or resolve ambigu- 15 ities by methods involving comparison of signal strengths from various keys 12.
The incremental value 'k' can also be zero, i.e., nothing is added or subtracted, although this would tend to make the decision proce ss unstabl e should there be any small amount of signal noise which would intro duce dithering between two competing keys.
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7 Preliminary Response: Preliminary Response

Document IPR2020-00778, No. 7 Preliminary Response - Preliminary Response (P.T.A.B. Jul. 21, 2020)
Instituting review in this IPR would cause the parties and the Board to incur significant inefficiencies and wasted efforts of the type warned of in Fintiv and NHK Spring.
Unable to find any actual “bias” in the prior art, the Petition relies exclusively on Jahier and, more specifically, Jahier’s “thresholds” to argue that claim element is met.
In fact, referring to a virtually identical demonstrative image that Petitioners present and rely upon again here, the Board did “not agree” that this was an accurate depiction of the teachings of Jahier: Id. at 11.
All six parallel district court cases were efficiently stayed pending the resolution of the ITC matter, avoiding duplicative efforts over the litigation of the ‘425 patent.
Further, in Fintiv, the Board found that a hearing scheduled to begin two months before the FWD deadline “weighs somewhat in favor of discretionary denial,” thus an eight-month difference weighs strongly against institution.
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3 Power of Attorney: Power of Attorney Samsung Electronics America, Inc

Document IPR2020-01119, No. 3 Power of Attorney - Power of Attorney Samsung Electronics America, Inc (P.T.A.B. Jun. 17, 2020)
U.S. Patent No. 7,821,425 Pursuant to 37 C.F.R. § 42.10(b), Petitioner Samsung Electronics America, Inc. (“Samsung”) hereby appoints the following attorneys to prosecute and transact all business before the Patent Trial and Appeal Board of the U.S. Patent and Trademark Office in connection with Samsung’s Petition for Inter Partes Review of U.S. Patent No. 7,821,425.
For Samsung Electronics America, Inc. /Jordan Flournoy/ Name: Jordan Flournoy Title: Directory and Senior Legal Counsel
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2 Power of Attorney: Power of Attorney re Samsung Electronics Co, Ltd

Document IPR2020-01119, No. 2 Power of Attorney - Power of Attorney re Samsung Electronics Co, Ltd (P.T.A.B. Jun. 17, 2020)
U.S. Patent No. 7,821,425 Pursuant to 37 C.F.R. § 42.10(b), Petitioner Samsung Electronics Co., Ltd. (“Samsung”) hereby appoints the following attorneys to prosecute and transact all business before the Patent Trial and Appeal Board of the U.S. Patent and Trademark Office in connection with Samsung’s Petition for Inter Partes Review of U.S. Patent No. 7,821,425.
For Samsung Electronics Co., Ltd. /Eric Cha/ Name: Eric Cha Title: Principal Legal Counsel, IP Center
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5 Mandatory Notice: Patent Owners Mandatory Notice

Document IPR2020-00778, No. 5 Mandatory Notice - Patent Owners Mandatory Notice (P.T.A.B. Apr. 24, 2020)
37 C.F.R §42.8(b)(2) – RELATED MATTERS Case No. IPR2020-00778 U.S. Patent No. 7,821,425 Patent Owner notes the following proceedings that may affect, or be affected by, a decision in this proceeding: No. Case Caption Plaintiff/Complainant: Neodron Ltd. 1 Defendant: Amazon.com, Inc.
Lead Counsel Kent Shum (Reg. No. 61,117) Russ August & Kabat 12424 Wilshire Blvd., 12th Fl.
Pursuant to 37 C.F.R. §42.10(b), a Power of Attorney is being filed concurrently with these mandatory notices.
37 C.F.R §42.8(b)(4) – SERVICE INFORMATION Please address all correspondence to the lead and backup counsel as shown above.
Respectfully submitted, /Kent Shum/ Kent Shum (Reg. No. 61,117) Russ August & Kabat 12424 Wilshire Blvd., 12th Fl.
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6 Power of Attorney: Patent Owners Power of Attorney

Document IPR2020-00778, No. 6 Power of Attorney - Patent Owners Power of Attorney (P.T.A.B. Apr. 24, 2020)
Patent Owner.
Patent No. 7,821,425
Pursuant to 37 C.F.R. §42.10(b), Patent Owner Neodron Ltd. is an Irish company with a principal place of business at Unit 4-5, Burton Hall Road, Sandyford, Dublin 18, D18a094, hereby appoints the following practitioners as its attorneys to transact all business in the United States Patent & Trademark Office associated with the above-captioned inter partes review:
Patent No. 7,821,425 Bacan n Counsel Neil A. Rubin (Reg. No. 67,030) Russ August & Kabat 12424 Wilshire Blvd., 12“ F1.
Kent Shum (Reg. No. 61,117) Russ August & Kabat 12424 Wilshire Blvd., 12th Fl.
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2 Power of Attorney: Petitioners Power of Attorney Pursuant to 37 CFR 4210b For Petition for Inter Partes Review

Document IPR2020-00778, No. 2 Power of Attorney - Petitioners Power of Attorney Pursuant to 37 CFR 4210b For Petition for Inter Partes Review (P.T.A.B. Apr. 16, 2020)
In re patent of Philipp Petition for Inter Partes Review U.S. Patent No. 7,821,425 B2 Issued: October 26, 2010 Customer No. 118925 Real Party In Interest: Apple Inc.
Title: CAPATIVE KEYBOARD WITH NON-
37 C.F.R. § 42.10(b) FOR PETITION FOR INTER PARTES REVIEW Pursuant to 37 CFR 42.l0(b) Petitioner, Apple Inc., hereby appoints the Practitioner(s) associated with Customer Number 118925, as its attorney(s) to prosecute and to transact all business before the Patent Trial & Appeal Board of the United States Patent and Trademark Office in connection with the above-identified petition for Inter Partes Review.
Please recognize the correspondence address (including any electronic mail address) associated with Customer Number 118925 for the above-identified Inter Partes Review proceeding number to be the address associated with the appointed lead and backup counsels.
The undersigned is authorized to sign this Power of Attorney on behalf of the Petitioner.
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3 Power of Attorney: Petitioners Power of Attorney Pursuant to 37 CFR 4210b for Petition Fo Inter Partes Review

Document IPR2020-00778, No. 3 Power of Attorney - Petitioners Power of Attorney Pursuant to 37 CFR 4210b for Petition Fo Inter Partes Review (P.T.A.B. Apr. 16, 2020)
III/Z re patent of Philipp fPetition for Inter Partes Review us.
IIssued: October 26, 2010 bReal Party In Interest: Microsoft Corporation FTitle: CAPATIVE KEYBOARD WITH NON—
37 C.F.R. § 42.10(b) FOR PETITION FOR INTER PARTES REVIEW Pursuant to 37 CFR 42.10(b) Petitioner, Microsoft Corporation, hereby appoints the Practitioner(s) associated with Customer Number 118925, as its attorney(s) to prosecute and to transact all business before the Patent Trial & Appeal Board of the United States Patent and Trademark Office in connection with the above-identified petition for Inter Partes Review.
Please recognize the correspondence address (including any electronic mail address) associated with Customer Number 118925 for the above-identified Inter Parres Review proceeding number to be the address associated with the appointed lead and backup counsels.
The undersigned is authorized to sign this Power of Attorney on behalf of the Petitioner.
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2002 Exhibit: Ex 2002 Invalidity Chart

Document IPR2020-00778, No. 2002-23 Exhibit - Ex 2002 Invalidity Chart (P.T.A.B. Jul. 21, 2020)
Patent No. 9,024,790 (“’790 Patent”) U.S. Patent No. 5,525,980 (“Jahier”) Exhibit C-14 U.S. Patent No. 5,525,980 (“Jahier”) qualifies as prior art to U.S. Patent No. 9,024,790 (“’790 Patent”) at least under pre-AIA 35 U.S.C. § 102(b) and anticipates, and alone or with other references, renders obvious one or more of claims 1, 4-8, 10-14, 16-24.
To the extent Jahier does not disclose one or more limitations of the claims, it would have been obvious to combine the teachings of Jahier with the knowledge of one of ordinary skill in the art and with one or more of the references below to render the claims at issue in the ’790 patent invalid.
The cited references listed in the following charts disclose or render obvious the respective limitations under those constructions agreed to by the parties and, where constructions are in dispute, under either party’s construction as set forth in the updated Joint Proposed Claim Construction Chart dated October 31, 2019 unless noted otherwise.
• U.S. Patent No. 7,545,366 (“Sugimoto”) • U.S. Patent No. 5,618,232 (“Martin”) • U.S. Patent No. 7,844,914 (“Andre”) • Japanese Patent Publication JP2000-214989 (“Amano”) • Quantum 16 Key QMatrixTM Keypanel Sensor IC (“QT60161”) • Quantum QProx QT160 / QT161 Manual (“QT160”) • U.S. Patent No. 6,696,985 (“Houston”) • U.S. Patent No. 5,760,715 (“Senk”) • Prior art references as set forth in Exhibit C-13 • Prior art references as described in the cover pleading to these contentions Asserted Claims Claim 1 1[pre] An apparatus comprising: Prior Art Disclosures Jahier, alone or in combination with other references identified in this chart or elsewhere in Respondents’ invalidity contentions, and further in light of the knowledge of a person of ordinary skill in the art, discloses the apparatus recited in claim 1.
Jahier discloses: “A method and apparatus for determining a valid selection of a capacitance tactile keyboard as a function of a selection state and validation state Neodron Ltd. Exhibit 2002
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2001 Exhibit: Ex 2001 Order re Procedural Schedule

Document IPR2020-00778, No. 2001-22 Exhibit - Ex 2001 Order re Procedural Schedule (P.T.A.B. Jul. 21, 2020)
File identification of expert witnesses, including their expertise and curriculum vitae Exchange list of claim terms to be construed Exchange of preliminary proposed claim constructions by the private parties Exchange of preliminary proposed claim constructions by the Staff Initial deadline for responses to contention interrogatories on issues for which the responding party bears the burden of proof and public interest Meet and confer to discuss and limit number of disputed claim terms Exchange of final proposed claim constructions by private parties and Staff Initial Markman briefs Rebuttal Markman briefs Submission of joint proposed claim construction chart Initial deadline for responses to contention interrogatories on issues for which the responding party does not bear the burden of proof File notice of prior art Markman hearing Proposed Dates No later than July 1, 2020 May 31, 2020, or ten calendar days after receipt of a party’s identification of persons most knowledgeable, whichever occurs later Wednesday, July 15, 2020 Thursday, July 16, 2020 Tuesday, July 28, 2020 Friday, July 31, 2020 Friday, July 31, 2020 Monday, August 10, 2020 Wednesday, August 12, 2020 Wednesday, August 19, 2020 Wednesday, September 2, 2020 Tuesday, September 8, 2020 Friday, September 11, 2020 Friday, September 11, 2020 Monday-Tuesday, September 14-15, 2020 Neodron Ltd. Exhibit 2001
File tentative list of witnesses a party will call to testify at the hearing, with an identification of each witness' relationship to the party Submission of updated joint proposed claim construction chart Cut-off date for supplements to contention interrogatories on issues for which the responding party bears the burden of proof and public interest Cut-off date for supplements to contention interrogatories on issues for which the responding party does not bear the burden of proof Fact discovery cut-off and completion Deadlines for motions to compel fact discovery Exchange of initial expert reports Exchange of rebuttal expert reports Expert discovery cut-off and completion Deadline for motions to compel expert discovery Deadline for filing motions for summary determination Exchange of exhibit lists among the parties Submit and serve direct exhibits, with physical exhibits available – Complainant and Respondents Submit and serve direct exhibits, with physical exhibits available – Staff Submit and serve rebuttal exhibits, with rebuttal physical exhibits available – Complainant and Respondents Thursday, September 17, 2020 Tuesday, September 22, 2020 Friday, October 2, 2020 Friday, October 16, 2020 Friday, October 23, 2020 Wednesday, October 30, 2020 Friday, November 6, 2020 Wednesday, November 25, 2020 Wednesday, December 16, 2020 Thursday, December 17, 2020 Thursday, December 17, 2020 Wednesday, January 6, 2021 Wednesday, January 13, 2021 Friday, January 15, 2021 Wednesday, January 20, 2021 Neodron Ltd. Exhibit 2001
Submit and serve rebuttal exhibits, with rebuttal physical exhibits available – Staff File pre-trial statements and briefs – Complainant and Respondents File pre-trial statements and briefs – Staff Deadline to file motions in limine File responses to motions in limine Pre-trial conference Hearing File initial post-trial briefs and final exhibit lists File reply post-trial briefs Initial Determination Friday, January 22, 2021 Monday, January 25, 2021 Wednesday, February 3, 2021 Monday, February 1, 2021 Monday, February 8, 2021 Tuesday, February 16, 2021 Tuesday, February 16, 2021 – Monday, February 22, 2021 Friday, March 12, 2021 Friday, March 26, 2021 Friday, June 18, 2021 Target date for completion of investigation Wednesday, October 20, 2021
I, Lisa R. Barton, hereby certify that the attached ORDER has been served via EDIS upon the Commission Investigative Attorney, Monica Bhattacharyya, Esq. and on the following parties as indicated, on April 20, 2020.
Lisa R. Barton, Secretary U.S. International Trade Commission 500 E Street, SW, Room 112 Washington, DC 20436 On Behalf of Complainant Neodron Ltd.: Matthew D. Aichele, Esq.
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2003 Exhibit: Ex 2003 Invalidity Chart

Document IPR2020-00778, No. 2003-24 Exhibit - Ex 2003 Invalidity Chart (P.T.A.B. Jul. 21, 2020)
Additional motivation arises from a desire to overcome known problems and determining intended touches using known techniques.
Additional motivation to do so arises from combining prior art elements according to known methods to yield predictable results to improve a similar device.
Doing so would have been within the abilities of one of skill in the art, would not have required undue effort, and would have led to expected results.
Practicing this limitation amounts to merely choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success.
Nor are Defendants asserting any claim construction positions through these charts, including whether the preamble is a limitation.
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2002 Exhibit: Ex 2002 Invalidity Chart

Document IPR2020-00778, No. 2002 Exhibit - Ex 2002 Invalidity Chart (P.T.A.B. Jul. 21, 2020)
Patent No. 9,024,790 (“’790 Patent”) U.S. Patent No. 5,525,980 (“Jahier”) Exhibit C-14 U.S. Patent No. 5,525,980 (“Jahier”) qualifies as prior art to U.S. Patent No. 9,024,790 (“’790 Patent”) at least under pre-AIA 35 U.S.C. § 102(b) and anticipates, and alone or with other references, renders obvious one or more of claims 1, 4-8, 10-14, 16-24.
To the extent Jahier does not disclose one or more limitations of the claims, it would have been obvious to combine the teachings of Jahier with the knowledge of one of ordinary skill in the art and with one or more of the references below to render the claims at issue in the ’790 patent invalid.
The cited references listed in the following charts disclose or render obvious the respective limitations under those constructions agreed to by the parties and, where constructions are in dispute, under either party’s construction as set forth in the updated Joint Proposed Claim Construction Chart dated October 31, 2019 unless noted otherwise.
• U.S. Patent No. 7,545,366 (“Sugimoto”) • U.S. Patent No. 5,618,232 (“Martin”) • U.S. Patent No. 7,844,914 (“Andre”) • Japanese Patent Publication JP2000-214989 (“Amano”) • Quantum 16 Key QMatrixTM Keypanel Sensor IC (“QT60161”) • Quantum QProx QT160 / QT161 Manual (“QT160”) • U.S. Patent No. 6,696,985 (“Houston”) • U.S. Patent No. 5,760,715 (“Senk”) • Prior art references as set forth in Exhibit C-13 • Prior art references as described in the cover pleading to these contentions Asserted Claims Claim 1 1[pre] An apparatus comprising: Prior Art Disclosures Jahier, alone or in combination with other references identified in this chart or elsewhere in Respondents’ invalidity contentions, and further in light of the knowledge of a person of ordinary skill in the art, discloses the apparatus recited in claim 1.
Jahier discloses: “A method and apparatus for determining a valid selection of a capacitance tactile keyboard as a function of a selection state and validation state Neodron Ltd. Exhibit 2002
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2001 Exhibit: Ex 2001 Order re Procedural Schedule

Document IPR2020-00778, No. 2001 Exhibit - Ex 2001 Order re Procedural Schedule (P.T.A.B. Jul. 21, 2020)

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2003 Exhibit: Ex 2003 Invalidity Chart

Document IPR2020-00778, No. 2003 Exhibit - Ex 2003 Invalidity Chart (P.T.A.B. Jul. 21, 2020)

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1003 Exhibit: Declaration of Tony Givargis Givargis Decl

Document IPR2020-01119, No. 1003-5 Exhibit - Declaration of Tony Givargis Givargis Decl (P.T.A.B. Jun. 17, 2020)

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