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No. 10 Unopposed MOTION to Stay Case Pending ITC Determination by Apple, Inc

Document NEODRON LTD., v. Apple, Inc., 6:20-cv-00116, No. 10 (W.D.Tex. Mar. 30, 2020)
Motion to Stay Pending ITC Investigation
Defendant Apple Inc. (“Apple”) respectfully moves this Court pursuant to 28 U.S.C. § 1659 and its inherent powers to control its docket for a stay of all proceedings in the above- captioned case until the determination of the United States International Trade Commission (“ITC”) in a parallel proceeding becomes final.
Pursuant to 28 U.S.C. § 1659, district court patent claims that involve the same issues as a parallel ITC proceeding are subject to a mandatory stay.
In a civil action involving parties that are also parties to a proceeding before the United States International Trade Commission under section 337 of the Tariff Act of 1930, at the request of a party to the civil action that is also a respondent in the proceeding before the Commission, the district court shall stay, until the determination of the Commission becomes final, proceedings in the civil action with respect to any claim that involves the same issues involved in the proceeding before the Commission, but only if such request is made within – (1) 30 days after the party is named as a respondent in the proceeding before the Commission, or (2) 30 days after the district court action is filed, whichever is later.
A stay issued under this statute remains in effect during any appeals and “until the Commission proceedings are no longer subject to judicial review.” In re Princo Corp., 478 F.3d 1345, 1355 (Fed. Cir. 2007).
For the foregoing reasons, Apple respectfully requests that the Court enter the attached proposed order and stay all proceedings in the Texas action until the determination of the ITC action becomes final, including any appeals and until the Commission proceedings are no longer subject to judicial review.
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No. 12 NOTICE OF DISMISSAL WITH PREJUDICE by NEODRON LTD., (Mirzaie, Reza) (Entered: 01/04/2021)

Document NEODRON LTD., v. LG Electronics, Inc., 6:20-cv-00118, No. 12 (W.D.Tex. Jan. 4, 2021)
Under Federal Rule of Civil Procedure 41(a)(1)(A)(i), Plaintiff Neodron Ltd. hereby dismisses the Complaint against LG Electronics Inc. with prejudice.
Each party shall bear its own costs, expenses and attorneys’ fees.
Dated: January 4, 2021
Respectfully Submitted,
12424 Wilshire Blvd.
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No. 5 COMPLAINT ( Filing fee $ 400 receipt number 0542-13216455)

Document NEODRON LTD., v. Apple, Inc., 6:20-cv-00116, No. 5 (W.D.Tex. Feb. 14, 2020)
Complaint
Beyond just providing greater usability to smartphones, tablets and notebooks, touchscreens now fill our lives in public and private spaces, from our homes and cars to the restaurants and stores we visit.
By making, using, offering for sale, selling and/or importing into the United States the Accused Products, Defendant has injured Neodron and is liable for infringement of the ’425 Patent pursuant to 35 U.S.C. § 271.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the Apple iPhone 11, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–14 of the ’092 Patent.
By making, using, offering for sale, selling and/or importing into the United States the Accused Products, Defendant has injured Neodron and is liable for infringement of the ’092 Patent pursuant to 35 U.S.C. § 271.
By making, using, offering for sale, selling and/or importing into the United States the Accused Products, Defendant has injured Neodron and is liable for infringement of the ’251 Patent pursuant to 35 U.S.C. § 271.
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8 Institution Decision: Trial Instituted Document

Document IPR2020-01000, No. 8 Institution Decision - Trial Instituted Document (P.T.A.B. Dec. 15, 2020)
“Not all such factors may be present in every case, and one or more of these or other factors may predominate in a particular case.” Id. Petitioner argues that a person having ordinary skill in the art at the time of the invention would have been a person having at least a bachelor’s degree in electrical engineering, computer engineering, computer science, or a related field, and at least two years of experience in the research, design, development, and/or testing of human-machine interfaces such as touch sensors and the firmware or system software that govern said interfaces, or the equivalent, with additional education substituting for experience and vice versa.
For purposes of this Decision, we adopt the level of ordinary skill in the art that Petitioner proffers, except that we delete the qualifiers “at least” to eliminate vagueness as to the amount of education and practical experience.
In deciding whether to institute inter partes review, we consider the guidance in the Consolidated Trial Practice Guide, which sets forth the following: Parallel Petitions Challenging the Same Patent.
Petitioner further argues that a person having ordinary skill in the art “would have understood that the disclosed control circuit [in Philipp] executes logic in accordance with firmware or software stored on internal memory to effectuate the functions discussed.” Id. at 36– 37 (citing Ex. 1003 ¶¶ 97–103).
Accordingly, at this stage of the proceeding, we are persuaded the information presented in the Petition establishes there is a reasonable likelihood that Petitioner would prevail with respect to claims 2–20 based on the combination of Philipp and QT60161.
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9 Order: Scheduled Order

Document IPR2020-01000, No. 9 Order - Scheduled Order (P.T.A.B. Dec. 15, 2020)
For example, reasonable expenses and attorneys’ fees incurred by any party may be levied on a person who impedes, delays, or frustrates the fair examination of a witness.
The parties are further directed to the Board’s Guidance on Motions to Amend in view of Aqua Products (https://go.usa.gov/xU6YV), and Lectrosonics, Inc. v. Zaxcom, Inc., IPR2018-01129, Paper 15 (PTAB Feb. 25, 2019) (precedential).
The Board defines a LEAP practitioner as a patent agent or attorney having three (3) or fewer substantive oral arguments in any federal tribunal,
Patent 8,749,251 B2 including PTAB, and seven (7) or fewer years of experience as a licensed attorney or agent.4 The Board encourages parties to participate in its LEAP program.
In exchange, the Board will grant up to fifteen minutes of additional argument time to that party, depending on the length of the proceeding and the PTAB’s hearing schedule.
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9 Order: Schedule Order

Document IPR2020-00998, No. 9 Order - Schedule Order (P.T.A.B. Dec. 15, 2020)
For example, reasonable expenses and attorneys’ fees incurred by any party may be levied on a person who impedes, delays, or frustrates the fair examination of a witness.
The parties are further directed to the Board’s Guidance on Motions to Amend in view of Aqua Products (https://go.usa.gov/xU6YV), and Lectrosonics, Inc. v. Zaxcom, Inc., IPR2018-01129, Paper 15 (PTAB Feb. 25, 2019) (precedential).
The Board defines a LEAP practitioner as a patent agent or attorney having three (3) or fewer substantive oral arguments in any federal tribunal,
Patent 8,749,251 B2 including PTAB, and seven (7) or fewer years of experience as a licensed attorney or agent.4 The Board encourages parties to participate in its LEAP program.
In exchange, the Board will grant up to fifteen minutes of additional argument time to that party, depending on the length of the proceeding and the PTAB’s hearing schedule.
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8 Institution Decision: Trial Instituted Document

Document IPR2020-00998, No. 8 Institution Decision - Trial Instituted Document (P.T.A.B. Dec. 15, 2020)
“Not all such factors may be present in every case, and one or more of these or other factors may predominate in a particular case.” Id. Petitioner argues that a person having ordinary skill in the art at the time of the invention would have been a person having at least a bachelor’s degree in electrical engineering, computer engineering, computer science, or a related field, and at least two years of experience in the research, design, development, and/or testing of human-machine interfaces such as touch sensors and the firmware or system software that govern said interfaces, or the equivalent, with additional education substituting for experience and vice versa.
For purposes of this Decision, we adopt the level of ordinary skill in the art that Petitioner proffers, except that we delete the qualifiers “at least” to eliminate vagueness as to the amount of education and practical experience.
In deciding whether to institute inter partes review, we consider the guidance in the Consolidated Trial Practice Guide, which sets forth the following: Parallel Petitions Challenging the Same Patent.
The present circumstance is consistent with the exception referenced in the Consolidated Trial Practice Guide because there is a dispute about the effective filing date of the ’251 patent, which may require arguments to be made under multiple prior art references.
According to Koziuk, “reducing power consumption in portable computers has gained a great deal of attention in the technical community as a result of a set of conflicting user requirements and technological constraints.” Ex. 1013, 1:60–63.
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No. 12 MOTION to Stay Case Pending ITC Determination by Sony Corporation

Document NEODRON LTD., v. Sony Corporation, 6:20-cv-00122, No. 12 (W.D.Tex. Apr. 1, 2020)
Motion to Stay Pending ITC Investigation
On March 16, 2020, the ITC instituted an investigation based on Neodron’s complaint, naming Sony as a respondent to the proceeding.
Pursuant to 28 U.S.C. § 1659, District Court claims that involve the same issues as a parallel ITC proceeding are subject to a mandatory stay.
A stay issued under this statute must remain in effect during any appeal(s) and must continue “until the Commission proceedings are no longer subject to judicial review.” In re Princo Corp., 478 F.3d 1345, 1355 (Fed. Cir. 2007).
For the foregoing reasons, Sony respectfully requests that the Court enter the attached proposed order staying all proceedings in this action until the determination of the 337-TA-1193 Investigation becomes final, including any appeals and until the ITC proceedings are no longer subject to judicial review.
Doing so does not affect service on Sony, does not satisfy Federal Rule of Civil Procedure 4(h)(2) & (f)(1), does not invoke the procedures of the Hague Convention on Convention on the Service Abroad of Judicial and Extrajudicial Documents in Civil or Commercial Matters, and does not comply with this Court’s order appointing the process server “to forward to the Central Authority in the applicable country, any and all documents to be served in this case.” (Dkt. No. 9).
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No. 1 COMPLAINT ( Filing fee $ 400 receipt number 0542-13216444), filed by NEODRON LTD.,. (Attachments: ...

Document NEODRON LTD., v. LG Electronics, Inc., 6:20-cv-00118, No. 1 (W.D.Tex. Feb. 14, 2020)
Complaint
Beyond just providing greater usability to smartphones, tablets and notebooks, touchscreens now fill our lives in public and private spaces, from our homes and cars to the restaurants and stores we visit.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the LG Gram 14T990, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–40 of the ’425 Patent.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the LG Gram 14T990, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–14 of the ’092 Patent.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the LG V40 and LG Gram 14T990, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–20 of the ’251 Patent.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the LG V40, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–23 of the ’472 Patent.
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No. 1 COMPLAINT ( Filing fee $ 400 receipt number 0542-13216412), filed by NEODRON LTD.,. (Attachments: ...

Document NEODRON LTD., v. AMAZON.COM. INC., 6:20-cv-00115, No. 1 (W.D.Tex. Feb. 14, 2020)
Complaint
Beyond just providing greater usability to smartphones, tablets and notebooks, touchscreens now fill our lives in public and private spaces, from our homes and cars to the restaurants and stores we visit.
On information and belief, Defendant Amazon.com, Inc. is a corporation organized under the laws of the State of Delaware, with its principal place of business at 410 Terry Avenue North, Seattle, Washington 98109.
On information and belief, Defendant offers for sale, sells, and/or imports certain products (“Accused Products”), such as the Acer Spin 3 and ASUS VivoBook Flip 14 TP401MA, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–40 of the ’425 Patent.
On information and belief, Defendant offers for sale, sells, and/or imports certain products (“Accused Products”), such as the Acer Spin 3 and ASUS VivoBook Flip 14 TP401MA, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–14 of the ’092 Patent.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the Amazon Fire HD 10 (9th Gen), Acer Spin 3, and ASUS VivoBook Flip 14 TP401MA, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–20 of the ’251 Patent.
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No. 1 COMPLAINT against MOTOROLA MOBILITY LLC., ( Filing fee $ 400, receipt number 0971-14183917

Document NEODRON LTD. v. MOTOROLA MOBILITY LLC.,, 3:20-cv-01179, No. 1 (N.D.Cal. Feb. 14, 2020)
Complaint
Beyond just providing greater usability to smartphones, tablets and notebooks, touchscreens now fill our lives in public and private spaces, from our homes and cars to the restaurants and stores we visit.
On information and belief, Defendant Motorola Mobility LLC is a Delaware limited liability company with its principal office located at 222 W. Merchandise Mart Plaza, Suite 1800, Chicago, Illinois 60654.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the Motorola Moto G6, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–14 of the ’092 Patent.
By making, using, offering for sale, selling and/or importing into the United States the Accused Products, Defendant has injured Neodron and is liable for infringement of the ’092 Patent pursuant to 35 U.S.C. § 271.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the Motorola Moto G6, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–20 of the ’251 Patent.
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No. 1 COMPLAINT against MOTOROLA MOBILITY LLC., ( Filing fee $ 400, receipt number 0971-14183917

Document NEODRON LTD. v. MOTOROLA MOBILITY LLC.,, 5:20-cv-01179, No. 1 (N.D.Cal. Feb. 14, 2020)
Complaint
Beyond just providing greater usability to smartphones, tablets and notebooks, touchscreens now fill our lives in public and private spaces, from our homes and cars to the restaurants and stores we visit.
On information and belief, Defendant Motorola Mobility LLC is a Delaware limited liability company with its principal office located at 222 W. Merchandise Mart Plaza, Suite 1800, Chicago, Illinois 60654.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the Motorola Moto G6, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–14 of the ’092 Patent.
By making, using, offering for sale, selling and/or importing into the United States the Accused Products, Defendant has injured Neodron and is liable for infringement of the ’092 Patent pursuant to 35 U.S.C. § 271.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the Motorola Moto G6, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–20 of the ’251 Patent.
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No. 1 COMPLAINT ( Filing fee $ 400 receipt number 0542-13216461), filed by NEODRON LTD.,. (Attachments: ...

Document NEODRON LTD., v. Microsoft Corporation, 6:20-cv-00119, No. 1 (W.D.Tex. Feb. 14, 2020)
Complaint
Beyond just providing greater usability to smartphones, tablets and notebooks, touchscreens now fill our lives in public and private spaces, from our homes and cars to the restaurants and stores we visit.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the Microsoft Surface Book 2 13.5, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–40 of the ’425 Patent.
By making, using, offering for sale, selling and/or importing into the United States the Accused Products, Defendant has injured Neodron and is liable for infringement of the ’425 Patent pursuant to 35 U.S.C. § 271.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the Microsoft Surface Book 2 13.5, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–14 of the ’092 Patent.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the Microsoft Surface Book 2 13.5, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–20 of the ’251 Patent.
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No. 1 COMPLAINT ( Filing fee $ 400 receipt number 0542-13216438), filed by NEODRON LTD.,. (Attachments: ...

Document NEODRON LTD., v. ASUSTeK Computer Inc., 6:20-cv-00117, No. 1 (W.D.Tex. Feb. 14, 2020)
Complaint
Beyond just providing greater usability to smartphones, tablets and notebooks, touchscreens now fill our lives in public and private spaces, from our homes and cars to the restaurants and stores we visit.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the ASUS VivoBook Flip 14 TP401MA, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–40 of the ’425 Patent.
By making, using, offering for sale, selling and/or importing into the United States the Accused Products, Defendant has injured Neodron and are liable for infringement of the ’425 Patent pursuant to 35 U.S.C. § 271.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the ASUS VivoBook Flip 14 TP401MA, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–14 of the ’092 Patent.
On information and belief, Defendant makes, uses, offers for sale, sells, and/or imports certain products (“Accused Products”), such as the ASUS VivoBook Flip 14 TP401MA, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–20 of the ’251 Patent.
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No. 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 (W.D.Tex. Feb. 14, 2020)
Complaint
Beyond just providing greater usability to smartphones, tablets and notebooks, touchscreens now fill our lives in public and private spaces, from our homes and cars to the restaurants and stores we visit.
By making, using, offering for sale, selling and/or importing into the United States the Accused Products, Defendants have injured Neodron and are liable for infringement of the ’425 Patent pursuant to 35 U.S.C. § 271.
By making, using, offering for sale, selling and/or importing into the United States the Accused Products, Defendants have injured Neodron and are liable for infringement of the ’092 Patent pursuant to 35 U.S.C. § 271.
By making, using, offering for sale, selling and/or importing into the United States the Accused Products, Defendants have injured Neodron and are liable for infringement of the ’251 Patent pursuant to 35 U.S.C. § 271.
On information and belief, Defendants make, use, offer for sale, sell, and/or import certain products (“Accused Products”), such as the Samsung Galaxy S10e, that directly infringe, literally and/or under the doctrine of equivalents, claims 1–23 of the ’472 Patent.
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