`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`JUNIPER NETWORKS INC.,
`RUCKUS WIRELESS, INC.,
`BROCADE COMMUNICATION SYSTEMS, INC.,
`and NETGEAR, INC.,
`
`Petitioners,
`
`v.
`
`CHRIMAR SYSTEMS, INC.,
`
`Patent Owner.
`
`
`
`Case IPR2016-013971
`
`U.S. Patent No. 9,019,838 B2
`
`
`
`
`
`
`
`PATENT OWNER’S REQUEST FOR AUTHORIZATION TO FILE
`SERVED SUPPLEMENTAL EVIDENCE IN RESPONSE
`TO MOTION EXCLUDE
`
`
`
`
`1 Ruckus Wireless, Inc., Brocade Communication Systems, Inc. and Netgear, Inc.
`
`(“Ruckus et al.”) filed a petition in (now terminated) IPR2017-00720, and Ruckus
`
`et al. has been joined to the instant proceeding.
`
`
`
`
`
`Case No.: IPR2016-01397
`Patent No.: 9,019,838
`
`
`
`Atty. Dkt. No.: CHRMC0111IPR1
`
`Patent Owner, Chrimar Systems, Inc. (“Chrimar”), submits this request
`
`seeking authorization to file its supplemental evidence in response to Petitioner’s
`
`Motion to Exclude Evidence.
`
`The Board has addressed a similar issue in IPR2013-00116, Paper 29, page
`
`3. “Patent Owner asked whether supplemental evidence provided in response to an
`
`evidentiary objected may be filed, as well as served. The Board instructed Patent
`
`Owner not to file such evidence. In the event Petitioner files a motion to exclude
`
`evidence, Patent Owner may seek authorization to file an opposition thereto and to
`
`file its supplemental evidence.”
`
`On August 2, 2017, Petitioners filed a Motion to Exclude Evidence. In
`
`addition to filing an opposition to the Motion to Exclude Evidence, Patent Owner
`
`is seeking authorization to file exhibits listed below that were served on the
`
`Petitioner on April 25, 2017.
`
`Description
`Ex. No.
`2052 U.S. Pat. No. 7,061,142 B1
`
`2053
`
`Supplemental Declaration of Dr. Vijay
`Madisetti
`2054 Declaration of Steven Johnson
`
`
`
`
`
`
`
`Date
`
`Identifier
`the ‘142 patent
`
`
`
`
`
`
`
`
`
`
`
`1
`
`
`
`Case No.: IPR2016-01397
`Patent No.: 9,019,838
`
`
`
`Atty. Dkt. No.: CHRMC0111IPR1
`
`For the foregoing reasons, Patent Owner respectfully requests that the Board
`
`authorize Patent Owner to file the supplemental exhibits.
`
`
`
`
`
`
`
`
`
`Dated: August 11, 2017
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
` /Frank A. Angileri/
`Frank A. Angileri (Reg. No. 36,733)
`Thomas A. Lewry (Reg. No. 30,770)
`Marc Lorelli (Reg. No. 43,759)
`Christopher C. Smith (Reg. No. 59,669)
`Brooks Kushman P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`(248) 358-4400
`
`
`Richard W. Hoffmann (Reg. No. 33,711)
`Reising Ethington PC
`755 West Big Beaver Rd., Suite 1850
`Troy, Michigan 48084
`248.786.0163
`
`Attorneys for Patent Owner
`
`2
`
`
`
`Case No.: IPR2016-01397
`Patent No.: 9,019,838
`
`
`
`Atty. Dkt. No.: CHRMC0111IPR1
`
`Certificate of Service
`
`On August 11, 2017, a copy of this PATENT OWNER’S REQUEST FOR
`AUTHORIZATION TO FILE SERVED SUPPLEMENTAL EVIDENCE IN
`RESPONSE TO MOTION EXCLUDE has been served on Petitioner’s counsel
`via electronic mail at the email addresses shown below:
`
`
`Lead Counsel & Back-up Counsel for Juniper
`Jonathan Kagan, pro hac vice pending
`Nima Hefazi Reg. No. 63,658
`nhefazi@irell.com
`jkagan@irell.com
`Postal and Hand-Delivery Address:
`Postal and Hand-Delivery Address:
`IRELL & MANELLA, LLP
`IRELL & MANELLA, LLP
`840 Newport Center Drive, Suite 400
`1800 Avenue of the Stars, Suite 900
`Newport Beach, CA 92660
`Los Angeles, CA 90067
`Juniper-ChrimarIPR@irell.com
`Juniper-ChrimarIPR@irell.com
`
`Lead Counsel & Back up Counsel for Ruckus Wireless, Inc., Brocade
`Communication Systems, Inc., & Netgear, Inc.
`Joseph Powers (Reg. No. 47,006)
`Christopher Tyson (Reg. No. 63,850)
`Duane Morris LLP
`Duane Morris LLP
`30 South 17th Street
`505 9th St. NW, Ste 1000
`Philadelphia PA 19103-4196
`Washington DC 20004
`JAPowers@duanemorris.com
`CJTyson@duanemorris.com
`
`
`Matthew S. Yungwirth
`DUANE MORRIS LLP
`1075 Peachtree Street, NE
`Suite 2000
`Atlanta, Georgia 30309
`msyungwirth@duanemorris.com
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
` /Frank A. Angileri/
`Frank A. Angileri (Reg. No. 36,733)
`Thomas A. Lewry (Reg. No. 30,770)
`Marc Lorelli (Reg. No. 43,759)
`Christopher C. Smith (Reg. No. 59,669)
`
`3
`
`
`
`Case No.: IPR2016-01397
`Patent No.: 9,019,838
`
`
`
`Atty. Dkt. No.: CHRMC0111IPR1
`
`Brooks Kushman P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`(248) 358-4400
`
`Richard W. Hoffmann (Reg. No. 33,711)
`Reising Ethington PC
`755 West Big Beaver Rd., Suite 1850
`Troy, Michigan 48084
`248.786.0163
`
`Attorneys for Patent Owner
`
`
`
`
`
`
`4
`
`
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