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`Case IPR2016-01622
`Patent 6,850,414
`Attorney Docket No. 160831-002USIPR
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`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`KINGSTON TECHNOLOGY COMPANY, INC.,
`
`Petitioner
`
`v.
`
`POLARIS INNOVATIONS LTD.,
`
`Patent Owner
`____________
`
`Case IPR2016-01622
`
`Patent 6,850,414 B2
`Priority July 2, 2001
`Issued February 1, 2005
`Title: ELECTRONIC PRINTED CIRCUIT BOARD HAVING A PLURALITY
`OF IDENTICALLY DESIGNED, HOUSING-ENCAPSULATED
`SEMICONDUCTOR MEMORIES
`____________
`
`
`PATENT OWNER’S REPLY
`TO PETITIONER’S OPPOSITION
`TO MOTION TO AMEND
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`
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`TABLE OF CONTENTS
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`Page
`THE BOARD HAS ALREADY DECLINED TO TRY CLAIM 4 ISSUES. .. 1
`
`I.
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`II. THE BOARD HAS ALREADY REJECTED THE PREMISE THAT
`A MOTION TO AMEND REOPENS ALREADY DECIDED
`QUESTIONS. .................................................................................................... 3
`
`III. PETITIONER’S NEW ARGUMENTS ARE UNTIMELY AND WRONG.... 9
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` i
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`STATUTES
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`TABLE OF AUTHORITIES
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`Page(s)
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`35 U.S.C. § 316(d)(2)................................................................................................. 5
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`35 U.S.C. § 316(d)(3)................................................................................................. 5
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`35 U.S.C. § 318(c) ..................................................................................................... 5
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`REGULATIONS
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`37 C.F.R. § 42.121(a)(2) ............................................................................................ 5
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`37 C.F.R. § 42.121(b) ................................................................................................ 5
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`ADMINISTRATIVE DECISIONS
`
`Amerigen Pharms. Ltd. v. Shire LLC, IPR2015-02009,
`Paper 8 (PTAB Apr. 18, 2016) ............................................................................. 6
`
`Amerigen Pharms. Ltd. v. Shire LLC, IPR2015-02009,
`Paper 36 (PTAB Jan. 10, 2017) ............................................................................ 7
`
`Amerigen Pharms. Ltd. v. Shire LLC, IPR2015-02009,
`Paper 38 (PTAB Mar. 31, 2017) .............................................................. 1, 6, 7, 8
`
`Idle Free Systems v. Berstrom, Inc., IPR2012-00027,
`Paper 26 (PTAB June 11, 2013) ........................................................................... 7
`
`Kingston Tech. Co., Inc. v. Polaris Innovations Ltd., IPR2016-01623,
`Paper 7 (PTAB Feb. 15, 2017) ............................................................................. 2
`
`Kingston Tech. Co., Inc. v. Polaris Innovations Ltd., IPR2016-01623,
`Paper 16 (PTAB Apr. 6, 2017) ............................................................................. 2
`
`Kingston Tech. Co., Inc. v. Polaris Innovations Ltd., IPR2017-00974,
`Paper 8 (PTAB Aug. 14, 2017) ............................................................................ 2
`
`
`
` ii
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`
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`EXHIBIT LIST
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`Exhibit 2001
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`Exhibit 2002
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`Exhibit 2003
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`Exhibit 2004
`
`Cara Garretson. “More DRAM vendors involved in Justice
`Department probe.” IDG News Service July 21, 2002.
`Computer World, Inc. November 21, 2016.
`“Error Correction Code in SoC FPGA-Based Memory
`Systems.” Altera Corporation April 2012.
`“133 MHz PC SDRAM 64-Bit Non-ECC/Parity 144 Pin
`UNBUFFERED SO-DIMM SPECIFICATION.” Intel, Revision
`1.0C. August 2000
`“PC SDRAM Serial Presence Detect (SPD) Specification.”
`Intel, Revision 1.2B. November 1999.
`Exhibit 2005 Declaration of Nathan Nobu Lowenstein in support of Motion
`for Admission Pro Hac Vice
`Institution Decision, Amerigen Pharms. Ltd. v. Shire LLC,
`IPR2015-02009, Paper 8 (PTAB Apr. 18, 2016)
`Patent Owner’s Motion To Amend, Amerigen Pharms. Ltd. v.
`Shire LLC, IPR2015-02009, Paper 14 (PTAB Jul. 18, 2016)
`Petitioner’s Opposition To Motion To Amend, Amerigen
`Pharms. Ltd. v. Shire LLC, IPR2015-02009, Paper 17 (PTAB
`Oct. 18, 2016)
`Patent Owner Reply To Petitioner’s Opposition, Amerigen
`Pharms. Ltd. v. Shire LLC, IPR2015-02009, Paper 21 (PTAB
`Nov. 17, 2016)
`Petitioner’s Request For Oral Argument, Amerigen Pharms.
`Ltd. v. Shire LLC, IPR2015-02009, Paper 27 (PTAB Dec. 9,
`2017)
`Final Written Decision, Amerigen Pharms. Ltd. v. Shire LLC,
`IPR2015-02009, Paper 38 (PTAB Mar. 31, 2017)
`Exhibit 2012 Deposition Transcript Of Vivek Subramanian (Apr. 19, 2017)
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`Exhibit 2006
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`Exhibit 2007
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`Exhibit 2008
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`Exhibit 2009
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`Exhibit 2010
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`Exhibit 2011
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`Exhibit 2013
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`Exhibit 1 To Deposition Transcript Of Vivek Subramanian
`(Apr. 19, 2017)
`
` iii
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`
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`Petitioner’s Opposition to Patent Owner’s Motion does not merely refuse to
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`accept that the Board has already rejected its positions on the merits at least three
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`times, in three separate orders across two IPRs. It also ignores a more fundamental
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`problem. The Opposition relies from beginning to end on the false premise that the
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`filing of a motion to amend reopens the Board’s non-institution determinations
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`constraining the scope of the trial. But Petitioner once again ignores past rulings
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`by the Board, where the Board already considered and rejected this premise—and
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`held that a motion to amend triggers no requirement to prove, let alone re-prove,
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`patentability of subject matter already recited in original non-amended claims—
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`“especially” claims challenged and denied institution. Amerigen Pharms. Ltd. v.
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`Shire LLC, IPR2015-02009, Paper 38 at 6 (PTAB Mar. 31, 2017) [Ex. 2011].
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`The Board has thus already thrice rejected Petitioner’s merits positions as to
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`the subject matter of the substitute claim. Petitioner asks the Board to revisit these
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`questions for at least a fourth time, improperly leveraging its past failures to once
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`again re-sculpt its arguments. The Board should reject Petitioner’s latest “‘nothing
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`to lose’ ploy . . . to restate its disagreement with the Board’s Institution Decision in
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`an improper new brief,” id., Paper 21 [Ex. 2010] at 12, and grant the Motion.
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`I. THE BOARD HAS ALREADY DECLINED TO TRY CLAIM 4 ISSUES.
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`The Petition in this case sought review of Claims 1-8 of the ’414 Patent
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`relying on two references: Simpson and the Intel Specification. Paper 1 at 9. The
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` 1
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`Board denied institution on Claims 2-4 because Petitioner failed to show that any
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`combination of asserted references was reasonably likely to render the claims
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`obvious. Paper 7 at 14-18, 22. Dissatisfied with this outcome, Petitioner sought
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`rehearing as to Claim 4. Paper 11. After careful consideration and explanation,
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`the Board reaffirmed on the merits. Paper 16.
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`Petitioner then filed a second Petition attacking Claim 4. Kingston Tech.
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`Co., Inc. v. Polaris Innovations Ltd., IPR2017-00974, Paper 1. It raised the same
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`references as the first Petition (Simpson and the Intel Specification1) plus three
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`others. Id. at 9-10. The Board again denied institution, explaining that the second
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`Petition’s arguments and references, including its new references, still failed to
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`raise a probability of unpatentability, and indeed were “‘substantially the same” as
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`those in the first petition.” Id., Paper 8 at 13 (PTAB Aug. 14, 2017).2
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`1 Petitioner called the Intel Specification a different name this time, and said
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`it was a new reference, but it was the same reference. Id. Paper 6 at 15-17 (POPR).
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`2 Petitioner’s August 18 Opposition to the Motion to Amend contumaciously
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`ignores the Board’s denial of institution in -00974. Instead, Petitioner continues to
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`insist that the Motion should be denied, for, inter alia, “the reasons set forth . . . in
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`Petitioner’s IPR2017-00974 Petition.” Opposition at 17. By that logic, the Motion
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`should be granted, for, inter alia, the reasons that the -00974 Petition was denied.
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` 2
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`Patent Owner’s Motion to Amend in the present case is thus supported by at
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`least three decisions of the Board. It seeks to cancel instituted Claims 1 and 5-8
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`and add one substitute claim 9. Claim 9 simply adds to the limitations of instituted
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`Claim 8 the limitation of Claim 4—the exact same limitation that the Board has
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`found, three times, not disclosed by Petitioner’s references and arguments:
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`9. The printed circuit board according to claim 1, wherein: said
`printed circuit board has a width of 5.25 inches and has a height of 1
`to 1.2 inches perpendicular to said contact strip.
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`Patent Owner’s Motion to Amend raises no new patentability issues and adds
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`no newly drafted limitations. The Board’s prior decisions as to this subject matter,
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`including the Board’s determinations in the Institution Decision and Decision on
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`Request for Rehearing, cannot be revisited by Petitioner yet again now. And even
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`if they could, Petitioner’s Opposition ultimately raises, yet again, materially the
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`same arguments based on materially the same references that it made before.
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`II. THE BOARD HAS ALREADY REJECTED THE PREMISE THAT A
`MOTION TO AMEND REOPENS ALREADY DECIDED QUESTIONS.
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`Patent Owner’s Motion adds a substitute claim, Claim 9, that has a limitation
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`the Board has already repeatedly found was not in the references raised by
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`Petitioner. Patent Owner is entitled to rely on those prior rulings for purposes of
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`its Motion to Amend. Any other result would frustrate the statutory framework,
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`create complicated procedural problems, and contradict the Board’s past rulings.
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` 3
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`Petitioner argues that the Motion reopens already-decided issues in this case.
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`That cannot be true, unless it is impossible for a motion to amend to rely upon the
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`Board’s institution decision. This Motion is specifically drafted to not raise any
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`new issues. Its proposed claim addresses only a limitation in a claim already
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`issued, already challenged, already denied review twice, and already denied
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`reconsideration. If this Motion opens up new issues for decision, all new claims
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`necessarily do so. Thus, Petitioner’s theory has to be that any motion to amend
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`must open up the patent owner to attack based on anything already decided against
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`Petitioner. But no statute or rule suggests that the act of filing a motion to amend
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`deletes—or even affects—the Board’s prior decision on Institution, grants
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`Petitioner a do-over on its failures to meet its burden that the Board has already
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`decided, or reopens any issues already adjudicated. Such a conclusion would
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`ignore, not only the statutory assignment of the burden to Petitioner, and
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`Petitioner’s prior failure to comply with the rules, but also the Board’s existing
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`decisions in the case. It would render the preliminary proceeding in the IPR a
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`nullity. What is more, it would create a perverse disincentive for patent owners to
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`eschew their right to seek to amend their patent—or perhaps even create a perverse
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`incentive for them to inject new issues in their amendments and avoid old ones.
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`The proposed amendment clearly distinguishes the substitute claim from
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`every ground of invalidity. New grounds of unpatentability could not be raised
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` 4
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`against this subject matter without also, in effect, being raised against non-
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`instituted claims.3 For this reason, the Motion cannot be denied on any basis that
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`would substantively contradict the Board’s rulings in the Institution Decision and
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`the limits that it set on the scope of trial in this case. Doing so would effectively
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`adopt an untimely new challenge to the patentability of non-instituted Claim 4.4
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`Nor do policy considerations (Opposition at 1-2) support Petitioner’s theory.
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`IPRs can never examine claims but only adjudicate them—and IPRs confine all
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`new claims to be within the scope of existing, uncanceled claims of the patent. 35
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`U.S.C. §§ 316(d)(3), 318(c); 37 C.F.R. §§ 42.121(a)(2), (b). There is therefore not
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`even a theoretical danger of granting Patent Owner any additional, undeserved
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`scope of patent protection in this case. Petitioner’s own failure, in three tries, to
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`mount a challenge to this patented subject matter before the Board does not prevent
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`any other person, not in privity or otherwise barred, from challenging the new or
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`old claims in the future. Nor is Petitioner barred from continuing to do so in court.
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`Unsurprisingly, Petitioner cites no Board decision supporting its startling
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`3 That would also contradict the AIA’s structure, which contemplates using
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`motions to amend as tools to eliminate disputes in IPR. See 35 U.S.C. § 316(d)(2).
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`4 Thus, the Motion may be denied only on bases (e.g., procedure or burden
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`issues) that do not conflict with the Board’s reason for partially denying institution.
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` 5
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`insistence that the Motion allows it to circumvent the shortcomings of its Petitions.
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`Yet Petitioner ignores the only decision on point: Amerigen, in Case No. IPR2015-
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`02009. In that decision, the Board has already rejected Petitioner’s premise.
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`In Amerigen, as in this case, the Board denied institution on some, but not
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`all, challenged claims. Id., Paper 8 [Ex. 2006] at 1. The patent owner, as in this
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`case, filed no response, but only filed a motion to amend, seeking to cancel all
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`instituted claims and add a substitute claim that confined its limitations only to
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`those of unchallenged or non-instituted claims. Id., Paper 14 [Ex. 2007] at 1.
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`In opposition, the Amerigen petitioner, like Petitioner here, argued that
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`because the patent owner had moved to add a substitute claim, the patent owner
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`now had to prove patentability of the substitute claim over all known prior art,
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`irrespective of the art and arguments raised in the petition, and irrespective of
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`whether the claim was limited to subject matter on which institution had already
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`been denied. Id., Paper 17 [Ex. 2008] at 3-5. And, like Petitioner here, the
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`Amerigen petitioner (i) raised a multiplicity of other references and unpatentability
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`arguments that had been allegedly raised against the non-instituted claims in other
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`cases but not in the petition, and (ii) raised numerous policy arguments against
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`adding the substitute claim to the patent without sufficient scrutiny. Id. at 5-8.
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`The Board rejected the petitioner’s contentions, cancelled the hearing, and
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`granted the motion to amend. Id., Paper 38 [Ex. 2011] at 7; see also id., Paper 27
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` 6
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`[Ex. 2010] at 3-4; id., Paper 36 at 1. The Board declined the petitioner’s invitation
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`to reconsider whether its initial institution decision was correct based on the new
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`merits arguments raised in the opposition to the motion to amend, and its invitation
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`to consider whether or not the patent owner candidly addressed the new references.
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`Instead, the Board “agree[d] with Patent Owner that ‘there is no requirement for
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`[the patent owner] to prove, after the Institution Decision, that original non-
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`amended claims are patentable over all potential prior art, especially non-instituted
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`claims.’” Ex. 2011 at 6 (alteration marks omitted). The Board noted that the
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`substitute claim’s limitations were not “‘newly drafted’” like the claims in Idle
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`Free Systems v. Berstrom, Inc., IPR2012-00027, Paper 26 (PTAB June 11, 2013),
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`but, instead, included only limitations of non-instituted or non-challenged claims,
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`Ex. 2011 at 4-5. Accordingly, the Board found that the patent owner’s filing of a
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`motion to amend did not impose a “burden of showing the substitute claim’s
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`patentable distinction over not only the prior art asserted in the petition, but also all
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`prior art of record in the initial patent prosecution, reissue proceeding, prior
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`litigations and other prior art known to patent owner.” Ex. 2011 at 6.
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`The Board’s decision in Amerigen was correct. And the same result is
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`correct here. Here, as in Amerigen, the Motion to Amend does not raise any new
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`“newly drafted” claim limitations, or any patentability issues except those already
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`resolved as to non-instituted claims. It merely adds a limitation already considered
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` 7
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`and analyzed by the Board. Here, as in Amerigen, Petitioner’s demand that Patent
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`Owner show substitute Claim 9’s patentability over not only the prior art in the
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`Petition, Opposition at 3, but all prior art known or of record in other proceedings,
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`id. at 6, is inapposite. As in Amerigen, the Motion to Amend should be granted.
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`Amerigen’s facts are, unsurprisingly, not absolutely identical to this case.
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`The substitute claim in Amerigen was the same as an instituted claim except that it
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`deleted from its multiple dependencies the dependencies on instituted claims, Ex.
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`2006 at 2, whereas by comparison substitute Claim 9 in this case is the same as an
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`instituted claim except that it adds a limitation found in a non-instituted claim. It is
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`a distinction without a difference. The fact that the new claim in Amerigen was
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`multiply dependent does not distinguish it in any way from the claim here. As the
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`Board pointed out in Amerigen, a “‘multiple dependent claim is considered in the
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`same manner as a plurality of single dependent claims.” Ex. 2011 at 4 (emphasis
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`added) (quoting MPEP 608.01(n)). No rule distinguishes multiple dependent
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`claims from other claims for this purpose. And the Board’s ultimate reasoning in
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`granting the motion to amend in Amerigen rested, not on the fact that the canceled
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`and substitute claims happened to be multiply dependent, but on the determination
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`that the patent owner’s motion to amend triggered no requirement for the patent
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`owner to revisit the patentability of the subject matter of non-amended claims,
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`“especially non-instituted claims.” Id. at 6. The same principle governs here.
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` 8
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`III.
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`PETITIONER’S NEW ARGUMENTS ARE UNTIMELY AND WRONG.
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`Petitioner submits new arguments and exhibits with its Opposition. But
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`these arguments are procedurally improper, grossly untimely, and unpersuasive.
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`Claim 4 recites “the printed circuit board according to Claim 1, wherein:
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`said printed circuit board has a height of 1 to 1.2 inches perpendicular to said
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`contact strip.” Ex. 1001 [’414 Pat.] Cl. 4. Petitioner’s Petitions already challenged
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`the height limitation of Claim 4. Both Petitions failed to show unpatentability of
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`this limitation. Petitioner now attempts to use its Opposition as an untimely
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`backdoor attempt to again re-litigate that limitation. Because both Patent Owner
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`and the Board have already refuted Petitioner’s references and arguments in the
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`Patent Owner Preliminary Responses and Institution Decisions in the two IPRs,
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`Patent Owner cannot be required to re-litigate these issues with Petitioner again.
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`For example, Simpson is the primary reference that Petitioner relied upon in
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`both Petitions. The Board already ruled three times that Petitioner has failed to
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`show unpatentability based on Simpson in combination with any other reference.
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`In its Opposition, Petitioner relies again primarily on Simpson. Opposition 4-17.
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`These new arguments and evidence are no more timely here, with the Opposition,
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`than they would have been with Petitioner’s Request for Rehearing, Papers 11, 16.
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`Nor is Petitioner’s “new” expert testimony (Exs. 1016, 1022) timely. It
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`purports to addresses patentability issues applicable to non-instituted Claim 4, so it
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` 9
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`can hardly be timely now. It is not responsive to any new evidence, for none was
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`submitted with the Motion. And much of it (Ex. 2016) is the same testimony
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`Petitioner already filed in -00974, in which the Board already denied institution.
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`The IPR statute and rules simply do not allow this “try, try again” gamesmanship.
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`But even if Petitioner’s premise that the Motion re-opened the doors the
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`Institution Decision closed were correct, and even if its “new” evidence and
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`arguments were timely, there are still further reasons—in addition to those that
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`Patent Owner already argued in two POPRs and the Board already found in two
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`institution denials—why Petitioner’s references fail to disclose the Claims. For
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`example, Claim 1, from which substitute Claim 9 depends, requires the “housing of
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`each one of said semiconductor memories . . . being individually connected to said
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`printed circuit board.” Ex. 1001 at Cl. 1. Simpson’s alleged memory chips are
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`connected to sockets, that are in turn connected to its printed circuit board. E.g.,
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`Pet. at 20; Ex. 1002 [Simpson] at Fig. 1, 13:18-28. Petitioner’s expert admitted in
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`cross-examination that, where a memory chip is not directly connected to a printed
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`circuit board but is instead connected through an intermediary with receptacles, the
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`housing of the chip “is not individually connected to the printed circuit board” as
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`that phrase is used in the Patent. Ex. 2012 at, e.g., 234:6-237:22. In connection
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`with the drawing reproduced below (Ex. 2013, marked as deposition Exhibit 1), on
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`which the upper housing is a memory chip, connected to receptacles on the lower
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` 10
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`
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`housing, which is a
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`second memory chip
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`and, in turn, is connected
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`to the printed circuit
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`board, Dr. Subramanian
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`testified that the housing of the upper memory chip pictured is not “individually
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`connected to the printed circuit board,” as that phrase is used in the Patent. Id.
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`The drawing, however, is no different in this respect from Simpson, whose “chip”
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`is connected to the PCB through a socket with receptacles. Ex. 1002 at 13:18-28.
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`Nor was there motivation to utilize or modify Simpson’s socketed invention
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`as claimed. Unlike the Patent (Ex. 1001 [’414 Pat.] at, e.g., Fig. 1; 2:37-42; 2:51-
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`53; 4:7-8), Simpson teaches no reason or benefit for the claimed layout of sockets
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`on the PCB. Further, Simpson is from an ancient epoch of computer DRAM
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`relative to the Patent’s priority date, and the intervening time rendered Simpson’s
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`problem, solution and rationale obsolete. Simpson’s raison d’être was that, at the
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`time, “a 16Mb module may cost as much as a whole computer,” Ex. 1002 at 11:28-
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`31, so Simpson disclosed an upgradable memory module with sockets that could
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`be filled in later to eliminate the need to replace the module. Id. at 11:25-28; 11:3-
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`6; 8:22-24; 11:8-10. These needs were not present by the time of the 2001 Patent.
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`Nor does Bechtolsheim—also already rejected by this Board in the -00974
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` 11
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`
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`IPR—help Petitioner. Bechtolsheim is not concerned with orientation of DRAM
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`memory chips on a DRAM PCB; instead, like the prior art the Patent improved, it
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`places all chips in the same direction without comment. Ex. 1004 [Bechtolsheim]
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`at 3:32-39; Figs. 1a, 2a. Nor does Bechtolsheim even discuss trying to reduce
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`height. On the contrary, where the Patent’s preferred embodiments teach one
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`horizontal row of chips, Bechtolsheim teaches three, which is necessarily taller.
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`Id. Figs. 1a, 1b; 4:61-5:6. Bechtolsheim does not even hint that one memory chip
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`(the error correction chip) be vertical and the rest horizontal, as claimed.
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`The Opposition suggests that, because Bechtolsheim shows a vertical driver
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`chip 15 (not a memory chip), artisans would put an error correction memory chip
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`in its place, move driver 15 under one of the horizontally oriented memory devices,
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`or simply add a vertically oriented error correction chip—but offers no reason why,
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`and ignores the Patent’s disclosure showing why that is not a simple design choice,
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`in combination with Simpson or not. Compare Opposition at 20-22 with POPR 12.
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`The Opposition, at 7-8, 15, also raises Kiehl (Exs. 1020, 1021), and attacks
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`Patent Owner for lack of candor in not disclosing and “showing patentability over
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`it.” But Petitioner fails to notice that Kiehl is not prior art to the Patent. Ex. 1001.
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`The Motion was not required to raise further patentability arguments such as
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`these, and this Reply is not the time or place to fully develop them. Petitioner’s
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`arguments are untimely. As a matter of law and discretion, they should be rejected.
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` 12
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`Date: September 18, 2017
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`Respectfully submitted,
` / Kenneth J. Weatherwax /
`Kenneth J. Weatherwax, Reg. No. 54,528
`Lowenstein & Weatherwax LLP
`
`
`
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`
`
`
`Case IPR2016-01622
`Patent 6,850,414
`Attorney Docket No. 160831-002USIPR
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the following documents were served
`by electronic service, by agreement between the parties, on the date signed below:
`
`
`PATENT OWNER’S REPLY
`TO PETITIONER’S OPPOSITION
`TO MOTION TO AMEND
`
`Exhibits 2006-2013
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`The names and address of the parties being served are as follows:
`
`IPR37307-0007IP1@fr.com (David Hoffman)
`IPR@sjclawpc.com (Martha Hopkins)
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`
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`Respectfully submitted,
`
` / Shawn Chi /
`
`Date: September 18, 2017
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`