Case No. IPR2018-00386
`U.S. Patent No. 9,490,411
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`VIZIO, INC.,
`Petitioner
`
`v.
`
`NICHIA CORPORATION,
`Patent Owner
`_______________
`
`Case No. IPR2018-00386
`Patent 9,490,411
`_______________
`
`
`
`DECLARATION OF DRAGO N. GREGOV IN SUPPORT OF
`PETITIONER’S REPLY
`
`
`
`
`
`VIZIO Ex. 1040 Page 00001
`
`
`U.S. Patent No. 9,490,411
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`VIZIO, INC.,
`Petitioner
`
`v.
`
`NICHIA CORPORATION,
`Patent Owner
`_______________
`
`Case No. IPR2018-00386
`Patent 9,490,411
`_______________
`
`
`
`DECLARATION OF DRAGO N. GREGOV IN SUPPORT OF
`PETITIONER’S REPLY
`
`
`
`
`
`VIZIO Ex. 1040 Page 00001
`
`
`
`Case No. IPR2018-00386
`U.S. Patent No. 9,490,411
`
`
`
`
`I, Drago N. Gregov, make the following Declaration pursuant to 28 U.S.C.
`
`§ 1746:
`
`1.
`
`I am a Litigation Paralegal Specialist at the law firm of
`
`Ropes & Gray LLP.
`
`2.
`
`I provide this Declaration in connection with the above-identified
`
`Inter Partes Review proceeding requested at the United States Patent and
`
`Trademark Office by VIZIO, Inc. Unless otherwise stated, the facts stated in this
`
`Declaration are based on my personal knowledge.
`
`3.
`
`Exhibit 1018 hereto is a true and correct copy of excerpts from the
`
`File History of U.S. Patent Application No. 15/360,316 (U.S. Patent No.
`
`10,115,870) to Hirofumi Ichikawa, Masaki Hayashi, Shimpei Sasaoka and
`
`Tomohide Miki, which I downloaded on December 6, 2018 from the United States
`
`Patent and Trademark Office (“USPTO”) Patent Application Information Retrieval
`
`(“PAIR”) website and which is a record of the USPTO to which all parties have
`
`access. An exhibit label and page numbers on all pages have been added to the
`
`bottom of this document but no other alterations have been made.
`
`4.
`
`Exhibit 1020 hereto is a true and correct copy of United States Patent
`
`Publication No. 2005/0151149 by Chee Wai Chia, Peng Koay and Lye Yee Wong,
`
`which I downloaded on December 6, 2018 from the United States Patent and
`
`2
`
`VIZIO Ex. 1040 Page 00002
`
`
`
`Case No. IPR2018-00386
`U.S. Patent No. 9,490,411
`
`
`Trademark Office (“USPTO”) Patent Application Information Retrieval (“PAIR”)
`
`website and which is a record of the USPTO to which all parties have access. An
`
`exhibit label and page numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`5.
`
`Exhibit 1021 hereto is a true and correct copy of United States Patent
`
`Publication No. 2004/0126913 by Ban P. Loh, which I downloaded on December
`
`6, 2018 from the United States Patent and Trademark Office (“USPTO”) Patent
`
`Application Information Retrieval (“PAIR”) website and which is a record of the
`
`USPTO to which all parties have access. An exhibit label and page numbers on all
`
`pages have been added to the bottom of this document but no other alterations have
`
`been made.
`
`6.
`
`Exhibit 1022 hereto is a true and correct copy of United States Patent
`
`Publication No. 2005/0269587 by Ban P. Loh and Gerald H. Negley, which I
`
`downloaded on December 6, 2018 from the United States Patent and Trademark
`
`Office (“USPTO”) Patent Application Information Retrieval (“PAIR”) website and
`
`which is a record of the USPTO to which all parties have access. An exhibit label
`
`and page numbers on all pages have been added to the bottom of this document but
`
`no other alterations have been made.
`
`7.
`
`Exhibit 1024 hereto is a true and correct copy of United States Patent
`
`Publication No. 2004/0106234 by Joerg-Erich Sorg and Gertrud Kraeuter, which I
`
`3
`
`VIZIO Ex. 1040 Page 00003
`
`
`
`Case No. IPR2018-00386
`U.S. Patent No. 9,490,411
`
`
`downloaded on December 7, 2018 from the United States Patent and Trademark
`
`Office (“USPTO”) Patent Application Information Retrieval (“PAIR”) website and
`
`which is a record of the USPTO to which all parties have access. An exhibit label
`
`and page numbers on all pages have been added to the bottom of this document but
`
`no other alterations have been made.
`
`8.
`
`Exhibit 1025 hereto is a true and correct copy of Patent Owner’s
`
`Preliminary Response in IPR2017-02011, Paper 12, which I downloaded on
`
`December 5, 2018 from the Patent Trial and Appeal Board (“PTAB”) to which all
`
`parties have access. An exhibit label and page numbers on all pages have been
`
`added to the bottom of this document but no other alterations have been made.
`
`9.
`
`Exhibit 1026 hereto is a true and correct copy of an excerpt from
`
`“Webster’s Third New International Dictionary”, Merriam-Webster, Incorporated,
`
`2002. An exhibit label and page numbers on all pages have been added to the
`
`bottom of this document but no other alterations have been made.
`
`10. Exhibit 1027 hereto is a true and correct copy of an excerpt from the
`
`“Shorter Oxford English Dictionary”, Oxford University Press, Sixth Edition,
`
`2007. An exhibit label and page numbers on all pages have been added to the
`
`bottom of this document but no other alterations have been made.
`
`11. Exhibit 1029 hereto is a true and correct copy of U.S. Patent No.
`
`10,115,870 to Hirofumi Ichikawa, Masaki Hayashi, Shimpei Sasaoka and
`
`4
`
`VIZIO Ex. 1040 Page 00004
`
`
`
`Case No. IPR2018-00386
`U.S. Patent No. 9,490,411
`
`Tomohide Miki, which I downloaded on December 10, 2018 from the United
`
`States Patent and Trademark Office ("USPTO") Patent Application Information
`
`Retrieval ("PAIR") website and which is a record of the USPTO to which all
`
`parties have access. An exhibit label and page numbers on all pages have been
`
`added to the bottom of this document but no other alterations have been made.
`
`12. Exhibit 1039 hereto is a true and correct copy of an excerpt from the
`
`"IEEE Standard Glossary of Computer Hardware Terminology", IEEE Std 610.10-
`
`1994, October 12, 1995. An exhibit label and page numbers on all pages have
`
`been added to the bottom of this document but no other alterations have been
`
`made.
`
`13.
`
`I have been warned that willful false statements and the like are
`
`punishable by fine or imprisonment, or both. I make this declaration of my own
`
`personal knowledge, and all statements are true. If called to testify as to the
`
`matters stated herein, I could and would testify competently.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed this 11th day of December, 2018, at East Palo Alto, California.
`
`o ~
`
`ai~L
`
`5
`
`VIZIO Ex. 1040 Page 00005
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`
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