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` Paper ____
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` Date filed: January 8, 2019
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`Filed on behalf of: Nichia Corp.
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`By: Martin M. Zoltick, Lead Counsel
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`Robert P. Parker, Back-up Counsel
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`Derek F. Dahlgren, Back-up Counsel
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`Michael H. Jones, Back-up Counsel
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`Mark T. Rawls, Back-up Counsel
`ROTHWELL, FIGG, ERNST & MANBECK, P.C.
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
`Phone: 202-783-6040
`Facsimile: 202-783-6031
`Emails: mzoltick@rfem.com
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` rparker@rfem.com
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` ddahlgren@rfem.com
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` mjones@rfem.com
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` mrawls@rfem.com
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`VIZIO, INC.,
`Petitioner,
`
`v.
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`NICHIA CORPORATION,
`Patent Owner.
`_______________
`
`Case IPR2018-00437
`Patent 9,537,071
`_______________
`
`REPLY TO PETITIONER’S OPPOSITION TO PATENT OWNER’S
`CONTINGENT MOTION TO AMEND CLAIMS
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`
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`Case IPR2018-00437
`Patent 9,537,071
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`TABLE OF CONTENTS
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`TABLE OF AUTHORITIES .................................................................................... ii
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`I.
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`The Proposed Claims Have § 112 Written Description Support .................... 1
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`II.
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`The Amendments Do Not Broaden the Claims ............................................... 6
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`III. The Proposed Claims Satisfy § 103 ................................................................. 8
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`A. Hsu lacks the claimed resin part and grounds based on Hsu are
`therefore deficient. ................................................................................. 9
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`B.
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`Glenn is not appropriate art to cite against light emitting devices. .....12
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`Patent 9,537,071
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`TABLE OF AUTHORITIES
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`
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`Cases
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`Aqua Prods., Inc. v. Matal,
`872 F.3d 1290 (Fed. Cir. 2017) (en banc) .............................................................. 8
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`Chicago Bd. Options Exch., Inc. v. Int’l Sec. Exch., LLC,
`677 F.3d 1361 (Fed. Cir. 2012) ............................................................................10
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`Digene Corp. v. Third Wave Techs., Inc.,
`323 F. App’x 902 (Fed. Cir. 2009) .......................................................................11
`
`In re Magnum Oil Tools Int’l, Ltd.,
`829 F.3d 1364 (Fed. Cir. 2016) .............................................................................. 9
`
`Sirona Dental Sys. GMBH v. Institut Straumann AG,
`892 F.3d 1349 (Fed. Cir. 2018) .............................................................................. 8
`
`Streck, Inc. v. Research & Diagnostic Sys.,
`665 F.3d 1269 (Fed. Cir. 2012) .............................................................................. 1
`
`Trading Techs. Int'l, Inc. v. Open E Cry, LLC,
`728 F.3d 1309 (Fed. Cir. 2013) .............................................................................. 1
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`Statutes
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`35 U.S.C. § 103 ....................................................................................................9, 12
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`35 U.S.C. § 112 ......................................................................................................1, 3
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`37 C.F.R. § 42.24(b)(3) .............................................................................................. 8
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`37 C.F.R. § 42.6(a)(3) ................................................................................................ 8
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`ii
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`Case IPR2018-00437
`Patent 9,537,071
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`Petitioner’s opposition fails to provide any basis that would warrant denial
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`of Patent Owner’s contingent motion to amend.
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`I.
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`The Proposed Claims Have § 112 Written Description Support
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`Claims 27, 28: Petitioner’s argument is that the patent’s fifth embodiment
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`requires devices having two leads and an additional, non-lead third metal structure.
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`Op. at 2. That is wrong. Ex. 2030, §VI(A), (B).
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`To support its argument, Petitioner has to rely on extrinsic evidence (lab
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`notebooks and draft patent drawings) not part of the specification and thus not part
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`of the § 112 analysis. Op. at 3-4. It is black letter law that the § 112 inquiry is an
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`“objective inquiry into the four corners of the specification from the perspective of
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`a person of ordinary skill in the art.” Streck, Inc. v. Research & Diagnostic Sys.,
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`665 F.3d 1269, 1285 (Fed. Cir. 2012); Trading Techs. Int'l, Inc. v. Open E Cry,
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`LLC, 728 F.3d 1309, 1319 (Fed. Cir. 2013) (contrasting the use of extrinsic
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`evidence in claim construction versus § 112 which looks at the “specification
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`itself”). Using extrinsic evidence to argue the existence of a third non-lead metal
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`structure not shown or described is therefore improper. Id.
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`Looking at Fig. 12 of the patent, even as the Petitioner has annotated it, it is
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`clear that the shape and configuration of the leads at the interior of the resin
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`package is not expressly illustrated. Even so, Petitioner asserts that Fig. 12 “shows
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`the metal of the resin package is divided into three separate structures.” Op. at 2. It
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`doesn’t. Rather, Fig. 12 illustrates the division of the metal leads on the outer side
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`surface (each of the positive and negative leads is divided into three portions), but
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`the figure does not show any (internal) division of the metal into three separate
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`structures. Ex. 2030, ¶¶11-12. This is because the underlying arrangement of the
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`leads is obscured by the resin. Id.
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`It was therefore unsurprising that, when pressed on cross examination, Dr.
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`Shanfield admitted he had not opined on the shape of the electrode structure under
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`the resin in Fig. 12, and that he was not comfortable doing so during his
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`deposition. Ex. 2033 at 46:21-49:7. Rather than consider the specification to figure
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`this out, Dr. Shanfield looked to an inventor’s notebook and drafts of figures made
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`more than five months before the priority application was filed and not included in
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`the patent. This is improper.
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`Instead, Petitioner should have looked (as a POSA would have) to the
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`description of the fifth embodiment found in the specification. Ex. 2030, ¶13. In
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`introducing the fifth embodiment, the patent states that a “[d]escription of some
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`configurations employing the substantially same configuration as the light emitting
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`device according to the first embodiment will be omitted where necessary.” Ex.
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`2023, ¶98; Ex. 2022, ¶98. In the fifth embodiment, and unlike the first through
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`third embodiments, the ʼ071 patent omits a lead frame illustration that would
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`illustrate the specific shape of the leads in the interior of the resin package. Cf.
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`Figs. 3, 7, and 10 (embodiments 1-3); see also Ex. 2033, 25:16-26:18, 28:4-6.
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`Thus, a POSA would consider the description of the first embodiment when
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`understanding the scope of the fifth embodiment, as instructed in the patent. Ex.
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`2030, ¶14. The first embodiment, as all agree, shows a resin package consisting of
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`a resin part and two metal leads. Op. at 6; Ex. 2030, ¶15; Ex. 2033, 49:11-16.
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`Petitioner’s own arguments further show the deficiencies of its § 112
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`challenge. For instance, Petitioner acknowledges that the fifth embodiment
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`describes at least two alternative designs – the leads being “separated respectively,
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`or jointed.” Op. at 4-5. But Petitioner appears to misunderstand what the patent
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`teaches, deriding this support for claims 27 and 28 as “ambiguous.” Op. at 4; Ex.
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`2030, ¶16. There is no ambiguity, and this disclosure identified by Petitioner
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`supports Nichia. For instance, the disclosure emphasizes that it is the leads that are
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`separated into six portions at the outer side surface. It does not state that two leads
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`and a third non-lead metal structure (e.g. a die-bonding pad, or heat sink) are
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`separated at the outer side surface (as Petitioner contends), and a POSA would not
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`have construed the specification in that way. Id. ¶17.
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`Moreover, the disclosure describes a version of the fifth embodiment where
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`the leads are separated at the “outer side surface 420b,” but also “jointed” at the
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`package interior, as explained by Dr. Schubert:
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`In other words, the patent says that the leads are “separated into
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`six” at the outer side surface. Additionally, in the next sentence,
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`the patent explains that the leads 422 (i.e. the “pair of positive and
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`negative leads,” …) may be respectively separated or jointed; that
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`is, although they are separated into six (as shown in FIG. 12) at the
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`outer surface, their internal configuration can be that of separate or
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`jointed anodes and cathodes.
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`Ex. 2030, ¶16. A POSA would have appreciated the patent as describing a two-
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`lead device, where each of the two leads separates into three parts at the outer
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`surface, as set forth in the claims. Id. ¶¶16-18. Contrary to Petitioner, that
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`arrangement would be operable (having two leads poses no danger of short
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`circuiting), and moreover, could improve adhesion and manufacturability. Id. ¶¶18-
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`20. The patent includes other, operable embodiments in which two leads are
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`separated into more than two at the outer surfaces. See, e.g., FIG. 1 (two leads,
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`separated into four at the outer surface 20b); 2030, ¶ 19 (“The ’071 patent makes
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`clear that the number of places that the leads are exposed from the package does
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`not dictate the number of leads within the package.”). Dr. Schubert has explained
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`that this position does not change even if Petitioner’s understanding of Fig. 12 is
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`correct that it depicts an “X” shape as shown in external drawings. Id. ¶20. That is
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`because the patent’s specification still describes configurations of the fifth
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`embodiment where the leads are internally jointed.
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`Petitioner’s arguments regarding elements [27.D]-[27.H] are based on its
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`flawed interpretation of Fig. 12 and likewise fail. Ex. 2030, ¶21. For the same
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`reasons as above, Petitioner’s arguments concerning claim 28 are wrong. Id. ¶22.
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`Claim 31: Petitioner’s argument improperly incorporates arguments by
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`reference and should be given no weight. Op. at 8; see n.1 below. Setting this
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`aside, its challenge fails on the merits. Fig. 11 clearly shows an upper surface and
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`bottom surface having an etched concave portion. Ex. 2030, §VI(C).
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`Etched concave portions identified in
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`yellow (upper surface) and red
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`(bottom surface). See Ex. 2030, ¶28.
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`Because the patent does not redefine these terms, and as Petitioner has not
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`advanced its own construction, the plain and ordinary meaning of the claim
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`language should control. Petitioner’s incorporated argument rests on a strained
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`interpretation of what constitutes the upper and bottom surfaces of the leads.
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`Specifically, Petitioner’s argument is that Nichia has re-defined the plain and
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`ordinary meaning of these terms based on its argument that a different prior art
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`reference did not teach a different claim element for a different, though related
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`patent. IPR2018-00386, Reply to Patent Owner’s Response at 10-11 (citing Ex.
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`1025, IPR2017-02011, Pap. 12 at 7, 46-47); Ex. 2030, ¶24. That goes too far. The
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`claim at issue referred to a concave portion of an inner side wall surface of a pre-
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`singulated lead frame, and Nichia pointed out that the prior art reference relied on
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`did not have this feature. There was no re-definition of terms. Moreover, even
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`crediting Petitioner’s flawed argument, Petitioner does not explain why a concave
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`portion of an inner side wall surface of a lead frame (pre-singulation) cannot result
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`in a device (post-singulation) with a lead having an upper surface with a concave
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`portion. FIG. 11 shows just that. Ex. 2030, ¶¶23-26.
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`Petitioner has also improperly incorporated the argument that creating a
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`concavity by etching must necessarily create a new surface. Nothing in the ʼ071
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`patent supports Petitioner’s argument that because a surface was formed by
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`etching, it cannot be considered an upper surface as claimed, especially where that
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`surface is the top of the lead. Ex. 2030, ¶¶27-29.
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`II.
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`The Amendments Do Not Broaden the Claims
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`Claim 27: Petitioner argues that the change from metal plate to metal lead
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`broadens the claim. Not so. Ex. 2030, §VII(A). Petitioner appears to assert that the
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`term lead is broader than plate because a lead does not have to be flat. Op.at 9.
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`Petitioner’s position is inconsistent with the patent’s disclosures in at least two
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`ways. First, Petitioner’s argument rests on a highly elided quote, arguing that “‘a
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`metal plate’ is a ‘flat plate shape . . . which [may have] differences in level or
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`concavity and convexity” and that metal lead is not so limited. Op. at 9. But the
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`full sentence from the specification makes clear that metal plates in the ʼ071 patent
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`are not limited to flat metal plates: “[a]lthough a metal plate of a flat plate shape
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`can be used for a lead frame, a metal plate in which differences in level or
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`concavity and convexity are provided can be used.” Ex. 2030, ¶¶31-32. Tellingly,
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`Petitioner has identified no lead in the ʼ071 patent that would be broader than the
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`metal plates described at 9:21-24. Second, Petitioner ignores that the claim has
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`been narrowed to “leads,” thus excluding plates used for purposes other than
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`conducting electricity to the LED chip, e.g. heat sinks or mounting plates. Ex.
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`2030, ¶¶33-34.
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`Additionally, even if “metal leads” is somehow interpreted to be broader
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`than “metal plates” (it should not be), Petitioner has not argued that “metal leads”
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`is also broader than the original language “a metal part”. Ex. 2030, ¶35.
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`Claim 28: Petitioner argues that the use of “portions of an outer lateral
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`surface of the resin part” in element [28.F] broadens the original use of “the resin
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`part.” This is wrong. Ex. 2030, §VII(B). The original claim recited “wherein the
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`resin part is located at left and right sides of a portion of the metal part.” It was
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`amended to recite “portions of an outer lateral surface of the resin part” are located
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`at left and right sides. This is not broader. Ex. 2030, ¶¶37-39. Under any logical
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`reading, the resin part being located at both the left and right sides of a portion of
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`the metal part, as originally required, must necessarily refer to portions of the resin
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`part. Ex. 2030, ¶38. It would be impossible for the entire resin part to be located at
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`both a left side and a right side of a metal part. Id.; Ex. 2033, 60:11-14. That
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`appears to be Petitioner’s implicit interpretation. Additionally, the claim has been
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`expressly narrowed – not only does the resin part now need to have portions to the
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`left and right of an exposed surface of the first metal plate (as before), it now needs
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`to have portions above the plate as well. Ex. 2030, ¶39.
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`III.
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`The Proposed Claims Satisfy § 103
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`Petitioner requested additional pages from the Board. The request was
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`denied. Paper 29. But rather than accept the Board’s ruling and focus its
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`challenges, Petitioner placed its voluminous arguments in an expert declaration
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`instead of the Opposition. Petitioner’s 14 new grounds of obviousness, including a
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`5-way obviousness combination, are not adequately explained in the Opposition.1
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`Petitioner here cannot reasonably be said to have met its burden. See Aqua Prods.,
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`Inc. v. Matal, 872 F.3d 1290, 1324-25 (Fed. Cir. 2017) (en banc); Sirona Dental
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`Sys. GMBH v. Institut Straumann AG, 892 F.3d 1349, 1357 (Fed. Cir. 2018).
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`At a minimum, Petitioner needed to identify the Graham factors and
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`articulate a motivation to combine the numerous references and why a POSA
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`would have had a reasonable expectation of success in doing so. In re Magnum Oil
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`1 This violates the prohibition against incorporation by reference and page limit
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`rules. See 37 C.F.R. § 42.6(a)(3), 42.24(b)(3), Pap. 29 (denying additional pages).
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`No weight should be given to the incorporated arguments.
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`Tools Int’l, Ltd., 829 F.3d 1364, 1381 (Fed. Cir. 2016). It did not. The opposition is
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`silent regarding any reasonable expectation of success for the various proposed
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`combinations aside from conclusorily noting some combinations would be
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`“straightforward.” E.g., Op. at 10-12, 23-24. It has a threadbare discussion of an
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`alleged motivation to combine the numerous references that boils down to a few
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`conclusory statements. E.g., Op. at 12 (“A POSA would have been motivated . . .
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`to use a thermosetting resin . . . to provide better heat resistance, light resistance
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`and adhesion . . . .”), 16 (“[I]t would have been obvious to combine Lin’s similar
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`disclosures.”). Further, it is difficult to decipher from the opposition the precise
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`nature of the grounds being asserted, which appear to be introduced implicitly in
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`section headings and described together without detailed explanation. E.g., Op. at
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`21. These exemplary deficiencies show why Petitioner failed to meet its burden.
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`A. Hsu lacks the claimed resin part and grounds based on Hsu are
`therefore deficient.
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`Petitioner’s § 103 challenges also fail on the merits. Each ground is based on
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`the incorrect position that both the reflecting ring 30 and the encapsulant 50 in Hsu
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`correspond to the claimed “resin part.” E.g., Op. at 10. This is wrong, and
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`inconsistent with the ʼ071 patent, in which a “sealing member” (such as Hsu’s
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`encapsulant 50) is disclosed and claimed as being distinct from the “resin part.”
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`Ex. 2030, ¶¶44-47. That is, because the encapsulant 50 is not part of the claimed
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`resin part, Hsu does not meet the requirements for the claimed resin part. Id.
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`First, the claims differentiate between a resin part of the resin package and a
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`sealing member (or encapsulant). The independent claims require a resin package
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`having a resin part and two metal leads or plates. Dependent claims further limit
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`the device to include a sealing member that contains two or more kinds of
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`phosphors (e.g. original claims 2 and 19, substitute claim 31). Thus, under the
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`doctrine of claim differentiation, the sealing member is something different than
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`the claimed resin part. Chicago Bd. Options Exch., Inc. v. Int’l Sec. Exch., LLC,
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`677 F.3d 1361, 1369 (Fed. Cir. 2012) (referring to the “general presumption that
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`different [claim] terms have different meanings”).
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`Second, the patent describes the resin part and the sealing member 30 (or
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`encapsulant) as being different, and as having competing purposes. Ex. 1001, 6:49-
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`65, 10:9-33, 18:3-33, FIG. 2. The patent consistently groups leads 22 and resin
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`part 25 under the designation resin package 20, and separately depicts the sealing
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`member 30 (or encapsulant) as not being part of the resin package 20. Ex. 2030,
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`¶46. This distinction between the resin part of the resin package and the sealing
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`member of the device also serves a practical purpose. The resin part is reflective,
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`while the sealing member 30 (and Hsu’s encapsulant 50) allows light to escape.
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`Ex. 2030, ¶¶46-47; ʼ071 Patent, 8:59-9:20, 10:9-32. Hsu itself has the same
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`distinction. Ring 30 is “an opaque white plastic material,” while encapsulant 50 is
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`a clear epoxy that allows light to escape (otherwise the device would be
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`inoperable). Ex. 1030, 4:16-27, FIG. 10; Ex. 2033, 68:16-70:16.
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`Because the encapsulant 50 of Hsu is not a component of the resin part, Hsu
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`fails to disclose or suggest a portion of the resin part being coplanar with a portion
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`of the metal leads at four outer lateral surfaces as required by claims 27 (element
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`[27.E]) and 28 (elements [28.D] and [28.H]). See Ex. 1030, FIG. 12.
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`Further, claim 27 requires that the resin package consist of the resin part and
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`two metal leads. In Hsu, the identified resin part of the resin package includes
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`reflecting ring 30 (molded in a first molding step) and encapsulant 50 (molded in a
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`second molding step to produce base 51 and dome-like protrusion 52). The resin
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`package therefore includes multiple, separately molded resins and does not consist
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`of a (single) resin part as claimed. Ex. 2030, ¶48; Ex. 1030, FIG. 12. See Digene
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`Corp. v. Third Wave Techs., Inc., 323 F. App’x 902, 909 (Fed. Cir. 2009) (holding
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`that “the clause ‘consists of’ generally requires that the word ‘an’ following it be
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`limited to one and only one”). The other references do not cure this deficiency, and
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`thus Petitioner’s challenge to claim 27 also fails for this additional reason. Id.; see
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`also Ex. 2030, ¶¶49-53 (grounds with Lin are inappropriate because Lin teaches an
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`opposing method of creating a resin part that is incompatible with Hsu and/or
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`Urasaki); Ex. 1010, ¶ [0027], FIG. 4g; Ex. 1031, ¶¶0004-0007, FIGS. 1, 5-6.
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`B. Glenn is not appropriate art to cite against light emitting devices.
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`In a district court action with respect to the parent application of the ʼ071
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`patent, Glenn was rejected as a viable reference for purposes of § 103. Ex. 2024 at
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`44 (FF157, finding Glenn in combination with LED references would not have
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`predictably yielded a viable LED device). The district court went so far as to state
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`that a POSA would have “dismissed” it because it related to integrated circuits
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`(“IC”) which have fundamentally different purposes. Ex. 2024 at 44-45 (FF158-
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`FF161). The district court even rejected the premise that Glenn would be combined
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`with the very same reference – Urasaki (Ex. 1031) – used by Petitioner in each of
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`the grounds with Glenn. Ex. 2024 at 44-48 (FF171, referring to Urasaki by its
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`assignee, “Hitachi”). The Federal Circuit affirmed. Ex. 2036 at 12-13. With this
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`backdrop, Petitioner’s decision to say nothing of these differences, not discuss
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`expectation of success, or even give a meaningful discussion of motivation is
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`particularly glaring. There is no summary of Glenn, or acknowledgement that it
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`has previously been deemed incompatible with Urasaki.
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`Further, because of the fundamentally different purposes and functions—
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`LEDs emitting light and ICs being isolated from light—a POSA would not have
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`relied on Glenn to modify Hsu or any other LED reference. Ex. 2030, ¶¶54-57.
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`Thus, Petitioner’s challenge to claim 31 fails for this additional reason, particularly
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`as Glenn is the only reference identified for elements [31.B], [31.C], and [31.D].
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`Respectfully submitted,
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`By:
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`Date: January 8, 2019
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`
`/ Martin M. Zoltick /
`Martin M. Zoltick, Reg. No. 35,745
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`ROTHWELL, FIGG, ERNST &
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` MANBECK, P.C.
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
`Phone: 202-783-6040
`Facsimile: 202-783-6031
`
`Counsel for Patent Owner
`Nichia Corporation
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`CERTIFICATE OF SERVICE
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`I hereby certify that on this 8th day of January, 2019, a true and correct copy
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`of the foregoing REPLY TO PETITIONER’S OPPOSITION TO PATENT
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`OWNER’S CONTINGENT MOTION TO AMEND CLAIMS was served, via
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`electronic mail, upon the following counsel of record for Petitioner Vizio, Inc.:
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`Gabrielle E. Higgins
`James L. Davis, Jr.
`Christopher M. Bonny
`James F. Mack
`ROPES & GRAY LLP
`1900 University Avenue, 6th Floor
`East Palo Alto, CA 94303-2284
`Phone: 650-617-4000 | Facsimile: 650-566-4090
`Emails: Gabrielle.Higgins@ropesgray.com
`James.L.Davis@ropesgray.com
`Christopher.Bonny@ropesgray.com
`James.Mack@ropesgray.com
`VIZIO2NichiaIPRs@ropesgray.com
`
`Scott McKeown
`ROPES & GRAY LLP
`2099 Pennsylvania Avenue, N.W.
`Washington, DC 20006-6807
`Phone: 202-508-4740 | Facsimile: 617-235-9492
`Email: Scott.McKeown@ropesgray.com
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`/ Erik van Leeuwen /
`Erik van Leeuwen
`Litigation Operations Coordinator
`Rothwell, Figg, Ernst & Manbeck, P.C.
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