IPR2020-00260
`Patent 8,269,523
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`Paper No. 48
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`FLEX LOGIX TECHNOLOGIES INC,
`
`Petitioner,
`
`v.
`
`VENKAT KONDA,
`
`Patent Owner.
`
`____________
`
`Case IPR2020-00260
`
`Patent 8,269,523 B2
`
`_________
`
`
`
`
`PATENT OWNER VENKAT KONDA’S CURRENT LIST OF EXHIBITS
`
`
`
`
`
`
`
`
`Patent 8,269,523
`
`
`
`
`Paper No. 48
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`FLEX LOGIX TECHNOLOGIES INC,
`
`Petitioner,
`
`v.
`
`VENKAT KONDA,
`
`Patent Owner.
`
`____________
`
`Case IPR2020-00260
`
`Patent 8,269,523 B2
`
`_________
`
`
`
`
`PATENT OWNER VENKAT KONDA’S CURRENT LIST OF EXHIBITS
`
`
`
`
`
`
`
`
`
`IPR2020-00260
`Patent 8,269,523
`
`
`
`
`Exhibit No.
`
`Description
`
`Ex. 2001 Venkat Konda Declaration
`
`Paper No. 48
`
`
`Previously
`Submitted
`
` X
`
`Ex. 2002
`
`Ex. 2003
`
`Ex. 2004
`
`Ex. 2005
`
`Ex. 2006
`
`Ex. 2007
`
`2011 paper at VLSI Symposium of circuits, by
`Co-founders of Petitioner Flex Logix
`Technologies Inc. plagiarizing the 2D-layouts
`disclosed in the 8,269,523 patent
`2009 DARPA Proposal submitted by Co-
`founders of Petitioner Flex Logix Technologies
`Inc. illustrating the long felt need and
`commercial recognition of 2D-layouts disclosed
`in the 8,269,523 patent
`2013 PhD Dissertation by Co-founder of
`Petitioner Flex Logix Technologies Inc.
`plagiarizing the 2D-layouts disclosed in the
`8,269,523 patent
`File history of the reissue application
`16/202,067 for the 8,269,523 patent currently
`under prosecution
`Computer Science Notes for Graduate course
`“Parallel Computing” for Chapter 2 - Parallel
`Architectures and interconnection networks, by
`Prof. Stewart Weiss at City University of New
`York
`Venkat Konda’s Declaration in support of
`Patent Owner’s sur-reply to Petitioner’s reply to
`Patent Owner’s Preliminary Response
`
`Ex. 2008
`
`2019-01-24 Motion to Dismiss by Petitioner
`
`Ex. 2009
`
`Ex. 2010
`
`2019-03-18 Motion to Dismiss to First
`Amended Complaint to Petitioner
`PCT Legal - '523 basic national fee late issue
`remedied
`Reissue application available for Public from 1-
`1-2019 on Public PAIR
`Ex. 2012 Notice-of-prior-concurrent-proceedings filed in
`reissue application
`
`Ex. 2011
`
`
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`Page 1 of 5
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`X
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`X
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`X
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`X
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`X
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`X
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`X
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`IPR2020-00260
`Patent 8,269,523
`
`
`
`
`Paper No. 48
`
`
`Ex. 2014
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`Ex. 2015
`
`Ex. 2013 Venkat Konda’s Declaration in support of
`Patent Owner’s response to Petitioner’s Notice
`in response to May 28, 2020 Board’s Order
`regarding multiple petitions
`Board's Order to rank in the PGR2019-00037,
`40 & 42
`Petitioner's Notice in Response to Board’s
`Order to rank in the PGR2019-00037, 40 & 42
`Patent Owner’s response Petitioner's Notice to
`Board’s Order to rank in the PGR2019-00037,
`40 & 42
`
`Ex. 2016
`
`Ex. 2017
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`Ex. 2018
`
`Ex. 2019
`
`Ex. 2020
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`Ex. 2021
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`Ex. 2022
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`
`
`Institution decision of PGR2019-00040
`
`Patent Owner’s Objections to evidence
`regarding Petitioner’s submission of a flawed
`Definition of a Person Of Ordinary Skill In The
`Art to accommodate its unqualified witness in
`the PGR2019-00037, 42
`Email Communication Regarding Petitioner’s
`delay for more than 2 weeks till today, to file
`Court Reporter’s Transcript in the PGR2019-
`00037, 42
`Transcript of conference call with the Board on
`May 27, 2020 regarding Petitioner’s submission
`of a flawed Definition of a Person Of Ordinary
`Skill In The Art to accommodate its unqualified
`witness in the PGR2019-00037, 42, and Board’s
`DENIED ORDER of Petitioner’s request to
`leave to file motion to expunge PO’s motions to
`exclude
`Petitioner’s Opposition to Patent Owner’s
`Motion to Exclude Evidence regarding
`Petitioner’s submission of a flawed Definition
`of a Person Of Ordinary Skill In The Art to
`accommodate its unqualified witness in the
`PGR2019-00037, 42
`Patent Owner’s Reply too Petitioner’s response
`to Patent Owner’s Motion to Exclude Evidence
`regarding Petitioner’s submission of a flawed
`Definition of a Person Of Ordinary Skill In The
`
`Page 2 of 5
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`IPR2020-00260
`Patent 8,269,523
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`Paper No. 48
`
`
`Art to accommodate its unqualified witness in
`the PGR2019-00037, 42
`Ex. 2023 Venkat Konda Declaration in Support of Patent
`Owner’s Reply to Petitioner’s Opposition to
`Patent Owner’s Motion to Exclude
`Ex. 2024 Venkat Konda Declaration in Support of Patent
`Owner’s Motion to Exclude
`
`Ex. 2025
`
`Ex. 2026
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`Ex. 2027
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`Declaration of Vipin Chaudhary Ph.D.
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`Curriculum Vitae of Vipin Chaudhary Ph.D.
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`USPTO form PTO/SB/68
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`X
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`X
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`X
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`X
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`X
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`X
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`X
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`Ex. 2028
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`Ex. 2030
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`Board’s Email Confirmation that PO satisfied
`the relying on Ex. 2025-27 for PO’s Responses
`Ex. 2029 Venkat Konda Declaration in Support of Patent
`Owner’s Motion to Amend
`Fourth Amended Complaint (Verified
`Complaint): Venkat Konda PhD vs Markovic,
`Wang, Flex Logix Technologies et al, Case
`No:19CV345846, In The Superior Court of the
`State of California, County of Santa Clara
`Ex. 2031 Declaration of Vipin Chaudhary Ph.D. in
`support of Fourth Amended Complaint - Exhibit
`2030
`Exhibits A-E, Declaration of Vipin Chaudhary
`Ph.D. in support of Fourth Amended Complaint
`- Exhibit 2030
`Ex. 2033 Venkat Konda Declaration in Support of Patent
`Owner’s Motion to Exclude Pursuant to 37 CFR
`§ 42.64(c)
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`Ex. 2032
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`
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`Dated: April 13, 2021
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`Respectfully submitted,
`
` /Venkat Konda/
`Venkat Konda
`Pro se Counsel
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`
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`Page 3 of 5
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`IPR2020-00260
`Patent 8,269,523
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`Paper No. 48
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`CERTIFICATE OF SERVICE
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`
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`Pursuant to 37 C.F.R. § 42.6(e) and consent of the Petitioner, I certify that
`
`on April 13, 2021, a true and correct copy of the foregoing Patent Owner’s current
`
`list of exhibits were served on counsel of record for Petitioner by email to PH-
`
`FlexLogix-Konda-IPR@paulhastings.com
`
`Lead counsel:
`Naveen Modi (Reg. No. 46,224),
`Backup counsel:
`1. Joseph E. Palys (Reg. No. 46,508)
`2. Paul M. Anderson (Reg. No. 39,896)
`3. Arvind Jairam (Reg. No. 62,759)
`
`Service information:
`Paul Hastings LLP
`875 15th St. N.W.
`Washington, D.C., 20005
`Tel.: 202.551.1700
`Fax: 202.551.1705
`Email: PH-FlexLogix-Konda-IPR@paulhastings.com.
`
`
`
`
`Dated: April 13, 2021
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`
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`
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`Respectfully submitted,
`
`/Venkat Konda/
`Venkat Konda
`Pro Se Counsel
`
`
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`
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