UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`SAMSUNG ELECTRONICS, CO., LTD., and
`
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioners,
`
`v.
`
`ANCORA TECHNOLOGIES, INC.
`Patent Owner.
`_______________
`
`IPR2020-00583
`Patent No. 6,411,941
`_______________
`
`PETITIONER’S MOTION FOR JOINDER UNDER 35 U.S.C. § 315(c),
`37 C.F.R. § 42.22, AND § 42.122(b)
`
`
`
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`SAMSUNG ELECTRONICS, CO., LTD., and
`
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioners,
`
`v.
`
`ANCORA TECHNOLOGIES, INC.
`Patent Owner.
`_______________
`
`IPR2020-00583
`Patent No. 6,411,941
`_______________
`
`PETITIONER’S MOTION FOR JOINDER UNDER 35 U.S.C. § 315(c),
`37 C.F.R. § 42.22, AND § 42.122(b)
`
`
`
`
`
`
`
`
`
`Table of Contents
`
`STATEMENT OF THE PRECISE RELIEF REQUESTED .............................................. 1
`
`ARGUMENT ...................................................................................................................... 2
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`
`
`
`
`
`
`Legal Standard ........................................................................................................ 2
`
`Samsung’s Motion for Joinder Is Timely ............................................................... 3
`
`The Four Factors Favor Joinder .............................................................................. 3
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
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`Joinder of Samsung Is Appropriate Because It Will Promote an
`Efficient Determination of the Validity of the ’941 Patent Without
`Prejudice to Any Party ................................................................................ 4
`
`Samsung’s Petition Does Not Raise Any New Grounds of
`Unpatentability and Therefore Does Not Add Additional
`Complexity to the Grounds in the TCT Petitioners’ Petition ..................... 6
`
`Joinder Will Not Affect the Schedule in the TCT IPR ............................... 7
`
`Joinder Will Simplify Briefing Because Samsung Has Agreed to
`Consolidated Filings and an Understudy Role............................................ 7
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`Joinder Will Result in No Prejudice to Patent Owner .............................. 10
`
`
`
`
`
`
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`INSTITUTION IS APPROPRIATE UNDER GENERAL PLASTIC ............................... 10
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`FINTIV Factors ................................................................................................................. 15
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`CONCLUSION ................................................................................................................. 15
`
`i
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`
`
`
`
`STATEMENT OF THE PRECISE RELIEF REQUESTED
`Samsung Electronics, Co., Ltd. and Samsung Electronics America, Inc., and
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`(together, “Samsung” or “Petitioners”) respectfully submit this Motion for Joinder,
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`concurrently with a Petition (“Samsung’s Petition”) for inter partes review of U.S.
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`Patent No. 6,411,941 (“’941 patent”).
`
`Pursuant to 35 U.S.C. § 315(c), 37 C.F.R. §§ 42.22 and 42.122(b), Samsung
`
`requests institution of an inter partes review and joinder with IPR2020-01609 (“TCT
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`IPR”), which was instituted on February 16, 2021. TCT Mobile (US) Inc. et al. v.
`
`Ancora Technologies, Inc., IPR2020-01609, Paper 7 (PTAB Feb. 16, 2021).
`
`Samsung’s Petition is essentially a copy of the TCT IPR. It includes the identical
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`grounds presented in the TCT IPR and therefore would create no additional burden
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`for the Board, the TCT Petitioners or Patent Owner if joined. Joinder would therefore
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`lead to an efficient resolution of the validity of the ’941 patent.
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`Samsung stipulates that if joinder is granted, it will cooperate with the TCT
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`Petitioners in the joined proceeding, whether at hearings, at depositions, in filings,
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`or otherwise, as outlined below. Unless all of the TCT Petitioners are terminated
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`from the proceedings, Samsung will act in a limited “silent understudy” role. Joinder
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`will not impact the trial schedule because the proceeding based on the TCT IPR is
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`in its early stages.
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`1
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`
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`Samsung has notified counsel for the TCT Mobile (US) Inc., Huizhou TCL
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`Mobile Communication Co., Ltd., and Shenzhen TCL Creative Cloud Technology
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`Co., Ltd. Petitioners (“TCT Petitioners”) and counsel for Patent Owner regarding
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`the subject of this motion. Counsel for the TCT Petitioners have indicated that the
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`TCT Petitioners have reached a settlement in principle with Patent Owner and do
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`not consent to this joinder motion.
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`Given the similarities of the proceedings, the lack of undue prejudice to Patent
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`Owner, and the potential benefit to the public and to the Board that would accrue by
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`Samsung’s participation in the TCT IPR proceeding in the event that TCT
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`Petitioners’ participation terminates, the Board should institute IPR and grant
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`Samsung’s Motion for Joinder.
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` ARGUMENT
` Legal Standard
`A petitioner may request joinder, without prior authorization, up to one month
`
`after the institution date of the proceeding to which joinder is requested. 37 C.F.R.
`
`§ 42.122(b); Taiwan Semiconductor Mfg. Co., Ltd. v. Zond LLC, IPR2014-00781
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`and IPR2014-00782, Paper 5 at 3 (PTAB May 29, 2014).
`
`The Board may grant a motion for joining a petitioner for inter partes review
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`to another inter partes review proceeding. See 35 U.S.C. § 315(c). In determining
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`whether to exercise its discretion to grant a motion for joinder, the Board considers:
`
`2
`
`
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`(1) reasons why joinder is appropriate; (2) any new grounds of unpatentability
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`asserted in the petition; (3) what impact (if any) joinder would have on the trial
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`schedule for the existing review; and (4) specifically how briefing and discovery
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`may be simplified. See Dell, Inc. v. Network-1 Security Solutions, Inc., IPR2013-
`
`00385, Paper 17 at 3 (July 29, 2013).
`
`Samsung’s Motion for Joinder Is Timely
`
`Joinder may be requested “no later than one month after the institution date
`
`of any inter partes review for which joinder is requested.” 37 C.F.R. § 42.122(b).
`
`The TCT IPR was instituted on February 16, 2021. IPR2020-01609, Paper 7 (Feb.
`
`16, 2021). Samsung’s current motion is timely as it is being filed within one month
`
`of the institution date. Samsung has become aware of a possible settlement between
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`the TCT Petitioners and Patent Owner, but respectfully submits that the Board
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`should not grant any motion to terminate the -01609 IPR until after it rules on
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`Samsung’s joinder petition and that of other parties who have also requested joinder,
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`see, e.g., IPR2021-00570, IPR2021-00581. Cf. AT&T Services, Inc. v. Convergent
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`Media Solutions, LLC, IPR2017-01235, Paper 11 (PTAB May 9, 2017). Moreover,
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`the mere possibility of settlement should not in and of itself be a basis for denial of
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`joinder.
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`
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`The Four Factors Favor Joinder
`
`3
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`
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`Each of the four factors weighs in favor of granting Samsung’s Motion for
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`Joinder. Samsung’s Petition is substantively identical to the petition in the TCT IPR;
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`it presents no new grounds of unpatentability. Because Samsung agrees to take on a
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`“silent understudy” role in the TCT IPR proceeding, joinder will have minimal or
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`no impact on the pending schedule of the TCT IPR. Moreover, the briefing and
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`discovery will be simplified by resolving all issues in a single proceeding.
`
`1.
`
`Joinder of Samsung Is Appropriate Because It Will Promote
`an Efficient Determination of the Validity of the ’941 Patent
`Without Prejudice to Any Party
`Samsung seeks to join the TCT IPR proceeding in order to ensure that an
`
`accused infringer1 with an active interest in the proceeding remains a party to this
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`Trial if the TCT Petitioners’ participation is terminated prior to completion.
`
`Accordingly, joining Samsung to the TCT IPR proceeding is the most practical way
`
`to secure the just, speedy, and inexpensive resolution of the challenge to the ’941
`
`patent. See 37 C.F.R. § 42.1(b).
`
`If Samsung is joined as a party, the validity of the grounds raised in the TCT
`
`IPR can be determined in a single proceeding. Joinder is also appropriate because
`
`
`1 Patent Owner has accused Samsung of infringing the ’941 patent in a lawsuit filed
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`in the Western District of Texas, see Ancora Technologies, Inc., v. Samsung
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`Electronics Co., Ltd., et al., Case No. 6:19-cv-00385-ADA (W.D. Tex.).
`
`4
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`
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`Samsung’s petition challenges the validity of the same claims of the ’941 patent on
`
`identical grounds to those in the TCT IPR. There are no substantive differences
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`between Samsung’s and TCT’s Petitions. See IPR2020-01609, Paper 1 (Sep. 10,
`
`2020). Samsung also relies on substantially the same supporting evidence in its
`
`Petition as is relied on in the TCT IPR.2 A consolidated proceeding, including
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`Samsung and the TCT Petitioners, will therefore be more efficient and less wasteful,
`
`as only a single trial on these common grounds would be required. See, e.g., Oracle
`
`America Inc. v. Realtime Data LLC, IPR2016-01672, Paper 13 at 7 (PTAB Mar. 7,
`
`2017) (noting that “joining Oracle’s identical challenges to those in the 1002 IPR
`
`will lead to greater efficiency while reducing the resources necessary from both
`
`Realtime and the Board”). The Board “routinely grants motions for joinder where
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`the party seeking joinder introduces identical arguments and the same grounds raised
`
`
`2 The supporting expert declaration of Dr. Erez Zadok submitted by Samsung agrees
`
`with the facts, analysis, and conclusions of the expert declaration in the TCT IPR.
`
`The Samsung expert declaration does not contain any new opinions not included in
`
`the TCT IPR expert declaration. See Everlight Elecs. Co., v. Document Security Sys.,
`
`Inc., IPR2018-01260, Paper No. 12 at 6-7 (Nov. 14, 2018) (granting motion for
`
`joinder where petitioner submitted separate but substantially identical expert
`
`declaration).
`
`5
`
`
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`in the existing proceeding.” Samsung Elecs. Co., Ltd. v. Raytheon Co., IPR2016-
`
`00962, Paper 12 at 9 (PTAB Aug. 24, 2016) (internal quotations and citations
`
`omitted).
`
`Joining Samsung as a party to the TCT IPR also would promote the public
`
`interest relating to the unpatentability of the ‘941 patent and not cause any undue
`
`prejudice to Ancora or the TCT Petitioners. Ancora, as the patent owner, must
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`respond to the common invalidity grounds identified in the TCT Petitioners’ and
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`Samsung’s Petitions regardless of joinder.
`
`2.
`
`Samsung’s Petition Does Not Raise Any New Grounds of
`Unpatentability and Therefore Does Not Add Additional
`Complexity to the Grounds in the TCT Petitioners’ Petition
`Samsung’s Petition challenges the validity of the ’941 patent on identical
`
`grounds to those in the TCT IPR. See IPR2020-01609, Paper 1 (Sep. 10, 2020).
`
`Samsung’s supporting materials―including its supporting expert declaration,
`
`exhibits, and exhibit numbering―are also substantially identical to those presented
`
`in the TCT -01609 IPR. See supra n.2. While Samsung uses its own expert declarant,
`
`the Samsung expert’s declaration agrees with the facts, analysis, and conclusions of
`
`the expert declaration in the TCT IPR and does not contain any new opinions not
`
`included in the TCT IPR expert declaration. See Everlight Elecs. Co., v. Document
`
`Security Sys., Inc., IPR2018-01260, Paper No. 12 at 6-7 (Nov. 14, 2018) (granting
`
`motion for joinder where petitioner submitted separate but substantially identical
`
`6
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`
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`expert declaration). Further, unity of exhibits and exhibit numbering with the TCT
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`IPR has also been maintained. Accordingly, no new grounds are being introduced.
`
`See Sony Corp. v. Memory Integrity, LLC., IPR2015-01353, Paper No. 11 at 5-6
`
`(PTAB Oct. 5, 2015) (granting motion for joinder where petitioners relied “on the
`
`same prior art, same arguments, and same evidence, including the same expert and
`
`a substantively identical declaration”).
`
`Therefore, consolidation of this proceeding with TCT’s via joinder of
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`Samsung’s Petition will not raise any new issues of unpatentability and will not
`
`impose any additional burden on the Board or add additional complexity to the case.
`
`Joinder Will Not Affect the Schedule in the TCT IPR
`3.
`Given that the Board instituted review of the TCT IPR only a week ago,
`
`joinder of Samsung would not affect the schedule in any forthcoming trial.
`
`Samsung’s participation would result in no changes to the schedule.
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`Samsung agrees to adhere to all applicable deadlines set forth in the TCT IPR
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`Scheduling Order. The Patent Owner’s Response will not be affected because the
`
`issues in Samsung’s Petition are identical to those in the TCT IPR petition. Patent
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`Owner will thus not be required to provide any additional analysis or arguments.
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`4.
`
`Joinder Will Simplify Briefing Because Samsung Has Agreed
`to Consolidated Filings and an Understudy Role
`To further prevent joinder from imposing any burden on the TCT Petitioners
`
`or Ancora and to further ensure that there are no changes in the potential trial
`
`7
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`
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`schedule, Samsung has agreed, as long as any of the TCT Petitioners remain a party
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`to the TCT IPR proceeding (IPR2020-01609), to take an understudy role, which will
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`simplify briefing and discovery. In this role, Samsung agrees to the following
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`conditions:
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`(a) Samsung shall not make any substantive filing and shall be bound by the
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`filings of the TCT Petitioners, unless a filing concerns termination and settlement,
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`or issues solely involving Samsung;
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`(b) Samsung shall not present any argument or make any presentation at oral
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`hearing on issues not solely involving Samsung, except when addressing
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`Board-approved motions that do not affect the TCT Petitioners, or their respective
`
`position;
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`(c) Samsung shall not seek to cross-examine or defend the cross-examination
`
`of any witness, unless the topic of cross-examination concerns issues solely
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`involving Samsung;
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`(d) Samsung shall not seek discovery from Patent Owner on issues not solely
`
`involving Samsung;
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`(e) Samsung will not rely on expert testimony beyond that submitted by the
`
`TCT Petitioners unless all of the TCT Petitioners are terminated from the case prior
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`to any necessary depositions. If the TCT Petitioners are not terminated from the case
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`prior to any necessary depositions, Samsung agrees to rely entirely on, and be bound
`
`8
`
`
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`by, the expert declaration(s) and depositions in the TCT IPR. (Petitioners intended
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`to submit an expert declaration identical to the Wolfe declaration filed by the TCT
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`Petitioners, but Dr. Wolfe’s unavailability required Petitioners to instead retain Dr.
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`Zadok. Samsung’s expert, Dr. Zadok, would not be relied on if the TCT Petitioners
`
`continue to participate in the -01609 IPR. See, e.g., Noven Pharm., Inc. v. Novartis
`
`AG, IPR2014-00550, Paper 38 at 5 (PTAB April 10, 2015)). Unless and until the
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`current petitioners in IPR2020-01609 cease to participate in the instituted TCT IPR
`
`proceeding, Samsung will not assume an active role therein.3
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`Accordingly, due to Samsung taking only an “understudy” role, Ancora and
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`the TCT Petitioners will only need to respond to one principal set of papers, will not
`
`require additional time to address additional arguments, and can thus proceed with
`
`the existing trial schedule. These steps will minimize or eliminate any potential
`
`complications or delay that could potentially result from joinder. See Sony Corp. v.
`
`Memory Integrity, LLC., IPR2015-01353, Paper No. 11 at 6-7 (PTAB Oct. 5, 2015)
`
`(granting motion because “joinder would increase efficiency by eliminating
`
`duplicative filings and discovery, and would reduce costs and burdens on the parties
`
`
`3 For clarity, should the TCT Petitioners’ participation in this IPR proceeding
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`terminate, Samsung would take over primary responsibility for subsequent filings
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`and discovery.
`
`9
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`
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`as well as the Board” where second petitioner agreed to “understudy” role). Samsung
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`will also abide by any additional conditions the Board deems appropriate for an
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`“understudy” role.
`
`Joinder Will Result in No Prejudice to Patent Owner
`5.
`As noted above, Samsung’s joining of the TCT IPR proceeding should not
`
`result in any prejudice to Patent Owner. No additional grounds or arguments are
`
`being introduced, no new evidence or issues are being added, and no additional
`
`discovery or briefing or oral argument should be necessary as a result of Samsung’s
`
`joinder. Thus, the Patent Owner would not need to expend any additional resources
`
`beyond those required in the current TCT IPR proceeding.
`
`
`
`INSTITUTION IS APPROPRIATE UNDER GENERAL PLASTIC
`The Board should not deny joinder under Apple Inc. v. Uniloc 2017 LLC,
`
`IPR2020-00854 Paper 9 (PTAB Oct. 28, 2020) (precedential) merely because
`
`Petitioner’s earlier Petition in IPR2020-01184 was discretionarily denied institution.
`
`The Petition accompanying this motion is not a coordinated serial attack that
`
`presents the “undue inequities and prejudices” addressed by the Board’s precedent.
`
`See General Plastic Indus. Co. v. Canon Kabushiki Kaisha, IPR2016-01357, Paper
`
`19 at 17–18 (PTAB Sept. 6, 2017) (Paper 19) (§II.B.4.i precedential).
`
`The accompanying Petition is filed solely for the purpose of joining the TCT
`
`IPR. Since 2008, Patent Owner has been a serial filer of patent infringement cases
`
`10
`
`
`
`that assert the ’941 patent. Petitioners’ first filed Petition was denied on discretionary
`
`grounds under § 314(a). Another discretionary denial under 314(a) would encourage
`
`the use by patentees of a staged litigation filing strategy that unjustly disadvantages
`
`Petitioner by removing the option of joining an IPR. The substance and timing of
`
`this Petition do not present undue inequities, and the General Plastic factors do not
`
`favor denial.
`
`Factor 1: Under General Plastic, factor 1 considers “whether the same
`
`petitioner previously filed a petition directed to the same claims of the same patent.”
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`Id., at 16. Valve Corp. v. Electronic Scripting Products, Inc. expanded the scope of
`
`this factor, holding that the “application of the General Plastic factors is not limited
`
`solely to instances when multiple petitions are filed by the same petitioner.”
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`IPR2019-00062, Paper 11, at 9 (PTAB Apr. 2, 2019) (precedential) (“Valve I”).
`
`When, as here, different petitioners challenge the same patent, the Board
`
`“consider[s] any relationship between those petitioners.” Id. Valve I held that “[t]he
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`complete overlap in the challenged claims and the significant relationship between
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`[the petitioners] favor denying institution.” Id., at 10.
`
`While the accompanying Petition challenges a subset of the claims challenged
`
`in Samsung’s first Petition, the accompanying Petition is not a “follow-on” petition
`
`as contemplated by General Plastic and Valve Corp. See Valve I, Paper 11 at 1, 12;
`
`Valve Corp. v. Electronic Scripting Products, Inc., IPR2019-00064, Paper 10 at 1,
`
`11
`
`
`
`12–13 (PTAB May 1, 2019) (precedential) (“Valve II”). Where, as here, “the
`
`petitions challenging [a patent] involve two different petitioners…, who have not
`
`been shown to have the type of significant relationship…found in Valve,” Factor 1
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`“does not support denial.” E.g., Foursquare Labs, Inc. v. Mimzi, LLC, IPR2019-
`
`01287, Paper 11 at 7 (PTAB Jan. 14, 2020).
`
`Samsung and the TCT Petitioners are separate, unrelated petitioners, and are
`
`not similarly situated for purposes of Factor 1. Samsung and the TCT Petitioners are
`
`not co-defendants in the same litigation, but rather have been sued in separate district
`
`court proceedings. Samsung is not a privy to the district court litigation involving
`
`the TCT Petitioners, and the TCT Petitioners and Samsung are not accused of
`
`infringing the ’941 Patent based on sale of the same products. Nor have Samsung or
`
`the TCT Petitioners provided any products or technology to the other leading to an
`
`allegation of infringement of the ’941 Patent.
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`This factor does not weigh in favor of discretionary denial, or is at least
`
`neutral.
`
`Factors 2 and 4: While Petitioners became aware of the Hellman and Chou
`
`prior art references as of early 2020, and Schneck upon reviewing the -01609 IPR,
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`Petitioners’ first filed Petition (IPR2020-01184) was denied on discretionary
`
`grounds under § 314(a) and their joinder petition should not be viewed as in General
`
`Plastic or as a “serial attack that General Plastic was intended to address.” Apple
`
`12
`
`
`
`Inc. v. Uniloc 2017 LLC, IPR2016-00854, Paper 9 at 17–18 (PTAB Oct. 28, 2020)
`
`(precedential).
`
`These factors thus should not weigh in favor of denial, or are at least neutral.
`
`Factor 3: In Apple v. Uniloc, the PTAB denied Apple’s Motion for Joinder
`
`and institution of its second IPR “because the evidence and arguments presented [in
`
`Apple’s first IPR petition] failed to meet substantively the reasonable likelihood
`
`threshold required for institution.” Id., at 6. Apple’s second IPR was filed
`
`approximately one year after the Board denied the first IPR. Id.
`
`In contrast, in Samsung’s petition in IPR2020-01184, the Board did not
`
`analyze the merits of Samsung’s grounds in depth but rather exercised its discretion
`
`under § 314(a) to deny institution.4 The accompanying petition is thus not an “end
`
`run” around Samsung’s -01184 Petition because the Board there did not find a failure
`
`to meet substantively the reasonable likelihood threshold required for institution. Id.
`
`Moreover, Ancora’s serial litigation tactics have resulted in parties sued at
`
`different times, thus leading to different petitions at different times. Ancora sued
`
`
`4 The Board stated that its “initial impressions of the merits on th[e] preliminary
`
`record suggests Petitioner’s challenges contain certain weaknesses and, taken as a
`
`whole, the strengths of the merits do not outweigh other factors in favor of
`
`discretionary denial.” IPR2020-01184, Paper 11 at 24.
`
`13
`
`
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`Samsung in June 2019 and TCT in August 2019. Thus, the timing of filings is “a
`
`direct result of [Polaris’s] litigation activity.” Alphatech Holdings, Inc. v. Nuvasive,
`
`Inc., IPR2019-00361, Paper 19 (PTAB Jul. 9, 2019).
`
`Samsung filed its first IPR (-01184) Petition approximately ten weeks before
`
`the Petitioners filed IPR2020-01609 and did not strategically stage its first Petition
`
`and arguments in order to gain an unfair advantage from the -01609 Petition or
`
`otherwise engage in serial, tactical filings—the concerns expressed by the Board in
`
`General Plastic. See General Plastic at 17. There is nothing unreasonable or dilatory
`
`about the timing of Samsung’s Petition.
`
`This factor thus does not weigh in favor of discretionary denial, or is at least
`
`neutral.
`
`Factor 5: The Board exercised its discretion to deny Samsung’s first Petition
`
`on January 5, 2021. Samsung’s accompanying Petition is being filed one week after
`
`the institution of the -01609 IPR—well within the permitted one month time. See 37
`
`C.F.R. § 42.122(b).
`
`This factor does not weigh in favor of discretionary denial, or is at least
`
`neutral.
`
`Factors 6 and 7: These factors weigh in favor of institution, as there should
`
`be no material impact on the Board’s finite resources or its ability to issue a final
`
`determination on TCT’s Petition within one year.
`
`14
`
`
`
` FINTIV Factors
`For Fintiv Factor 2, the institution decision for IPR2020-01609 stated that “[i]t
`
`is undisputed that the parallel trial is scheduled to begin on April 19, 2021,” that
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`“Petitioner does not show that the trial date for the parallel litigation has been (or
`
`likely will be) changed,” and that “we generally take courts’ trial schedules at face
`
`value absent some strong evidence to the contrary.” IPR2020-01609, Paper 11, at 9,
`
`12–13. However, it is now less than certain that trial will commence in April 2021,
`
`as the Court recently indicated that trial will be held in 2021, but not necessarily in
`
`April. Ex. 1016, at 17.
`
` CONCLUSION
`For the reasons given above, Samsung respectfully requests that its Petition
`
`for Inter Partes Review of the ’941 patent be instituted and that Samsung be joined
`
`to the TCT IPR proceeding IPR2020-01609.
`
`
`
`February 23, 2021
`Date
`
`
`
`
`Respectfully submitted,
`
`COVINGTON & BURLING
`
`
`/Anupam Sharma/
`Anupam Sharma (Reg. No. 55,609)
`Peter P. Chen (Reg. No. 39,631)
`Gregory S. Discher (Reg. No. 42,488)
`Sinan Utku (Reg. No. 46,137)
`Richard L. Rainey (Reg. No. 47,879)
`
`Attorneys for Petitioners
`
`15
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6 and 42.105, I hereby certify that on February
`
`23, 2021, I caused a true and correct copy of the foregoing PETITIONER’S
`
`MOTION FOR JOINDER to be served on the Patent Owner’s counsel of record via
`
`Federal Express at the following address:
`
`Venable LLP
`600 Massachusetts Ave., N.W.
`Washington, DC 20043-9998
`
`A courtesy copy was also sent via electronic mail to:
`
`Jeffri A. Kaminski
`VENABLE LLP
`600 Massachusetts Ave., N.W.
`Washington, DC 20001
`Telephone (202) 344-4000
`Facsimile (202) 344-8300
`jakaminski@Venable.com
`
`A courtesy copy was also sent via electronic mail to Patent Owner’s litigation
`
`counsel at the following addresses:
`
`William E. Thomson, Jr.
`Marc Lorelli
`John P. Rondini
`Mark A. Cantor
`John S. LeRoy
`BROOKS KUSHMAN P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`
`
`
`Telephone (248) 358-4400
`Facsimile (248) 358-3351
`wthomson@brookskushman.com
`mlorelli@brookskushman.com
`jrondini@brookskushman.com
`mcantor@brookskushman.com
`jleroy@brookskushman.com
`ANCC0120IPR@brookskushman.com
`
`A courtesy copy was also sent via electronic mail to TCT Mobile (US) Inc.,
`
`Huizhou TCL Mobile Communication Co., Ltd., and Shenzhen TCL Creative Cloud
`
`Technology Co., Ltd.’s counsel at the following addresses:
`
`John P. Schnurer
`Yun (Louise) Lu
`Kyle R. Canavera
`PERKINS COIE LLP
`11452 El Camino Real, Suite 300
`San Diego, CA 92130
`Telephone (858) 720-5700
`Facsimile (858) 720-5799
`PerkinsServiceTCL-Ancora-IPR@perkinscoie.com
`
`February 23, 2021
`Date
`
`Respectfully submitted,
`
`COVINGTON & BURLING LLP
`
`/Anupam Sharma/
`Anupam Sharma
`Registration No.: 55,609
`
`
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