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Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 1 of 16 PageID #: 20850
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`VLSI TECHNOLOGY LLC,
`Plaintiff,
`
`v.
`
`INTEL CORPORATION,
`Defendant.
`
`
`
`
`
`
`C.A. No. 18-966-CFC
`
`FILED UNDER SEAL
`
`
`
`REPLY BRIEF IN SUPPORT OF
`PLAINTIFF VLSI TECHNOLOGY LLC'S SECOND MOTION
`TO REINTRODUCE CERTAIN ASSERTED PATENT CLAIMS, OR TO
`SEVER SUCH CLAIMS INTO A SEPARATE ACTION TO BE STAYED
`
`
`
`
`Dated: March 20, 2020
`
`Brian E. Farnan (Bar No. 4089)
`Michael J. Farnan (Bar No. 5165)
`FARNAN LLP
`919 N. Market St., 12th Floor
`Wilmington, DE 19801
`Telephone : (302) 777-0300
`Fax : (302) 777-0301
`bfarnan@farnanlaw.com
`mfarnan@farnanlaw.com
`
`Morgan Chu (admitted pro hac vice)
`Benjamin Hattenbach (admitted pro hac vice)
`Iian D. Jablon (admitted pro hac vice)
`Christopher Abernethy (admitted pro hac vice)
`Amy E. Proctor (admitted pro hac vice)
`Dominik Slusarczyk (admitted pro hac vice)
`S. Adina Stohl (admitted pro hac vice)
`
`
`
`
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`10815877
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 2 of 16 PageID #: 20851
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`Charlotte J. Wen (admitted pro hac vice)
`Brian M. Weissenberg (admitted pro hac vice)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067
`Telephone: (310) 277-1010
`mchu@irell.com
`bhattenbach@irell.com
`ijablon@irell.com
`cabernethy@irell.com
`aproctor@irell.com
`dslusarczyk@irell.com
`astohl@irell.com
`cwen@irell.com
`bweissenberg@irell.com
`
`Attorneys for Plaintiff
`VLSI Technology LLC
`
`10815877.
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 3 of 16 PageID #: 20852
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`TABLE OF CONTENTS
`
`Page
`
`I. 
`
`II. 
`
`III. 
`
`IV. 
`
`There Is No Dispute The Reintroduced Claims Present Unique Issues
`of Validity and Infringement, Implicating Due Process ............................... 1 
`A. 
`Intel Admits The Katz Standard Is Satisfied ......................................... 1 
`B. 
`Intel's "General Arguments" Are Mere Attempts At Misdirection ...... 1 
`C. 
`Intel Fails To Refute Any of VLSI's Claim-By-Claim Arguments ...... 3 
`1. 
`The '331 Patent ............................................................................ 3 
`2. 
`The '026 Patent ............................................................................ 4 
`3. 
`The '633 Patent ............................................................................ 5 
`4. 
`The '552 Patent ............................................................................ 6 
`VLSI Has Provided "A Showing of Good Cause That Includes A
`Demonstration that [Reintroduction] Is Necessary To Vindicate
`[VLSI's] Due Process Rights" ...................................................................... 6 
`A. 
`Intel Misstates Both This Court's Order and The Law ......................... 6 
`B. 
`Intel's Suggestion That VLSI's Motion Is "Untimely" Is Meritless ..... 8 
`Intel's Suggestion That Upholding Due Process Would Be Disruptive
`and Prejudicial Is Misguided ........................................................................ 9 
`If Not Reintroduced, The Claims At Issue Must Be Severed And
`Stayed .......................................................................................................... 10 
`
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 4 of 16 PageID #: 20853
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`
`
`TABLE OF AUTHORITIES
`
` Page(s)
`
`Cases
`In re Katz Interactive Call Processing Patent Litig., Inc.,
`639 F.3d 1303 (Fed. Cir. 2011) ...................................................................passim
`Other Authorities
`Fed. R. Civ. P. 11 ....................................................................................................... 2
`
`* Unless noted, all emphasis is added.
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`10815877
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 5 of 16 PageID #: 20854
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`
`
`I.
`
`There Is No Dispute The Reintroduced Claims Present Unique Issues of
`Validity and Infringement, Implicating Due Process
`Intel Admits The Katz Standard Is Satisfied
`Intel admits that "the limitations of each unelected claim are … different from
`
`A.
`
`the limitations of each elected claim" and that "the unelected claims omit certain
`
`limitations that form the basis for Intel's noninfringement defenses for certain elected
`
`claims." D.I. 591 ("Intel Op.") at 2, 12. This aligns perfectly with the Katz standard—
`
`i.e., a "defense raised by [the] defendant [] to a currently asserted claim does not
`
`apply in substantially the same manner to a newly asserted claim." In re Katz
`
`Interactive Call Processing Patent Litig., Inc., 639 F.3d 1303, 1313 (Fed. Cir. 2011).
`
`Because Intel admits that the claims VLSI seeks to reintroduce present unique
`
`issues of infringement and validity, there is no meaningful dispute that they
`
`implicate VLSI's due process rights. The Court could end its analysis here.
`
`B.
`
`Intel's "General Arguments" Are Mere Attempts At Misdirection
`Having admitted the Katz standard is satisfied, Intel resorts to misdirection.
`
`First, Intel argues it is not enough that "the unelected claims contain certain
`
`limitations not present in certain elected claims." Intel Op. at 12. This is a strawman.
`
`VLSI agrees, as does the Federal Circuit, that "[w]hile different claims are presumed
`
`to be of different scope, that does not mean that they necessarily present different
`
`questions of validity or infringement." Katz, 639 F.3d at 1313. There must be a
`
`difference that actually matters, whereby a "defense raised by [the] defendant [] to a
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`10815877
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 6 of 16 PageID #: 20855
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`
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`currently asserted claim does not apply in substantially the same manner to a newly
`
`asserted claim." Id. That is precisely what VLSI has shown and Intel admits—e.g.,
`
`"the unelected claims omit certain limitations that form the basis for Intel's
`
`noninfringement defenses for certain elected claims." Intel Op. at 12.
`
`Second, Intel suggests Katz should be disregarded because any defendant who
`
`disputes infringement necessarily "denies infringement based on limitations recited
`
`in the claims." Intel Op. at 13. This is a non-sequitur. Defendants do not always, or
`
`even typically, dispute infringement based on every limitation. Indeed, per Rule 11,
`
`a defendant should only dispute infringement based on the limitations for which it
`
`has a good-faith argument. Intel itself does not dispute every limitation.
`
`Third, Intel contends the analysis must consider "limitations that are common
`
`to both elected and unelected claims." Intel Op. at 14. But Intel has it backwards.
`
`The Katz analysis hinges on the differences between claims—not their similarities—
`
`because it requires that a "defense … to a currently asserted claim does not apply in
`
`substantially the same manner to a newly asserted claim." Katz, 639 F.3d at 1313.
`
`That can only occur if a difference between two claims makes a defense applicable
`
`to one claim but not the other. And if such a difference exists, extraneous similarities
`
`will not change that the defense still only applies to one claim and not the other.
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`10815877
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 7 of 16 PageID #: 20856
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`
`
`C.
`
`Intel Fails To Refute Any of VLSI's Claim-By-Claim Arguments
`1.
`The '331 Patent
`VLSI has shown Claim 2 of the '331 Patent presents unique questions of both
`
`validity and infringement. See D.I. 581 ("VLSI Br.") at 6-8.
`
`Rather than address VLSI's validity arguments, Intel turns to misdirection,
`
`stating the obvious: "claim 2 depends from claim 1 and therefore contains all
`
`limitations recited in claim 1," so "defenses with respect to the many limitations in
`
`common apply to both claims." Intel Op. at 15. But Intel again has it backwards.
`
`What matters is the differences—not commonalities—and how they impact Intel's
`
`defenses. Intel concedes "claim 2 requires … 'the cache memory is switchable to a
`
`locked state,' which claim 1 does not recite." Id. Intel further concedes this unique
`
`limitation leads to "differences in Intel's anticipation challenges" for Claims 1 and
`
`2. Id. For example, Intel does not deny that it contends "Claim 1 is purportedly
`
`anticipated by the Irie reference and, separately, by the Irie '277 reference," but
`
`"does not contend that either of Irie or Irie '277 anticipates dependent Claim 2." VLSI
`
`Br. at 7. Intel does not dispute that these "same defense[s] do[] not affect [Claim 2]
`
`in substantially the same way." Katz, 639 F.3d at 1313.
`
`VLSI has also shown Claim 2 presents unique questions of infringement. See
`
`VLSI Br. at 7-8. Intel's Opposition ignores this.
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 8 of 16 PageID #: 20857
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`
`
`2.
`The '026 Patent
`VLSI has shown Claim 17 of the '026 Patent presents unique questions of both
`
`validity and infringement. See VLSI Br. at 9-10.
`
`Intel ignores VLSI's arguments. Without addressing VLSI's discussion of the
`
`"non-overlapping limitation[s]," Intel contends "the more relevant comparison is
`
`between claim 17 and elected claim 4." Intel Op. at 16. But Intel ignores VLSI's
`
`entire discussion comparing precisely those claims, including specific Claim 4
`
`limitations not included in Claim 17—e.g., "mode indicator generator," "leakage
`
`indicator generator," and a "control circuit, connected to the mode indicator
`
`generator and the leakage indicator generator." VLSI Br. at 10. Intel merely
`
`provides bare assertions that these limitations allegedly do not "raise new issues of
`
`noninfringement or invalidity" and that "Intel's noninfringement arguments for those
`
`claims substantially overlap." Intel Op. at 16. But tellingly, Intel does not dispute
`
`that it "alleges non-infringement of … Claim 4 based on these limitations, but those
`
`defenses are inapplicable to … Claim 17." VLSI Br. at 10.
`
`Nor does Intel dispute that Claim 4 (which depends on Claim 1) and Claim 17
`
`(which depends on Claim 13) raise different validity issues. For example, "Intel
`
`alleges that Claim 13 is anticipated by Kim, but does not allege that Kim anticipates
`
`Claim 1." VLSI Br. at 10. Intel confusingly responds that, "[i]f the narrower claim
`
`is invalid, so is the broader one." Intel Op. at 16. But Intel's obfuscation aside, the
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 9 of 16 PageID #: 20858
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`
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`issue is quite simple: Intel asserts non-infringement defenses against Claim 4 that do
`
`not apply to Claim 17, and it asserts invalidity defenses against Claim 17 that do not
`
`apply to Claim 4. VLSI accordingly has a due process right to assert both claims.
`
`3.
`The '633 Patent
`Dropping Claims 1 and 13 in the second narrowing left VLSI with no asserted
`
`claims of the '633 Patent. Intel does not deny that, "[w]ithout reintroducing these
`
`claims, VLSI will be denied of its due process rights in the '633 Patent entirely."
`
`VLSI Br. at 11. Yet, through tortured logic, that is precisely what Intel advocates.
`
`Intel says non-elected claims should not be compared to a "null set of claims."
`
`Intel Op. at 14. That makes no sense. Claims 1 and 13 implicate VLSI's due process
`
`rights because they raise unique issues both (a) relative to every elected claim, and
`
`(b) relative to each other.
`
`First, Intel does not dispute that "the '633 Patent and its claims are wholly
`
`unrelated to all of the other asserted patents." VLSI Br. at 11. It is accordingly
`
`undisputed that Claims 1 and 13 "raise unique issues vis-à-vis the elected claims."
`
`Intel Br. at 14. VLSI thus indisputably has a due process right to assert at least one
`
`'633 Patent claim in this litigation.
`
`Second, VLSI has due process rights in both Claims 1 and 13—as opposed to
`
`only one of them—because they "present unique questions of both infringement and
`
`validity relative to each other." VLSI Br. at 11. Intel's assertion that "distinguish[ing]
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 10 of 16 PageID #: 20859
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`
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`one unelected claim from another has no bearing" on the Katz analysis is nonsensical
`
`(Intel Op. at 14), as a patentee would not have a due process right to reintroduce
`
`multiple claims that raise identical issues. For the same reason, Intel's assertion that
`
`granting VLSI's motion would allow patentees to "drop all claims of asserted patents
`
`and then freely re-assert them" is unsupportable (id.), because patentees must
`
`show—as VLSI has done—that each reintroduced claim raises unique issues not
`
`only relative to the elected claims, but also relative to each other.
`
`4.
`The '552 Patent
`VLSI has shown Claim 11 of the '552 Patent presents unique infringement
`
`issues. See VLSI Br. at 13-14. In response, Intel merely says it believes Claim 11
`
`"substantially overlap[s]" with Claims 2 and 20. Intel Br. at 15. Notably, Intel does
`
`not dispute that "Intel asserts non-infringement defenses for Claims 2 and 20 based
`
`on … limitations … Claim 11 does not include." VLSI Br. at 13.
`
`II. VLSI Has Provided "A Showing of Good Cause That Includes A
`Demonstration that [Reintroduction] Is Necessary To Vindicate [VLSI's]
`Due Process Rights"
`Intel Misstates Both This Court's Order and The Law
`The Court's Order requires "a showing of good cause that includes a
`
`A.
`
`demonstration that [reintroduction] is necessary to vindicate [VLSI's] due process
`
`rights." D.I. 136 at 2 n.1. Yet, Intel argues that "a showing that the added claims
`
`implicate VLSI's due process rights is necessary to establish good cause under the
`
`Case Narrowing Order, but is not sufficient standing alone." Intel Op. at 9. Intel says
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 11 of 16 PageID #: 20860
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`
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`the Court's words "showing of good cause that includes" require this. Id. But the
`
`Court was plainly just describing what the "showing of good cause" required—i.e.,
`
`a demonstration of due process rights, consistent with Katz.
`
`Intel suggests Katz should be ignored because the Federal Circuit "affirmed a
`
`district court's decision not to sever and stay." Intel Op. at 9. But Intel ignores that
`
`"Katz did not file a motion to add claims with the requisite showing." Katz, 639 F.3d
`
`at 1312. "Katz could have sought to demonstrate that some of its unselected claims
`
`presented unique issues as to liability or damages. If, notwithstanding such a
`
`showing, the court had refused to permit Katz to add those specified claims, that
`
`decision would be subject to review and reversal." Id. at 1312-13. Because "Katz
`
`made no effort to make such a showing," the Federal Circuit affirmed. Id. Here,
`
`VLSI filed has made the requisite showing.
`
`Intel nevertheless contends—without authority—that in addition to a Katz due
`
`process showing, VLSI must identify "new evidence (e.g., source code) to which
`
`VLSI did not previously have access that justifies adding the claims to the case now."
`
`Intel Op. at 11; see also id. at 8 (arguing VLSI must show, "based on new evidence,
`
`that it has a cognizable basis to assert [the] claims"). This argument lacks merit.
`
`VLSI does not seek to assert new claims; it seeks to vindicate due process rights in
`
`claims already asserted. VLSI asserted every claim at issue in its initial infringement
`
`contentions, identifying ample evidence supporting its allegations. D.I. 278, Ex. 1.
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 12 of 16 PageID #: 20861
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`
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`What Intel suggests is that, after a defendant produces documents and the plaintiff
`
`discloses its asserted claims and infringement contentions based on that production,
`
`the plaintiff could be forced to drop asserted claims that raise unique issues if the
`
`plaintiff does not show new evidence "that post-date[s] the Case Narrowing Order."
`
`Intel Br. at 11. That is illogical. A plaintiff who timely asserts claims in which it has
`
`due process rights—based on evidence produced in the case—cannot reasonably be
`
`forced to then dig up new evidence to avoid being stripped of its due process rights.
`
`B.
`
`Intel's Suggestion That VLSI's Motion Is "Untimely" Is Meritless
`Without meaningful explanation, Intel suggests VLSI's motion is "untimely."
`
`Intel Op. at 10-11. Intel's arguments are unsupportable.
`
`Waiver requires knowing relinquishment. VLSI has consistently emphasized
`
`the opposite: that VLSI would not be giving up its due process rights. See D.I. 318,
`
`VLSI Br. at 7-8. Recognizing this, the Court's Case Narrowing Order allowed VLSI
`
`to move to reintroduce claims if necessary for due process. See D.I. 136 at 2 n.1.
`
`Intel says "VLSI's true objection appears to be the Court's case narrowing"
`
`(Intel Op. at 10), and it suggests VLSI should have "sought reconsideration of the
`
`Case Narrowing Order" instead of filing this motion. Id. at 6. This makes no sense.
`
`VLSI is not challenging the Case Narrowing Order, as the Court appropriately
`
`provided that "Plaintiff may seek to add at a later date asserted claims … upon a
`
`showing of good cause that includes a demonstration that the addition of the
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 13 of 16 PageID #: 20862
`
`
`
`proposed new claims … is necessary to vindicate [its] due process rights." D.I. 136
`
`at 2 n.1. VLSI filed this motion following the procedure the Court ordered.
`
` Intel's suggestion VLSI should have filed this motion sooner also lacks merit.
`
`Intel Op. at 11. The Court's Order required VLSI to make its second claim election
`
`"30 days after the Court's issuance of a Claim Construction Order." D.I. 136 at 1.
`
`That deadline was later extended to 15 days after an Amended Claim Construction
`
`Order (VLSI Br. at 5 n.2), which the Court entered on December 19, 2019. D.I. 483.
`
`VLSI thereafter timely served its second election, dropping the claims at issue while
`
`expressly objecting to doing so, on January 3, 2020. D.I. 582, Ex. 1. VLSI then
`
`promptly filed this motion on February 27, 2020. D.I. 581.
`
`III.
`
`Intel's Suggestion That Upholding Due Process Would Be Disruptive and
`Prejudicial Is Misguided
`Intel contends that reintroducing claims of the '633 Patent would only waste
`
`resources because, in Intel's view, "VLSI's infringement theory is no longer viable
`
`under the Court's claim construction." Intel Op. at 17. This argument is misguided.
`
`First, Intel's Opposition is not a summary judgment motion. Second, the merits of an
`
`infringement claim have no bearing on VLSI's due process right to have its claim
`
`litigated on the merits, even if that were to mean resolution on summary judgment.
`
`Notably, VLSI "reserves the right to appeal any and all matters decided by the Court"
`
`(VLSI Br. at 5), including the construction of "serial communications interface."
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 14 of 16 PageID #: 20863
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`
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`Intel Op. at 17. VLSI has a right to have its claim litigated on the merits under the
`
`Court's construction, including to ensure that the issues are ripe for appeal if needed.
`
`Intel's "disruptive impact" argument is also unsupportable. Intel Br. at 17.
`
`Intel argues that discovery has proceeded for "fifteen months" and that, "[w]ith the
`
`elected claims in mind, … Intel served interrogatories, requests for production, and
`
`more than a dozen subpoenas." Id. But the five claims at issue were all in the case
`
`until VLSI's second election on January 3, 2020. D.I. 582, Ex. 1. Intel has served no
`
`discovery requests since, nor does it identify anything meaningful that has changed.
`
`IV.
`
`If Not Reintroduced, The Claims At Issue Must Be Severed And Stayed
`VLSI has shown the claims at issue "present[] unique issues as to liability."
`
`Katz, 639 F.3d at 1312. Thus, "due process requires [VLSI] be allowed to litigate
`
`the unselected claims either in this case or in subsequent actions." Id. at 1310.
`
`If not reintroduced, the claims must be severed and stayed to preserve VLSI's
`
`due process rights. Intel concedes this is the "usual practice" in the Eastern District
`
`of Texas and that this Court has also recognized the procedure. Intel Op. at 20 n.8.
`
`Intel wants to bar VLSI from litigating unique claims, yet still adjudicate them with
`
`prejudice. That would be unfair to VLSI and antithetical to due process.
`
`
`
`Dated: March 20, 2020
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`10815877
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`Respectfully submitted,
`
`/s/ Michael J. Farnan
`
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 15 of 16 PageID #: 20864
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`
`
`Brian E. Farnan (Bar No. 4089)
`Michael J. Farnan (Bar No. 5165)
`FARNAN LLP
`919 N. Market St., 12th Floor
`Wilmington, DE 19801
`Telephone : (302) 777-0300
`Fax : (302) 777-0301
`bfarnan@farnanlaw.com
`mfarnan@farnanlaw.com
`
`Morgan Chu (admitted pro hac vice)
`Benjamin Hattenbach (admitted pro hac vice)
`Iian D. Jablon (admitted pro hac vice)
`Christopher Abernethy (admitted pro hac vice)
`Amy E. Proctor (admitted pro hac vice)
`Dominik Slusarczyk (admitted pro hac vice)
`S. Adina Stohl (admitted pro hac vice)
`Leah Johannesson (admitted pro hac vice)
`Charlotte J. Wen (admitted pro hac vice)
`Brian M. Weissenberg (admitted pro hac vice)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`mchu@irell.com
`bhattenbach@irell.com
`ijablon@irell.com
`cabernethy@irell.com
`aproctor@irell.com
`dslusarczyk@irell.com
`astohl@irell.com
`ljohannesson@irell.com
`cwen@irell.com
`bweissenberg@irell.com
`
`Attorneys for Plaintiff
`VLSI Technology LLC
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`- 11 -
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`10815877
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`Case 1:18-cv-00966-CFC-CJB Document 602 Filed 03/27/20 Page 16 of 16 PageID #: 20865
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`
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`CERTIFICATE OF COMPLIANCE
`
`In accordance with the Court’s November 6, 2019 Standing Order Regarding
`
`Briefing in all Cases, I, Michael J. Farnan, hereby certify that the following is true
`
`and correct as to the foregoing document, titled "REPLY BRIEF IN SUPPORT OF
`
`PLAINTIFF VLSI TECHNOLOGY LLC'S SECOND MOTION TO
`
`REINTRODUCE CERTAIN ASSERTED PATENT CLAIMS, OR TO SEVER
`
`SUCH CLAIMS
`
`INTO A SEPARATE ACTION TO BE STAYED"
`
`("VLSI's Reply Brief"):
`
`VLSI's Reply Brief is set forth in 14-point, Times New Roman font. VLSI’s
`
`Reply Brief includes 2,498 words.
`
`
`
`Dated: March 20, 2020
`
`/s/ Michael J. Farnan
` Michael J. Farnan
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`10815877
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