`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Parrot S.A. and Parrot, Inc.
`
`Petitioners,
`
`v.
`
`Drone Technologies, Inc.
`
`Patent Owner
`
`
`
`
`
`
`
`
`
`Case IPR2014-00730
`U.S. Patent No. 7,584,071
`
`
`
`
`
`
`
`
`
`
`
`
`Before HOWARD B. BLANKENSHIP, MATTHEW R. CLEMENTS, and
`CHRISTOPHER M. KAISER, Administrative Patent Judges.
`
`PETITIONER’S REPLY IN SUPPORT OF
`MOTION TO CORRECT EXHIBIT
`TO PETITION FOR INTER PARTES REVIEW
`PURSUANT TO 37 C.F.R. § 42.104(c)
`
`
`
`
`
`
`
`Case IPR2014-00730
`Patent 7,584,071
`
`
`EXHIBIT LIST
`
`Exhibit #
`
`Reference Name
`
`Ex. 1001
`
`U.S. Patent No. 7,584,071 (the ’071 Patent)
`
`Ex. 1002
`
`U.S. Patent No. 5,043,646 (“Smith”)
`
`Ex. 1003
`
`French Patent Publication No. 2,789,765 to Potiron
`
`Ex. 1004
`
`Certified English Translation of French Patent No.
`2,789,765 (“Potiron”)
`
`Ex. 1005
`
`U.S. Patent No. 7,219,861 (“Barr”)
`
`Ex. 1006
`
`U.S. Patent No. 6,751,529 (“Fouche”)
`
`Ex. 1007
`
`U.S. Patent Application Publication No. 2006/0144994 to
`Spirov (“Spirov”)
`
`Ex. 1008
`
`U.S. Pat. No. 7,145,551 (“Bathiche”)
`
`Ex. 1009
`
`U.S. Pat. Pub. No. 2004/0263479 (“Shkolnikov”)
`
`Ex. 1010
`
`Expert Declaration of Prof. Raffaello D’Andrea, with
`Attachments A-C
`
`Ex. 1010, Att. A U.S. Patent No. 613,809 to Tesla (“Tesla”)
`
`Ex. 1010, Att. B U.S. Patent No. 3,101,569 to Giardina (“Giardina”)
`
`Ex. 1010, Att. C U.S. Patent No. 8,072,417 to Jouanet (“Jouanet”)
`
`Ex. 1011
`
`Claim Chart Demonstrating Invalidity of the ’071 Patent
`
`Ex. 1012
`
`Declaration of Deborah A. Skolaski
`
`Ex. 1013
`
`Declaration of James E. Hopenfeld
`
`Ex. 1014
`
`Declaration of Prof. Raffaello D’Andrea
`
`
`
`i
`
`
`
`Case IPR2014-00730
`Patent 7,584,071
`
`
`Petitioner files this Reply in support of Petitioner’s Motion under 37 C.F.R.
`
`§ 42.104(c) to correct a clerical error in Exhibit 1010. This filing was authorized
`
`by the Board on February 2, 2015.
`
`The only issue here is whether Petitioner should be permitted to file a
`
`corrected Ex. 1010 that includes the inadvertently omitted “Appendix B.” For the
`
`reasons in Petitioner’s Motion, the correction should be authorized. Patent Owner
`
`does not establish otherwise. Petitioner’s filing establishes that there were clerical
`
`PDF assembly errors that were inadvertent and their correction would not prejudice
`
`Patent Owner. Indeed, Patent Owner made the same errors when filing its Patent
`
`Owner Response, as Exhibits 2013 and 2014 are both missing “Appendix A.”
`
`Patent Owner’s arguments that there are “inconsistencies” and “questions” raised
`
`regarding Prof. D’Andrea’s declaration in related proceeding IPR2014-00732 are
`
`neither relevant nor correct. There is no dispute that Prof. D’Andrea’s declaration
`
`is in fact Prof. D’Andrea’s, as he so testified.
`
`For the reasons set forth in Petitioner’s Motion and in the interests of justice,
`
`the Board should permit the correction of Ex. 1010.
`
`Dated: February 23, 2015
`
`Respectfully submitted,
`
`
`
`/ James E. Hopenfeld /
`James E. Hopenfeld (Reg No. 47,661)
`Hopenfeld@oshaliang.com
`Tammy J. Terry (Reg No. 69,167)
`Terry@oshaliang.com
`OSHA LIANG LLP
`
`1
`
`
`
`909 Fannin Street, Suite 3500
`Houston, Texas 77010
`Tel: 713-228-8600/Fax: 713-228-8778
`Counsel for Petitioner
`
`Case IPR2014-00730
`Patent 7,584,071 B2
`
`
`
`2
`
`
`
`Case IPR2014-00730
`Patent 7,584,071 B2
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies service pursuant to 37 C.F.R. §§ 42.6 on the Patent
`
`Owner by email and U.S. Mail a copy of this Reply in Support of Petitioner’s
`
`Motion to Correct Exhibit to Petition for Inter Partes Review pursuant to 37
`
`C.F.R. § 42.104(c) as follows:
`
`Gene Tabachnick
`James Dilmore
`gtabachnick@beckthomas.com
`jdilmore@beckthomas.com
`docket@beckthomas.com
`BECK & THOMAS, P.C.
`1575 McFarland Road, Suite 100
`Pittsburgh, PA 15216-1808
`
`Respectfully submitted,
`
`Dated: February 23, 2015
`
`/Tammy J. Terry/
`Tammy J. Terry (Reg No. 69,167)
`Terry@oshaliang.com
`James E. Hopenfeld (Reg No. 47,661)
`Hopenfeld@oshaliang.com
`OSHA LIANG LLP
`909 Fannin Street, Suite 3500
`Houston, Texas 77010
`Tel: 713-228-8600/Fax: 713-228-8778
`Counsel for Petitioner
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