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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY LIMITED,
`Petitioner,
`
`v.
`
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`____________
`
`Case IPR2016-01367
`U.S. Patent No. RE41,980
`____________
`
`
`
`PATENT OWNER’S MOTION FOR DISTRICT COURT-TYPE
`CLAIM CONSTRUCTION UNDER 37 C.F.R. § 42.100(b)
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`

`
`I.
`
`Authorization and Relief Requested
`
`Case IPR2016-1331 for
`U.S. Patent No. RE41,980
`
`
` Patent Owner Godo Kaisha IP Bridge 1 (“IP Bridge”) requests a district
`
`court-type claim construction approach under the standard provided by Phillips v.
`
`AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005), in accordance with 37 C.F.R. §
`
`42.100(b) (effective May 2, 2016).
`
`II. Certification
`
`
`
`IP Bridge certifies that the subject U.S. Patent No. RE41,980 (“the ‘980
`
`Patent”) will expire within 18 months from the entry of the Notice of Filing date
`
`Accorded to Petition. The Notice of Filing Date Accorded to Petition was entered
`
`on July 12, 2016 and the ‘980 patent will expire on September 8, 2017.
`
`
`Dated: August 2, 2016
`
`
`
`Respectfully Submitted by:
`
`/Michael J. Fink /
`Michael J. Fink
`Registration No. 31,827
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
`Fax: 703-716-1180
`Email: mfink@gbpatent.com
`
`Attorney for Patent Owner,
`IP Bridge
`
`
`
`
`1
`
`{R50505 02823166.DOC}
`
`

`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true copy of the foregoing:
`
`PATENT OWNER’S MOTION FOR DISTRICT COURT-TYPE CLAIM
`CONSTRUCTION UNDER 37 C.F.R. § 42.100(b)
`
`was served by electronic mail on this 2nd day of August, 2016, upon Counsel for
`
`Petitioner, as follows:
`
`E. Robert Yoches (bob.yoches@finnegan.com);
`Stephen E. Kabakoff (stephen.kabakoff@finnegan.com);
`Joshua L. Goldberg (joshua.goldberg@finnegan.com); and
`TSMC-IPB-PTAB@finnegan.com.
`
`
`
`/Michael J. Fink /
`Michael J. Fink
`Registration No. 31,827
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
`Fax: 703-716-1180
`Email: mfink@gbpatent.com

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