`U.S. Patent No. RE41,980
`
`Filed on behalf of Godo Kaisha IP Bridge 1
`
`By: Michael J. Fink (mfink@gbpatent.com)
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: (703) 716-1191
`Fax: (703) 716-1180
`
`
`
`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 IPR2017-00931
`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, PTAB
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`I.
`
`BACKGROUND
`
`Case IPR2017-00931 for
`U.S. Patent No. RE41,980
`
`
`Petitioner, Taiwan Semiconductor Manufacturing Company Limited
`
`(TSMC), previously filed two IPR Petitions challenging U.S. Patent No. RE41,980
`
`(Cases IPR2016-01331 and IPR2016-01367, both filed July 8, 2016), the same
`
`patent challenged in this case. Motions for District Court-Type Claim
`
`Construction were filed in both of the previously filed cases. See IPR2016-01331,
`
`Paper 6, August 8, 2016; and, IPR2016-01367, Paper 6, August 8, 2016. The
`
`Board denied institution of both of the previously filed cases. See Decision
`
`Denying Institution of Inter Partes Review, IPR2016-01331, Paper 9, January 5,
`
`2017; and, Decision Denying Institution of Inter Partes Review, IPR2016-01367,
`
`Paper 8, January 5, 2017. TSMC filed Requests for Rehearing in both of the
`
`previously filed cases on February 6, 2017. The Board denied the Request for
`
`Rehearing in Case IPR2016-01367 on March 13, 2017. See Decision Denying
`
`Request for Rehearing, IPR2016-01367, Paper 10.
`
`II. AUTHORIZATION AND RELIEF REQUESTED
`
`If the Board institutes this Case IPR2017-00931, 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). The filing of this Motion was authorized by the Board by email on March
`
`1
`
`
`
`Case IPR2017-00931 for
`U.S. Patent No. RE41,980
`
`
`13, 2017.
`
`III. 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 February 28, 2017 and the ‘980 patent will expire on September 8, 2017.
`
`
`Dated: March 15, 2017
`
`
`
`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
`
`2
`
`
`
`Case IPR2017-00931 for
`U.S. Patent No. RE41,980
`
`
`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 15th day of March, 2017, 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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