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`For the Patent Owner
`Lead counsel: Richard Neifeld, Reg. No. 35,299
`Backup counsel: Bruce Margulies, Reg. No. 64,175
`Neifeld IP Law, PC
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`Paper No. __
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`KYOCERA INTERNATIONAL, INC.
`Petitioner
`v.
`WISTARIA TRADING LTD.,
`Patent Owner
`____________
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`Case IPR2017-01109
`Patent 8,930,719
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`Patent Owner Motion for District Court-Type Claim Construction
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`Pursuant to 37 CFR 42.100(b), Patent Owner requests a district court-type
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`claim construction approach to be applied.
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`Pursuant to 37 CFR 42.100(b) and 42.20, Patent Owner certifies that the
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`involved patent will expire within 18 months from the filing date of the petition.
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`The petition was filed March 27, 2017.
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`Pursuant to 35 USC 154(a)(2), patent term is 20 years from the earliest date to
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`which the application claims a specific reference under 35 USC 120, 121, 365(c),
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`or 386)c). USP 8,930,719 is Exhibit 1001. Exhibit 1001 shows that the earliest
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`date to which USP 8,930,719 claims a specific reference is March 24, 1998.
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`Exhibit 1001 shows no patent term adjustment. This patent has a term that will
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`end 20 years from March 24, 1998, which is March 24, 2018.
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`March 24, 2018 is within 18 months of the petition filing date of March 27,
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`2017.
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`/RichardNeifeld/
`Richard Neifeld, Registration No. 35,299
`Lead counsel for Patent Owner
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`42.6(e) CERTIFICATE OF SERVICE
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`I certify that this document was served or simultaneously is being served on
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`each opposing party with the filing of this document. According to the Petition,
`Petitioner consents to electronic service. I certify that the following exhibits being
`filed along with this document, if any, have been or simultaneously are being
`served on each opposing party: N/A
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`42.6(e)(4) (iii)(A) The date and manner of service:
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`Manner of service: Email to npisano@foley.com and skaspar@foley.com
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`Date of Service: 4/21/2017
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`42.6(e)(4)(iii)(B) The name and address of every person served are:
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`Lead Counsel for petitioner, telephone and email:
`Nicola A. Pisano (Reg. No. 34,408) Tel: 858.847.6877; Email at
`npisano@foley.com
`Backup Counsel for petitioner, telephone and email:
`Scott R. Kaspar (Reg. No. 54,583) Tel: 312.832.5113; Email at
`skaspar@foley.com
`Postal Address for lead and backup counsel for petitioner:
`Foley & Lardner LLP, 3579 Valley Centre Drive, San Diego, CA 92130
`Fax Address for lead and backup counsel for petitioner: 858.792.6773
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`/RichardNeifeld/
`Richard Neifeld, Reg. No. 35,299
`Lead Counsel for the Patent Owner
`Neifeld IP Law, PC
`5400 Shawnee Road, Suite 310,
`Alexandria, VA 22312
`Tel: 1-703-415-0012 Ext. 100
`Fax: 1-703-415-0013
`Email: Rneifeld@neifeld.com
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