`Paper No. ____
`Filed: March 4, 2020
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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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`FLEX LOGIX TECHNOLOGIES INC.
`Petitioner
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`v.
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`VENKAT KONDA
`Patent Owner
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`Case: PGR2019-00042
`U.S. Patent No. 10,003,553 B2
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`PETITIONER’S REPLY
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`Flex Logix Technologies Inc. (“Petitioner”) submits this reply. In Patent
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`Owner’s Motion to Amend (Paper No. 17) (“Mot.”) (“Motion”), Patent Owner
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`(“PO”) cancels claims 1-20. (Mot. at 2, Appendix (“App.”).) PO’s Motion indicates
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`that it is “made on a contingent basis and is made in lieu of a response.” (Id.)
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`However, because PO cancels claims 1-20, which PO acknowledges “will not be
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`regarded as contingent” (id. at 1-2, citing Lectrosonics, Inc. v. Zaxcom, Inc., Case
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`IPR2018-01129, (PTAB, Feb. 25, 2019) (Paper 15)), Petitioner understands that
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`claims 1-20 of the ’553 patent are no longer at issue. Moreover, even if PO would
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`not have cancelled claims 1-20, PO has not filed a response opposing the grounds
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`for invalidity raised in the Petition, and therefore claims 1-20 are invalid for the
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`reasons set forth in the Petition.
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`Dated: March 4, 2020
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`Respectfully submitted,
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`By: /Naveen Modi/
` Naveen Modi (Reg. No. 46,224)
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), I certify that I served on the counsel for Patent
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`Owner a true and correct copy of the foregoing Petitioner’s Reply by electronic
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`means on March 4, 2020, at the following address of record:
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`Venkat Konda <venkat@kondatech.com>
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`Dated: March 4, 2020
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`Respectfully submitted,
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`By: /Naveen Modi/
` Naveen Modi (Reg. No. 46,224)
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` Counsel for Petitioner
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