`__________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`SAP AMERICA INC. AND SAP AG,
`Petitioners,
`v.
`VERSATA DEVELOPMENT GROUP INC.,
`Patent Owner.
`_________________
`Case CBM2012-00001
`Patent 6,553,350
`_________________
`Before the honorable MICHAEL P. TIERNEY, SALLY C. MEDLEY and RAMA
`G. ELLURU.
`
`
`PETITIONERS’ LIST OF PROPOSED MOTIONS
`
`Further to the Board’s Scheduling Order (Paper 37) setting an Initial
`
`Conference Call for February 5, 2013, and directing the parties to pages 48765-66
`
`of the Office Patent Trial Practice Guide, 77 Fed. Reg. 48756 (Section (II)(E)),
`
`Petitioners SAP America Inc. and SAP AG (collectively “SAP”) hereby submit a
`
`list of proposed motions presently contemplated by SAP and for which SAP
`
`intends to request authorization during the Initial Conference Call:
`
`● a Motion for Summary Determination of Invalidity under
`
`35 U.S.C. § 101, on an expedited schedule as approved by the Board,
`
`asserting that the challenged claims (claims 17 and 26-29) of U.S. Pat.
`
`
`
`
`
`Case No. CBM2012-00001
`Attorney Docket No. 09449.0025-00000
`
`No. 6,553,350 are unpatentable because they are unpatentably abstract
`
`and not directed to patent eligible subject matter. SAP expects to be in a
`
`position to file the proposed motion promptly after receiving
`
`authorization from the Board.
`
`Although SAP does not presently contemplate filing additional motions,
`
`SAP reserves the right to seek subsequent authorization for motions consistent with
`
`the Board’s Rules.
`
`Dated: February 1, 2013
`
`
`
`Respectfully submitted,
`
`By: /Michael V. Young, Sr./
`Erika H. Arner, Lead Counsel
`Joseph E. Palys
`Michael V. Young, Sr.
`FINNEGAN, HENDERSON,
`FARABOW, GARRETT & DUNNER,
`L.L.P.
`11955 Freedom Drive
`Reston, VA 20190
`Phone: 571-203-2700
`Facsimile: 202-408-4400
`
`J. Steven Baughman, Back-up Counsel
`ROPES & GRAY L.L.P
`Prudential Tower
`800 Boylston Street
`Boston, Massachusetts 02199
`Phone: 202-508-4606
`Facsimile: 617-235-9492
`
`Attorneys for Petitioners SAP America,
`Inc. and SAP AG
`
`
`
`
`
`
`
`2
`
`
`
`
`
`Case No. CBM2012-00001
`Attorney Docket No. 09449.0025-00000
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that the foregoing PETITIONERS’ LIST OF
`
`PROPOSED MOTIONS was served on February 1, 2013, to Nancy J. Linck and
`
`Martin M. Zoltick, Lead and Back-up Counsel for Versata, respectively, at the
`
`service e-mail address of VERSATA-PGR@rfem.com provided in Versata’s
`
`Mandatory Notices. The parties have agreed to electronic service.
`
`
`
` /Jacob Mersing/
`Jacob Mersing
`
`
`
`
`
`FINNEGAN, HENDERSON,
`FARABOW, GARRETT &
`DUNNER, L.L.P.
`
`
`
`
`
`
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`3
`
`
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