`______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
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`LIBERTY MUTUAL INSURANCE CO.
`Petitioner
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`v.
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`PROGRESSIVE CASUALTY INSURANCE CO.
`Patent Owner
`______________
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`Cases CBM2012-00002 & CBM2013-00009
`Patent Nos. 6,064,970 & 8,140,358
`______________
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`Before the Honorable JAMESON LEE, JONI Y. CHANG, and MICHAEL R.
`ZECHER, Administrative Patent Judges.
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`PETITIONER LIBERTY MUTUAL INSURANCE CO.’S NOTICE OF
`DEPOSITION OF MARK EHSANI
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`Pursuant to 37 C.F.R. § 42.53, Petitioner Liberty Mutual Insurance Co.
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`(“Liberty Mutual”), by and through its attorneys will conduct cross-examination by
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`deposition of Dr. Mark Ehsani. Dr. Ehsani’s deposition will take place commencing
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`at 9:00 AM EDT on July 29, 2013 and continuing from day-to-day if necessary, at the
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`offices of Jones Day, North Point 901 Lakeside Avenue, Cleveland, OH 44114, or at
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`such other time and place to which the parties may agree or which may be ordered by
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`the Board.
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`The cross-examination will be taken before a Notary Public or other officer
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`authorized by law to administer oaths. It will be recorded using audiotape and/or by
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`stenographic means. Liberty Mutual also intends to video record the cross-
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`examination of Dr. Ehsani. The arrangement for the reporter and videographer will
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`be made by counsel for Liberty Mutual.
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`July 3, 2013
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`Respectfully submitted,
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`ROPES & GRAY LLP
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`By /J. Steven Baughman/
`J. Steven Baughman, Lead Counsel
`Nicole M. Jantzi
`ROPES & GRAY LLP
`Prudential Tower
`800 Boylston Street
`Boston, Massachusetts 02199-3600
`Steven.baughman@ropesgray.com
`Nicole.jantzi@ropesgray.com
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`Attorneys for Petitioner Liberty Mutual Insurance Co.
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`2
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`CERTIFICATE OF SERVICE
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`It
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`is certified
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`that a copy of PETITIONER LIBERTY MUTUAL
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`INSURANCE CO.’S NOTICE OF DEPOSITION OF MARK EHSANI has been
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`served in its entirety on the Patent Owner as provided in 37 CFR § 42.6.
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`The copy has been served on July 3, 2013 by causing the aforementioned
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`document to be electronically mailed to:
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`Calvin P. Griffith, at: cpgriffith@jonesday.com
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`James L. Wamsley, III at: jlwamsleyiii@jonesday.com
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`John V. Biernacki at: jvbiernacki@jonesday.com
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`pursuant to the Petitioner and Patent Owner’s agreement.
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` /s/ Darrell W. Stark
`Darrell W. Stark
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`ROPES & GRAY LLP
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`3
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