`Filed: April 26, 2013
`
`Filed on behalf of: Bloomberg Inc. et al.
`By: Michael T. Rosato
`Brian D. Range
`WILSON SONSINI GOODRICH & ROSATI
`701 Fifth Avenue
`Suite 5100
`Seattle, WA 98104-7036
`Tel.: 206-883-2529
`Fax: 206-883-2699
`Email: mrosato@wsgr.com
`Email: brange@wsgr.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________________
`
`Bloomberg Inc., Bloomberg L.P., Bloomberg Finance L.P., The Charles Schwab
`Corporation, Charles Schwab & Co., Inc., E*TRADE Financial Corporation,
`E*TRADE Securities LLC, E*TRADE Clearing LLC, optionsXpress Holdings
`Inc., optionsXpress, Inc., TD Ameritrade Holding Corp., TD Ameritrade, Inc., TD
`Ameritrade IP Company, Inc., and thinkorswim Group Inc.
`Petitioner,
`
`v.
`
`Patent of MARKETS-ALERT PTY LTD.
`Patent Owner.
`_____________________________
`
`Case CBM2013-00005 (JYC)
`Patent No. 7,941,357
`_____________________________
`
`PETITIONER’S MOTIONS LIST
`
`
`
`PETITIONER’S MOTIONS LIST
`
`Petitioner respectfully submits the following Petitioner’s list of proposed motions, in
`
`advance of the initial conference call with the Board, scheduled for 1 PM ET on April 30, 2013.
`
`1. Motion to submit supplemental information under 37 C.F.R. §42.223, including
`
`affidavit materials from the organization “Internet Archive” regarding certain archived Web
`
`pages cited in the petition for Covered Business Method Patent Review.
`
`2. Motion for discovery under 37 C.F.R. §42.51 and/or §42.224, including cross-
`
`examination of Jeffery Bruce McGeorge, who is listed as the sole inventor of the subject Patent
`
`No. 7,941,357. Markets-Alert filed a “Declaration of Jeffery Bruce McGeorge” as “Exhibit 3”
`
`with its Preliminary Response, and cited to said testimony throughout the Preliminary Response.
`
`To the extent the requested cross-examination is not considered routine discovery under 37
`
`C.F.R. §42.51(b)(1)(ii), Petitioner seeks authorization to file a motion for additional discovery
`
`pursuant to 37 C.F.R. §42.51(b)(2).
`
`Date: April 26, 2013
`
`Respectfully submitted,
`
`/ Michael T. Rosato /
`Michael T. Rosato
`WILSON SONSINI GOODRICH & ROSATI
`701 Fifth Avenue
`Suite 5100
`Seattle, WA 98104-7036
`Tel.: 206-883-2529
`Fax: 206-883-2699
`Email: mrosato@wsgr.com
`Email: brange@wsgr.com
`
`1
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that the foregoing Petitioner’s Motions List was served on
`
`April 26, 2013, at the following address of record for the subject patent:
`
`Andrew Y. Choung
`GLASER WEIL FINK JACOBS HOWARD AVCHEN & SHAPIRO LLP
`10250 Constellation Boulevard, 19th Floor
`Los Angeles, CA 90067
`achoung@glaserweil.com
`Tel.: 310-553-3000
`Fax: 310-785-3506
`
`William Fitzpatrick
`3700 Newport Blvd., Suite 101
`Newport Beach, CA 92663
`bill@frobbeintl.com
`Tel.: 518-573-2879
`
`5538688v1
`
`/ Michael T. Rosato /
`Michael T. Rosato
`
`2
`
`
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