`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`LIBERTY MUTUAL INSURANCE CO.
`Petitioner
`
`v.
`
`PROGRESSIVE CASUALTY INSURANCE CO.
`Patent Owner
`______________
`
`Case CBM2013-00009
`Patent 8,140,358
`______________
`
`Before the Honorable JAMESON LEE, JONI Y. CHANG, and MICHAEL R.
`ZECHER,
`Administrative Patent Judges.
`
`PETITIONER’S LIST OF PROPOSED MOTIONS
`
`Further to the Board’s Institution Order (Paper 10) setting an Initial
`
`Conference Call for April 10, 2013, and directing the parties to pages 48765-66 of
`
`the Office Patent Trial Practice Guide, 77 Fed. Reg. 48756 (Section (II)(E)),
`
`Petitioner Liberty Mutual Insurance Co. (“Liberty Mutual”) hereby submits a list
`
`of proposed motions presently contemplated by Liberty Mutual and for which
`
`Liberty Mutual intends to request authorization during the Initial Conference Call:
`
` Motion for Protective Order pursuant to Rule 42.54; and
` Motions for Pro Hac Vice Admission pursuant to Rule 42.10(c).
`
`
`
`
`
`
`
`
`
`Liberty Mutual further intends to request during the Initial Conference Call
`
`that the Board adjust Due Date 7 (oral argument) in this matter (now scheduled for
`
`October 28, 2013), and the corresponding Due Date 7 (oral argument) in
`
`proceeding CBM2012-00003 concerning the same patent (now scheduled for
`
`September 10, 2013), so that (1) both oral arguments take place on the same date,
`
`facilitating decision in both matters on the same schedule, and (2) the date for both
`
`oral arguments is set for a date other than October 28, 2013, when two other
`
`proceedings (CBM2012-00010 and CBM2013-00002) between the same parties
`
`are set for oral argument before the Board.
`
`
`
`
`
`Dated: April 8, 2013
`
`Respectfully submitted,
`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
`
`Attorneys for Petitioner Liberty Mutual
`Insurance Co.
`
`
`
`
`
`
`
`
`
`-2-
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that the foregoing PETITIONER’S LIST OF
`
`PROPOSED MOTIONS was served on April 8, 2013, to the following Counsel for
`
`Patent Owner via e-mail, pursuant to the parties’ agreement concerning service:
`
`Calvin P. Griffith, Lead Counsel
`James L. Wamsley, III
`John V. Biernacki
`JONES DAY
`North Point
`901 Lakeside Avenue
`Cleveland, Ohio 44114-1190
`cpgriffith@jonesday.com
`jlwamsleyiii@jonesday.com
`jvbiernacki@jonesday.com
`
`Attorneys for Patent Owner
`Progressive Casualty Insurance Co.
`
`
`
`
`
` /s/ Darrell W. Stark
`Darrell W. Stark
`
`ROPES & GRAY LLP
`
`
`
`
`
`
`-3-
`
`
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