`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`LIBERTY MUTUAL INSURANCE CO.
`Petitioner
`
`v.
`
`PROGRESSIVE CASUALTY INSURANCE CO.
`Patent Owner
`______________
`
`Cases CBM2012-00003, CBM2013-00004 & -00009
`Patent Nos. 8,090,598, & 8,140,358
`______________
`
`Before the Honorable JAMESON LEE, JONI Y. CHANG, and MICHAEL R.
`ZECHER, Administrative Patent Judges.
`
`PETITIONER LIBERTY MUTUAL INSURANCE CO.’S NOTICE OF
`DEPOSITION OF IVAN ZATKOVICH
`
`Pursuant to 37 C.F.R. § 42.53, Petitioner Liberty Mutual Insurance Co.
`
`
`
`(“Liberty Mutual”), by and through its attorneys will conduct cross-examination by
`
`deposition of Ivan Zatkovich.
`
` Mr. Zatkovich’s deposition will take place
`
`commencing at 9:00 AM EDT on July 15, 2013 and continuing from day-to-day if
`
`necessary, at the offices of Jones Day, North Point 901 Lakeside Avenue, Cleveland,
`
`OH 44114, or at such other time and place to which the parties may agree or which
`
`may be ordered by the Board.
`
`
`
`The cross-examination will be taken before a Notary Public or other officer
`
`authorized by law to administer oaths. It will be recorded using audiotape and/or by
`
`stenographic means. Liberty Mutual also intends to video record the cross-
`
`examination of Mr. Zatkovich. The arrangement for the reporter and videographer
`
`will be made by counsel for Liberty Mutual.
`
`
`
`
`
`July 8, 2013
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`ROPES & GRAY LLP
`
`
`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
`
`It
`
`is certified
`
`that a copy of PETITIONER LIBERTY MUTUAL
`
`
`
`
`
`INSURANCE CO.’S NOTICE OF DEPOSITION OF IVAN ZATKOVICH has
`
`been served in its entirety on the Patent Owner as provided in 37 CFR § 42.6.
`
`The copy has been served on July 8, 2013 by causing the aforementioned
`
`document to be electronically mailed to:
`
`Calvin P. Griffith, at: cpgriffith@jonesday.com
`
`James L. Wamsley, III at: jlwamsleyiii@jonesday.com
`
`John V. Biernacki at: jvbiernacki@jonesday.com
`
`pursuant to the Petitioner and Patent Owner’s agreement.
`
`
`
`
`
`
`
` /s/ Darrell W. Stark
`Darrell W. Stark
`
`ROPES & GRAY LLP
`
`
`
`
`
`3
`
`
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