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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`APPLE INC.,
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`Petitioner,
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`v.
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`SMARTFLASH LLC,
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`Patent Owner.
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`____________
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`Case CBM2015-00032
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`Patent 8,336,772 B2
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`____________
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`PATENT OWNER’S LIST OF PROPOSED MOTIONS
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`Case CBM2015-00032
`Patent 8,336,772 B2
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`The Patent Trial and Appeal Board (“Board”) has scheduled an initial
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`conference call for Monday, June 29, 2015 at 2 PM. Paper 12 at 6. Pursuant to the
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`Office Patent Trial Practice Guide, 77 Fed. Reg. 48756, 48765-66 (Aug. 14, 2012),
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`Patent Owner submits the following list of proposed motions it anticipates filing
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`during the trial. This list is provided without prejudice to Patent Owner’s right to
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`seek authorization to file additional motions or to decide not to file the motions
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`listed.
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`1. Motion to Compel Routine Discovery
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`Patent Owner anticipates filing a Motion to Compel Routine Discovery to
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`compel the production of Apple’s litigation filings and reports relating to non-
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`infringement and non-infringing alternatives that should have been served by
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`Petitioner Apple concurrently with its Corrected Petition under to 37 CFR §
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`42.51(b)(1)(iii).
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`2. Motion to Permit Coordination of Deposition Transcripts
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`Petitioner filed a declaration in this proceeding and in multiple other
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`proceedings by the same declarant, Mr. Anthony J. Wechselberger. Patent Owner
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`anticipates filing a Motion to Permit Coordination of Deposition Transcripts, if
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`necessary, seeking the Board’s permission (as was permitted in earlier CBM
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`proceedings on patents in the same patent family) to allow a single deposition to be
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`2
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`Case CBM2015-00032
`Patent 8,336,772 B2
`taken of the declarant (and future declarants) such that a single deposition
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`transcript can be used in all proceedings (albeit filed separately in each
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` /
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` Michael R. Casey /
`
`
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist Jackson & Gowdey, LLP
`8300 Greensboro Drive
`Suite 500
`McLean, VA 22102
`Telephone: (571) 765-7705
`Fax: (571) 765-7200
`Email: mcasey@dbjg.com
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`3
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`proceeding).
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`Dated: June 25, 2015
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`Case CBM2015-00032
`Patent 8,336,772 B2
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that this PATENT OWNER’S LIST OF
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`PROPOSED MOTIONS in CBM2015-00032 was served today, June 25, 2015, by
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`agreement of the parties by emailing a copy to counsel for the Petitioner as
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`follows:
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`
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`J. Steven Baughman (steven.baughman@ropesgray.com)
`Ching-Lee Fukuda (ching-lee.fukuda@ropesgray.com)
`Megan Raymond (megan.raymond@ropesgray.com)
`ApplePTABService-SmartFlash@ropesgray.com
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`
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` /
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` Michael R. Casey /
`
`
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist Jackson & Gowdey, LLP
`8300 Greensboro Drive
`Suite 500
`McLean, VA 22102
`Telephone: (571) 765-7705
`Fax: (571) 765-7200
`Email: mcasey@dbjg.com
`Attorney for Patent Owner
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`
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`Dated: June 25, 2015
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`4
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