`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`APPLE INC.,
`
`Petitioner,
`
`v.
`
`SMARTFLASH LLC,
`
`Patent Owner.
`
`____________
`
`Case CBM2015-00033
`
`Patent 8,336,772 B2
`
`____________
`
`PATENT OWNER’S LIST OF PROPOSED MOTIONS
`
`
`
`Case CBM2015-00033
`Patent 8,336,772 B2
`
`
`The Patent Trial and Appeal Board (“Board”) has scheduled an initial
`
`conference call for Monday, June 29, 2015 at 2 PM. Paper 12 at 6. Pursuant to the
`
`Office Patent Trial Practice Guide, 77 Fed. Reg. 48756, 48765-66 (Aug. 14, 2012),
`
`Patent Owner submits the following list of proposed motions it anticipates filing
`
`during the trial. This list is provided without prejudice to Patent Owner’s right to
`
`seek authorization to file additional motions or to decide not to file the motions
`
`listed.
`
`1. Motion to Compel Routine Discovery
`
`Patent Owner anticipates filing a Motion to Compel Routine Discovery to
`
`compel the production of Apple’s litigation filings and reports relating to non-
`
`infringement and non-infringing alternatives that should have been served by
`
`Petitioner Apple concurrently with its Corrected Petition under to 37 CFR §
`
`42.51(b)(1)(iii).
`
`2. Motion to Permit Coordination of Deposition Transcripts
`
`Petitioner filed a declaration in this proceeding and in multiple other
`
`proceedings by the same declarant, Mr. Anthony J. Wechselberger. Patent Owner
`
`anticipates filing a Motion to Permit Coordination of Deposition Transcripts, if
`
`necessary, seeking the Board’s permission (as was permitted in earlier CBM
`
`proceedings on patents in the same patent family) to allow a single deposition to be
`
`
`
`2
`
`
`
`Case CBM2015-00033
`Patent 8,336,772 B2
`taken of the declarant (and future declarants) such that a single deposition
`
`transcript can be used in all proceedings (albeit filed separately in each
`
` /
`
` 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
`
`
`
`3
`
`proceeding).
`
`Dated: June 25, 2015
`
`
`
`
`
`
`
`
`
`
`Case CBM2015-00033
`Patent 8,336,772 B2
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that this PATENT OWNER’S LIST OF
`
`PROPOSED MOTIONS in CBM2015-00033 was served today, June 25, 2015, by
`
`agreement of the parties by emailing a copy to counsel for the Petitioner as
`
`follows:
`
`
`
`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
`
` /
`
` 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
`
`
`
`Dated: June 25, 2015
`
`4
`
`
`
`
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