`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`
`APPLE INC.
`Petitioner
`
`v.
`
`CONTENTGUARD HOLDINGS, INC.
`Patent Owner
`____________________
`
`Case CBM 2015-00160
`
`U.S. Patent 7,774,280
`Filed October 4, 2004
`Issued August 10, 2010
`Title: SYSTEM AND METHOD FOR MANAGING TRANSFER
`OF RIGHTS USING SHARED STATE VARIABLES
`
`____________________
`
`Attorney Docket No. 20318-134361
`Customer No: 22242
`____________________
`
`
`
`
`CONTENTGUARD HOLDINGS INC.’S RESPONSE TO
`PETITIONER’S MOTION FOR JOINDER TO CBM2015-00040
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`
`
`
`
`Case CBM2015-00160 for
`U.S. Patent No. 7,774,280
`
`In response to Petitioner Apple’s Motion for Joinder (Paper No. 2), Patent
`
`Owner ContentGuard Holdings, Inc. (“ContentGuard”) provides its position as
`
`directed by the panel via Paralegal Operations Manager Maria Vignone’s e-mail to
`
`counsel of August 24, 2015. Ms. Vignone’s e-mail directed Patent Owner
`
`ContentGuard Holdings, Inc.
`
`to “file a paper
`
`indicating
`
`the following:
`
`(1) ContentGuard does not oppose the Motion for Joinder provided the conditions
`
`[previously specified by ContentGuard to Apple] are acceptable to the panel; and
`
`(2) ContentGuard elects to waive filing a Preliminary Response.”
`
`ContentGuard does not oppose Apple’s motion to join CBM2015-00040
`
`subject to the conditions: (1) the current schedule remains in place; (2) discovery is
`
`limited to the scope previously agreed to by ContentGuard and Google, namely the
`
`cross-examination depositions of experts; and (3) Apple’s participation in briefing,
`
`depositions, and oral argument is limited to sharing the briefing and time allotted
`
`to Google. ContentGuard also consents to Apple participating as a full party,
`
`subject to the same conditions, in the event that Google ends its participation.
`
`In view of the above, and to allow the Board to issue a decision on joinder
`
`and the Petition, ContentGuard hereby waives its right to file a Preliminary
`
`Response in this proceeding, while reserving its right to do so if joinder is denied.
`
`
`
`
`
`
`
`1
`
`
`
`Case CBM2015-00160 for
`U.S. Patent No. 7,774,280
`
`
`
`
`Respectfully submitted,
`FITCH EVEN TABIN & FLANNERY, LLP
`
`Dated: August 25, 2015 By: /Timothy P. Maloney/
`
`
`Timothy P. Maloney
`
`Registration No. 38,233
`
`tim@fitcheven.com
`120 South LaSalle Street
`Suite 1600
`Chicago, Illinois 60603
`(312) 577-7000
`(312) 577-7007 (fax)
`
`
`
`2
`
`
`
`Case CBM2015-00160 for
`U.S. Patent No. 7,774,280
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the foregoing CONTENTGUARD
`
`HOLDINGS INC.’S RESPONSE TO PETITIONER’S MOTION FOR JOINDER
`
`TO CBM2015-00040 was served electronically via email on August 25, 2015, in
`
`their entireties on the following counsel of record for Petitioner:
`
`Michael R. Franzinger
`Reg. No. 46,355
`Sidley Austin LLP
`1501 K Street, N.W.
`Washington, DC 20005
`iprnotices@sidley.com
`(202) 736-8583
`
`Thomas A. Broughan, III
`Reg. No. 66,001
`Sidley Austin LLP
`1501 K Street, N.W.
`Washington, DC 20005
`iprnotices@sidley.com
`(202) 736-8314
`
`By:
`
`Respectfully submitted,
`FITCH EVEN TABIN & FLANNERY LLP
`/Timothy P. Maloney/
`
`Timothy P. Maloney
`Registration No. 38,233
`tim@fitcheven.com
`Lead Counsel for Patent Owner
`
`Jeffrey P. Kushan
`Reg. No. 43,401
`Sidley Austin LLP
`1501 K Street, N.W.
`Washington, DC 20005
`iprnotices@sidley.com
`(202) 736-8914
`
`
`
`
`Dated: August 25, 2015
`
`
`
`
`120 South LaSalle Street
`Suite 1600
`Chicago, Illinois 60603
`(312) 577-7000
`(312) 577-7007 (fax)
`
`
`
`3
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