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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_______________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_______________________________
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`AVAYA INC.
`Petitioner
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`v.
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`NETWORK-1 SECURITY SOLUTIONS, INC.
`Patent Owner
`____________________
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`CASE IPR2013-00071
`U.S. Patent No. 6,218,930
`____________________
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`Before the honorable Jameson Lee, Joni Y. Chang, and Justin T. Arbes
`____________________
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`PETITIONER’S LIST OF PROPOSED MOTIONS
`PRIOR TO INITIAL CONFERENCE CALL
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`An initial conference call is scheduled for 2:00 PM Eastern Time on
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`Petition for Inter Partes Review of
`U.S. Patent No. 6,218,930
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`Tuesday, June 18, 2013. Pursuant to the Decision of the Board to institute inter
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`partes review (Paper 18) and Office Patent Trial Practice Guide, 77 Fed. Reg.
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`48756, 48765-66 (Aug. 14, 2012), Petitioner identifies the following motions that
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`it may file during the trial, depending upon positions taken by Patent Owner:
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`• Motions Requesting Discovery Pursuant to 37 CFR § 42.51(b);
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`• Motions to Submit Supplemental Information Pursuant to 37 CFR §§
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`42.64(b)(2), 42.123;
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`• Motions to Exclude Evidence Pursuant to 37 CFR § 42.64(c); and
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`• Motions for Observation on Cross-Examination Pursuant to 37 CFR § 42.20.
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`To the extent necessary – given that Petitioner is not aware of what
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`amendments, remarks, and evidence Patent Owner may present – Petitioner
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`reserves the right to request permission to file additional motions as appropriate.
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`June 14, 2013
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`Respectfully submitted,
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` /Jonathan M. Lindsay/
`Jeffrey D. Sanok, Reg. No. 32,169
`Jonathan M. Lindsay, Reg. No. 45,810
`CROWELL & MORING LLP
`Intellectual Property Group
`P.O. Box 14300
`Washington, DC 20044-4300
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`Page 2 of 2
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6(e)
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`I hereby certify that on this 14th day of June 2013, a true and correct copy of
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`the foregoing “PETITIONER’S LIST OF PROPOSED MOTIONS PRIOR TO
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`INITIAL CONFERENCE CALL” was served, in accordance with the parties’
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`electronic service agreement, by electronic mail upon the following lead and
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`backup counsel of record for the Patent Owner:
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`Robert G. Mukai, Lead Counsel
`Buchanan, Ingersoll & Rooney P.C.
`1737 King St., Suite 500
`Alexandria, VA 22314
`Service E-mail: Robert.Mukai@BIPC.com
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`Charles F. Wieland III, Back-up Counsel
`Buchanan, Ingersoll & Rooney P.C.
`1737 King St., Suite 500
`Alexandria, VA 22314
`Service E-mail: Charles.Wieland@BIPC.com
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`Respectfully submitted,
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`June 14, 2013
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`DCACTIVE-23638574.1
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`
` /Jonathan M. Lindsay/
`Jonathan M. Lindsay, Reg. No. 45,810
`(Back-up Counsel)
`CROWELL & MORING LLP
`Intellectual Property Group
`1001 Pennsylvania Avenue, N.W.
`Washington, DC 20004-2595
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