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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., DELL INC., SONY CORPORATION OF AMERICA,
`and HEWLETT-PACKARD CO.
`Petitioners
`
`v.
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`NETWORK-1 SECURITY SOLUTIONS, INC.
`Patent Owner
`____________________
`
`CASE IPR2013-00071
`U.S. Patent No. 6,218,930
`____________________
`
`Before the Honorable Joni Y. Chang, Justin T. Arbes, and Glenn J. Perry
`____________________
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`NOTICE OF DEPOSITION OF DECLARANT
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`Notice of Deposition of Declarant
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`IPR2013-00071
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`The Patent Owner has indicated that it expects to submit a second
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`declaration from Dr. James Knox in support of a Patent Owner’s Reply to Avaya’s
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`Opposition to Patent Owner’s Motion to Amend, which is due on November 14,
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`2013. In view of the shortened timeframe by which Petitioner is to provide its
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`observations on cross examination and any motions to exclude (Scheduled Due
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`Date No. 4), and in order to provide the required notice period, in the event such a
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`declaration is filed and the declarant is Dr. James Knox, Petitioner Avaya Inc.
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`hereby provides notice, pursuant to 37 C.F.R. § 42.53, that it will cross-examine
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`Dr. Knox on November 25, 2013. Further, in the event such a declaration is filed
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`by someone other than Dr. James Knox, Petitioner Avaya Inc. hereby provides
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`notice that it will cross-examine any such other declarant on November 25, 2013.
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`In accordance with 37 C.F.R. § 42.53(d)(1), the parties have conferred on a
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`date for the cross-examination, but to date Patent Owner has not offered any date
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`within the discovery period prior to Scheduled Due Date No. 4. Unless otherwise
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`indicated by the Patent Owner in advance, the location of the deposition, if and
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`when it occurs, will be held at the office of Dovel & Luner LLP, located at 201
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`Santa Monica Boulevard, Suite 600, Santa Monica, CA 90401. The deposition
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`will be recorded at least by audiotape and/or stenographic means by a court
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`reporter licensed to administer oaths.
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`2
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`Notice of Deposition of Declarant
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`IPR2013-00071
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`In accordance with 37 C.F.R. § 42.53(d)(4), this Notice is being provided no
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`later than 10 business days prior to the deposition.
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`Respectfully submitted,
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`November 8, 2013
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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
`Attorneys for Petitioner Avaya Inc.
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`3
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`Notice of Deposition of Declarant
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`IPR2013-00071
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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 8th day of November 2013, a true and correct
`copy of the foregoing “NOTICE OF DEPOSITION OF DECLARANT” was
`served, by electronic mail, upon the following:
`
`Robert G. Mukai
`Charles F. Wieland III
`BUCHANAN, INGERSOLL & ROONEY
`P.C.
`1737 King St., Suite 500
`Alexandria, VA 22314
`Robert.Mukai@BIPC.com
`Charles.Wieland@BIPC.com
`Counsel for Network-1 Security Solutions, Inc.
`
`Lionel M. Lavenue, Esq.
`Erika Arner, Esq.
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`Two Freedom Square
`11955 Freedom Drive
`Reston, VA 20190-5675
`(571) 203-2700
`lionel.lavenue@finnegan.com
`erika.arner@finnegan.com
`Counsel for Sony Corp. of America
`
`Michael J. Scheer
`Thomas M. Dunham
`WINSTON & STRAWN LLP
`200 Park Ave.
`New York, NY 10166
`(212) 294-4700
`mscheer@winston.com
`tdunham@winston.com
`Counsel for Dell Inc.
`
`Robert J. Walters, Esq.
`Charles J. Hawkins, Esq.
`MCDERMOTT WILL & EMERY LLP
`500 North Capitol Street, N.W.
`Washington, DC 20001
`(202) 756-8019
`rwalters@mwe.com
`chawkins@mwe.com
`Counsel for Hewlett-Packard Co.
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`Respectfully submitted,
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`November 8, 2013
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` /Jonathan M. Lindsay/
`Jonathan M. Lindsay, Reg. No. 45,810
`CROWELL & MORING LLP
`Intellectual Property Group
`1001 Pennsylvania Avenue, N.W.
`Washington, DC 20004-2595
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`4
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