`
`STATES PATENT AND TRADEMARK OFFICE
`
`Trial No.:
`
`IPR 2013-00083
`
`In re:
`
`US. Patent No. 6,415,280
`
`Patent Owners:
`
`PersonalWeb Technologies, LLC & Level 3 Communications
`
`Petitioner:
`
`EMC Corporation & \/Mware, Inc.
`
`Inventors:
`
`David A. Farber and Ronald D. Lachman
`
`For:
`
`IDENTIFYING AND REQUESTING DATA IN NETWORK USING
`IDENTIFIERS WHCH ARE BASED ON CONTENTS OF DATA
`
`>l<
`
`>l<
`
`>l<
`
`*
`
`>l<
`
`>l<
`
`>!<
`
`>5<
`
`*
`
`>l<
`
`*
`
`May 30, 2013
`
`PATENT OWNER’S INITIAL LIST OF PROPOSED MOTIONS FOR
`DISCUSSION DURING INITIAL CONFERENCE CALL
`
`An initial conference call is scheduled in this matter for Monday, June 3,
`
`2013, at 2:00 pm. Patent Owner submits this initial listing of proposed motions
`
`which it may bring during this trial. This listing is without prejudice to Patent
`
`Owner’s right to seek authorization to bring additional motions, or to decide not to
`
`bring motions as indicated, as circumstances may warrant.
`
`1. Motion for Modification of Scheduling Order -— depending at least upon
`
`whether petitioner submits additional information and the nature of such
`
`additional information.
`
`1
`
`2020057
`
`
`
`2. Motion for Discovery ~ depending at least upon whether petitioner
`
`submits additional information and the nature of such additional
`
`information.
`
`3. Motion to Exclude Under Rule 42.64.
`
`4. Motion for Observations on Cross—Examination —— if applicable.
`
`5. Motion to Seal regarding Confidential Information.
`
`6. Motion for admission pro hac vice for one additional attorney.
`
`Patent owner would also like to discuss how to coordinate discovery
`
`between the six IPRS: 2013-00082, 00083, 00084, 00085, 00086, and 00087.
`
`Patent owner also desires to file opposition(s), if appropriate, to motions
`
`filed by petitioner as permitted under the Rules.
`
`Respectfully submitted,
`
`NIXON & VANDERHYE P.C.
`
`By:
`
`/Joseph A. Rhoa/
`Joseph A. Rhoa
`Reg. No. 37,515
`Updeep (Mickey) S. Gill
`Reg. No. 37,334
`Counsel for Patent Owner PersonalWeb
`
`2020057
`
`JAR:caj
`Nixon & Vanderhye, PC
`901 North Glebe Road, 11th Floor
`Arlington, VA 22203— l 808
`Telephone: (703) 816-4000
`Facsimile: (703) 816-4100
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify service of the foregoing Patent Owner’s Initial List of
`
`Proposed Motions for Discussion During Initial Conference Call to the following
`
`lead counsel for petitioner on May 30, 2013 Via email (pursuant to agreement
`
`between the parties):
`
`Peter M. Dichiara
`
`WilmerHale
`
`60 State Street
`
`Boston, MA 02109
`(peter.dichiara@wilrnerhale.com)
`
`By:
`
`/Joseph A. Rhoa/
`Joseph A. Rhoa
`Reg. No. 37,515
`
`2020057
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
