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`Docket No. PMC-006
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________
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`ZYNGA, INC.
`Petitioner
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`V.
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`PERSONALIZED MEDIA COMMUNICATIONS LLC
`Patent Owner
`___________________________
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`Case No. IPR2013-00164
`U.S. Patent No. 7,797,717
`___________________________
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`PATENT OWNER’S LIST OF PROPOSED MOTIONS
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`PETITIONER’S LIST OF PROPOSED MOTIONS
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`IPR2013-00164
`Patent No. 7,797,717 B1
`Atty. Docket: PMC-006
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`
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`In anticipation of the Initial Conference Call with the Patent Trial and
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`Appeal Board scheduled for August 27, 2013, Patent Owner Personalized Media
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`Communications, LLC (“PMC”) provides the following list of currently
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`contemplated motions pursuant to the Office Patent Trial Practice Guide, 77 Fed.
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`Reg. 48756, 48765-66 (Aug. 14, 2012):
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`1. If the need arises, a motion for discovery regarding secondary
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`considerations for non-obviousness;
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`2. If the need arises, a motion to amend the claims;
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`3. Motion to exclude evidence, should such a motion be considered
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`necessary later in the proceeding; and
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`4. Other motions as the occasion arises (PMC relies on the statement in
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`the Trial Practice Guide: “Submission of a list would not preclude the
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`filing of additional motions not contained in the list.” Id. at 48765).
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`Dated: August 23, 2013
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`Respectfully submitted,
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`By /Thomas J. Scott, Jr./
`Thomas J. Scott, Jr.
` Registration No.: 27,836
`GOODWIN PROCTER LLP
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`2
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`IPR2013-00164
`Patent No. 7,797,717 B1
`Atty. Docket: PMC-006
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`
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`901 New York Avenue, NW
`Washington, DC 20001
`(202) 346-4000
`Attorney for Patent Owner
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`3
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`IPR2013-00164
`Patent No. 7,797,717 B1
`Atty. Docket: PMC-006
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the:
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`PATENT OWNER’S LIST OF PROPOSED MOTIONS
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`filed herewith was served on:
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`David B. Cochran at dcochran@jonesday.com
`and
`Joseph M. Sauer at jmsauer@jonesday.com
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`pursuant to 37 C.F.R. § 42.8(e)(1) and the consent found in Section VI.C of the
`Petition (Paper No. 1) and repeated in the Section VI.C of the Supplemental
`Petition (Paper No. 4).
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`Dated: August 23, 2013
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`By:
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` /Thomas J. Scott, Jr./
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`4
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