`By: Brenton R. Babcock
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`Ted M. Cannon
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`KNOBBE, MARTENS, OLSON & BEAR, LLP
`2040 Main Street, 14th Floor
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`Irvine, CA 92614
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`Tel.: (949) 760-0404
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`Fax: (949) 760-9502
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`Email: BoxGSN@Knobbe.com
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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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`Game Show Network, LLC and WorldWinner.com, Inc.,
`Petitioners,
`v.
`Patent Owner of
`U.S. Patent 6,174,237 to Stephenson
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`Case IPR2013-00289
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`PETITIONERS’ PROPOSED MOTIONS
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`IPR2013-00289
`GSN v. Stephenson
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`Pursuant to the Decision Instituting Trial (Paper 8) and the Office Trial
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`Practice Guide, 77 Fed. Reg. 48756 at 48765-66, Petitioners Game Show
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`Network, LLC and WorldWinner.com, Inc. (collectively “GSN”) hereby raise
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`the
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`following
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`issue regarding proposed motions
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`that are currently
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`contemplated for filing by GSN during this proceeding.
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`GSN may seek authorization at a later date to file motions requesting
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`discovery related to factual issues that may be raised by Patent Owner in
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`its Response to the Petition for Inter Partes Review, including, but not
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`limited to, factual issues concerning objective indicia (or secondary
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`considerations) of non-obviousness (with respect to claims for which
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`obviousness is an issue in this proceeding).
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`GSN raises the above issue without prejudice to GSN’s right to seek
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`authorization to bring additional motions as circumstances may warrant
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`during this proceeding.
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`Respectfully submitted,
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`KNOBBE, MARTENS, OLSON & BEAR, LLP
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` By:/Brenton R. Babcock/
`Brenton R. Babcock, Reg. No. 39,592
`Ted M. Cannon, Reg No. 55,036
`Email: BoxGSN@Knobbe.com
`Attorneys for Petitioners
`Game Show Network, LLC and
`WorldWinner.com, Inc.
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`- 1 -
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`Dated: December 6, 2013
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`IPR2013-00289
`GSN v. Stephenson
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and correct copy of PETITIONERS’
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`PROPOSED MOTIONS is being served on December 6, 2013, via email
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`pursuant to 37 C.F.R. § 42.6(e) per agreement of the parties, to counsel for
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`Stephenson at the email address set forth below:
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`VIA EMAIL
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`MERCHANT & GOULD P.C.
`P.O. Box 2903
`Minneapolis, MN 55402-0903
`docket@merchantgould.com
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`Dated: December 6, 2013
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`/Brenton R. Babcock/
`Brenton R. Babcock
`Reg. No. 39,592
`Attorney for Petitioners
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`16800379