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Filed on behalf of Game Show Network, LLC and WorldWinner.com, Inc.
`By: Brenton R. Babcock
`
`Ted M. Cannon
`
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`2040 Main Street, 14th Floor
`
`
`Irvine, CA 92614
`
`Tel.: (949) 760-0404
`
`Fax: (949) 760-9502
`
`Email: BoxGSN@Knobbe.com
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________
`
`Game Show Network, LLC and WorldWinner.com, Inc.,
`Petitioners,
`v.
`Patent Owner of
`U.S. Patent 6,174,237 to Stephenson
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Case IPR2013-00289
`
`
`
`
`
`
`
`
`
`
`PETITIONERS’ PROPOSED MOTIONS
`
`
`
`
`
`
`
`
`
`
`
`

`
`IPR2013-00289
`GSN v. Stephenson
`
`
`
`Pursuant to the Decision Instituting Trial (Paper 8) and the Office Trial
`
`Practice Guide, 77 Fed. Reg. 48756 at 48765-66, Petitioners Game Show
`
`Network, LLC and WorldWinner.com, Inc. (collectively “GSN”) hereby raise
`
`the
`
`following
`
`issue regarding proposed motions
`
`that are currently
`
`contemplated for filing by GSN during this proceeding.
`
`
`
`GSN may seek authorization at a later date to file motions requesting
`
`discovery related to factual issues that may be raised by Patent Owner in
`
`its Response to the Petition for Inter Partes Review, including, but not
`
`limited to, factual issues concerning objective indicia (or secondary
`
`considerations) of non-obviousness (with respect to claims for which
`
`obviousness is an issue in this proceeding).
`
`
`
`GSN raises the above issue without prejudice to GSN’s right to seek
`
`authorization to bring additional motions as circumstances may warrant
`
`during this proceeding.
`
`Respectfully submitted,
`
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`
`
` 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.
`
`- 1 -
`
`
`
`
`
`
`
`Dated: December 6, 2013
`
`

`
`IPR2013-00289
`GSN v. Stephenson
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of PETITIONERS’
`
`PROPOSED MOTIONS is being served on December 6, 2013, via email
`
`pursuant to 37 C.F.R. § 42.6(e) per agreement of the parties, to counsel for
`
`Stephenson at the email address set forth below:
`
`VIA EMAIL
`
`MERCHANT & GOULD P.C.
`P.O. Box 2903
`Minneapolis, MN 55402-0903
`docket@merchantgould.com
`
`
`
`Dated: December 6, 2013
`
`
`
`/Brenton R. Babcock/
`Brenton R. Babcock
`Reg. No. 39,592
`Attorney for Petitioners
`
`
`
`16800379

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