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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`RAYMARINE, INC.
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`Petitioner
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`V.
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`NAVICO HOLDING AS
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`Patent Owner
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`Case IPR2013—00355
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`Patent 8,305,840
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`Before SALLY C. MEDLEY, Administrative Patent Judge.
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`PATENT OWNER’S NOTICE OF MOTIONS
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`The initial conference call in this matter is set for January 9, 2014, at 1:30
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`pm. Eastern Time. Pursuant to the instructions for initial conference calls set forth
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`in the Trial Practice Guide, Patent Owner Navico Holding AS gives notice that it
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`does not presently intend to file a motion to amend the claims, but reserves the
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`right to request authorization to file such a motion by Due Date 1.
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`Patent Owner hereby requests authorization to file the following:
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`1. Motion to disqualify Martin Klein and Paul Stokes as expert witnesses, to
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`include striking their improperly generated reports.
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`2. Motion to submit for in camera review certain papers relating to motion
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`(1).
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`3. Motion for additional discovery.
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`January 7,2014
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`Date
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`Respectfully Submitted,
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`8Q 92 _i__'.\___
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`Christopher TL Douglas
`Reg. No. 56,950
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`
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`Inter Partes Review of US. Patent No. 8,3 05 ,840 - IPR2013-00355
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`Certificate of Service
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`Pursuant to 37 C.F.R. § 42.6(6), the undersigned hereby certifies service on
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`the Petitioner of a copy of this notice of motions via electronic delivery directed to
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`davidmccombs.iprthaynesboonecom and first class mail directed to the
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`corresponding address for lead counsel, as submitted in the Petition for Inter
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`Partes Review:
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`David L. McCombs
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`HAYNES AND BOONE, LLP
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`2323 Victory Ave.
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`Suite 700
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`Dallas, TX 75219
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` Dated: January 7, 2014
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`Christopher TL Douglas
`Reg. No. 56,950
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