`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`DELL INC.,
`Petitioner
`
`v.
`
`NETWORK-1 SECURITY SOLUTIONS, INC.,
`Patent Owner
`
`
`CASE IPR: IPR2013-00385
`
`
`
`DELL’S NOTICE OF WITHDRAWAL OF ITS GROUND 3
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`Dell’s Notice of Withdrawal of its Ground 3 (IPR2013-00385)
`
`In view of the Board’s recent denial of Petitioner Avaya Inc.’s Request for
`
`Rehearing on the subject matter of its Ground 5 (that the combination of the Chang
`
`and De Nicolo references renders obvious claims 6 and 9 of U.S. Patent No.
`
`6,218,930) (Paper No. 32, IPR2013-00071), Dell Inc. (“Dell”) hereby withdraws
`
`from consideration its Ground 3, which was substantively identical to Avaya’s
`
`Ground 5.1 Dell’s Grounds 1 and 2 remain pending and are not withdrawn.
`
`
`
`Respectfully submitted,
`
`Date: July 9, 2013
`
`
`
`WINSTON & STRAWN LLP
`200 Park Ave.
`New York, NY 10166
`Telephone: (212) 294-3325
`Fax: (202) 282-5100
`mscheer@winston.com
`
`/Michael J. Scheer/
`Michael J. Scheer
`Reg. No. 34,425
`
`Lead Counsel for Petitioner
`Dell Inc.
`
`
`1 Permission was given to file the instant paper by the Board staff in an e-mail
`
`received this morning stating “Counsel for Dell is authorized to file a one page
`
`notice stating the ground is withdrawn”.
`
`
`
`1
`
`
`
`
`
`Dell’s Notice of Withdrawal of its Ground 3 (IPR2013-00385)
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(a), this is to certify that on July
`
`9, 2013 I caused to be served a true and correct copy of the foregoing “DELL’S
`
`NOTICE OF WITHDRAWAL OF ITS GROUND 3” by EXPRESS MAIL on the
`
`Patent Owner at the correspondence address of record for the U.S. Patent No.
`
`6,218,930, as follows:
`
`BUCHANAN, INGERSOLL & ROONEY PC
`
`POST OFFICE BOX 1404
`
`ALEXANDRIA VA 22313-1404
`
`Date: July 9, 2013
`
`
`
`WINSTON & STRAWN LLP
`200 Park Ave.
`New York, NY 10166
`Telephone: (212) 294-3325
`Fax: (202) 282-5100
`mscheer@winston.com
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`/Michael J. Scheer/
`Michael J. Scheer
`Reg. No. 34,425
`
`Lead Counsel for Petitioner
`Dell Inc.
`
`
`
`