`Filed: February 11, 2014
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`CARDIOCOM, LLC
`Petitioner
`v.
`ROBERT BOSCH HEALTHCARE SYSTEMS, INC.
`Patent Owner
`_____________________
`CASE NO. IPR2013-00468
`Patent No. 7,516,1921
`_____________________
`
`Patent Owner’s Notice Regarding Proposed Motions
`
`1 Case No. IPR2013-00469 has been joined with this proceeding.
`
`OHSUSA:756416714.1
`
`Page 1 of 4
`
`
`
`Paper No. 29
`Filed: February 11, 2014
`
`The initial conference call for this trial is scheduled for February 13, 2014.
`Further to the Board’s Decision (Paper No. 22, January 28, 2014) instituting inter
`partes review of U.S. Patent 7,516,192, Patent Owner Robert Bosch Healthcare
`Systems, Inc., gives notice that it is considering filing the following motions:
`1. Motion for Routine Discovery
`2. Motion for Additional Discovery
`3. Motion to File Supplemental Evidence
`4. Motion to Exclude Evidence
`5. Motion to Permit Videorecording of Depositions and Use of Videorecorded
`Testimony
`Patent Owner would also like to confirm that joinder of IPR2013-00469 with
`this IPR does not substantively impact Patent Owner’s rights by, for example,
`changing the page limits to which Patent Owner would otherwise be entitled for
`these two joined proceedings.
`The above list is not intended to exclude other motions the Patent Owner may
`consider filing at a later date, for example a Motion to Amend Claims. Patent Owner
`will seek guidance and authorization from the Board, if required, should the need
`arise for filing further motions.
`
`Respectfully submitted,
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`
`Dated: February 11, 2014
`
`OHSUSA:756416714.1
`
`By: /s/ Don Daybell
`Don Daybell
`Reg. No. 50,877
`Davin M. Stockwell
`Reg. No. 41,334
`Orrick, Herrington & Sutcliffe LLP
`2050 Main Street, Suite 1100
`Irvine, CA 92614-8255
`Page 2 of 4
`
`
`
`Paper No. 29
`Filed: February 11, 2014
`
`Tel: 949-567-6700
`Fax: 949-567-6710
`Customer Number: 34313
`
`Counsel for Robert Bosch Healthcare
`Systems, Inc.
`
`OHSUSA:756416714.1
`
`Page 3 of 4
`
`
`
`Paper No. 29
`Filed: February 11, 2014
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 11th day of February 2014, a copy of Patent
`
`Owner’s Notice Regarding Proposed Motions was served by electronic mail upon
`
`the following counsel for Cardiocom, LLC:
`
`Daniel W. McDonald
`Andrew J. Lagatta
`Merchant & Gould, P.C.
`80 South 8th Street, Suite 3200
`Minneapolis, MN 55402
`email: dmcdonald@merchantgould.com
`alagatta@merchantgould.com
`
`Dated: February 11, 2014
`
`By:
`
`/s/ Sally Hartwell
`Sally Hartwell
`
`OHSUSA:756416714.1
`
`Page 4 of 4
`
`
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