throbber
Filed on behalf of Cardiocom, LLC
`
`By: Daniel W. McDonald (dmcdonald@merchantgould.com)
`Merchant & Gould P.C.
`3200 IDS Center
`80 South 8th Street
`Minneapolis, MN 55402
`Tel: (612) 332-5300
`Fax: (612) 332-9081
`
`
`
`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 IPR2013-004681
`Patent 7,516,192
`____________
`
`
`
`PETITIONER’S LIST OF ANTICIPATED
`AND POTENTIAL MOTIONS
`
`
`
`
` 1
`
`
`
` Case IPR2013-00469 has been joined with this proceeding.
`
`
`

`

`In preparation for the February 13, 2014 initial conference call as scheduled
`
`in this proceeding, and pursuant to the Office Patent Trial Practice Guide, 77 Fed.
`
`Reg. 48756, 48765-66 (Aug. 14, 2012), Petitioner Cardiocom LLC (“Cardiocom”)
`
`provides the following list of motions it currently is considering filing.
`
`This list is provided without prejudice to Petitioner’s right to seek
`
`authorization to file additional motions or to decide not to file motions listed.
`
`1. Motion for Additional Discovery pursuant to 37 C.F.R. § 42.51(b)(2);
`
`2. Motion to File Supplemental Information pursuant to 37 C.F.R. § 42.123;
`
`3. Motion to Exclude Evidence pursuant to 37 C.F.R. § 42.64; and
`
`4. A Motion to Permit the Video-Recording of Depositions and For Use of
`
`Video-Recorded Testimony Pursuant to 37 C.F.R. § 42.53(a).
`
`
`
`
`
`
`
`
`
`
`
`
`
`Date: February 11, 2014
`
`
`
`
`
`Respectfully submitted,
`
`MERCHANT & GOULD P.C.
`
`
`
`
`/Daniel W. McDonald/
`Daniel W. McDonald, Reg. No. 32,044
`Attorneys for Petitioner Cardiocom, LLC
`
`
`
`
`
`
`2
`
`

`

`Certification of Service
`
`Pursuant to 37 C.F.R § 42.6, the undersigned hereby certifies that a copy of
`
`this PETITIONER’S LIST OF ANTICIPATED AND POTENTIAL MOTIONS
`
`has been served on February 11, 2014, by email on counsel of record for the patent
`
`owner at the following name and address:
`
`Don Daybell (ddaybell@orrick.com)
`Davin M. Stockwell (dstockwell@orrick.com)
`Bas de Blank (basdeblank@orrick.com)
`Lillian Mao (lmao@orrick.com)
`ORRICK, HERRINGTON, &
`SUTCLIFFE LLP
`2050 Main St., Suite 1100
`Irvine, CA 92614
`Tel: 949-567-6700
`Fax: 949-567-6710
`
`
`
`Respectfully submitted,
`
`
`Date: February 11, 2014
`
`
`
`
`
`
`
`/Daniel W. McDonald/
`Daniel W. McDonald (Lead Counsel)
`USPTO Registration No. 32,044
`
`
`
`
`
`3
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket