`Patent No. 5,832,494
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________
`FACEBOOK, INC., LINKEDIN CORP., and TWITTER, INC.,
`Petitioners
`v.
`SOFTWARE RIGHTS ARCHIVE, LLC
`Patent Owner
`
`
`Patent No. 5,832,494
`Issue Date: November 3, 1998
`Title: METHOD AND APPARATUS FOR INDEXING,
`SEARCHING AND DISPLAYING DATA
`
`________________
`
`Inter Partes Review No. IPR2013-00479
`
`
`PETITIONERS’ LIST OF PROPOSED MOTIONS
`
`
`
` 1218902
`
`
`
`Case IPR2013-00479
`Patent No. 5,832,494
`
`
`Petitioners Facebook, Inc., LinkedIn Corp., and Twitter, Inc. (“Petitioners”)
`
`respectfully identify the following motions that Petitioners currently anticipate they might file,
`
`pursuant to Office Trial Practice Guide 77 Fed. Reg. 48756 at 48765-66.
`
`
`
`Motion To Submit Supplemental Information (37 C.F.R. § 42.123)
`
`Petitioners understand that they need not file any motion to serve and file
`
`supplemental evidence pursuant to 37 C.F.R. § 42.64(b)(2) in response to the Patent
`
`Owner’s evidentiary objections. To the extent any authorization by the Board were deemed
`
`necessary or appropriate for Petitioners to file the supplemental evidence, Petitioners
`
`reserve the right to seek such authorization.
`
`
`
`Motion For the Imposition of Sanctions (37 C.F.R. § 42.12)
`
`Petitioners do not lightly raise the issue of sanctions, and hope that no motion
`
`relating to sanctions will be necessary. However, the Patent Owner filed numerous
`
`evidentiary objections that do not have any objectively reasonable basis. The parties
`
`subsequently conferred and the Patent Owner has withdrawn many of the objections.
`
`However, the Patent Owner still maintains numerous objections that will require Petitioners
`
`to incur substantial time and expense to respond. To the extent the Patent Owner declines
`
`to withdraw evidentiary objections that do not have any objectively reasonable basis,
`
`thereby requiring Petitioners to incur unnecessary costs to respond, Petitioners reserve the
`
`right to request that the Board impose appropriate sanctions under 37 C.F.R. § 42.12.
`
`Petitioners further reserve the right to request any motions that may become
`
`1
`
`
`
`Case IPR2013-00479
`Patent No. 5,832,494
`
`appropriate in view of any further events or submissions in these proceedings.
`
`Respectfully submitted,
`
`/Heidi L. Keefe/
`Heidi L. Keefe
`Reg. No. 40,673
`Counsel for Petitioners Facebook, Inc,
`LinkedIn Corp., and Twitter Inc.
`
`
`
`
`
`
`
`DATED: February 24, 2014
`
`COOLEY LLP
`ATTN: Heidi L. Keefe
`Patent Docketing
`1299 Pennsylvania Ave. NW
`Suite 700
`Washington, D.C. 20004
`Tel: (650) 843‐5001
`Fax: (650) 849‐7400
`
`
`2
`
`
`
`CERTIFICATE OF SERVICE
`
`Case IPR2013-00479
`Patent No. 5,832,494
`
`
`
`
`I hereby certify, pursuant to 37 CFR sections 42.6(e), that a complete copy
`of the attached PETITIONERS’ LIST OF PROPOSED MOTIONS is being served via
`electronic service at the email address noted below on the 24th day of February,
`2014, the same day as the filing of the above‐identified document in the United
`States Patent and Trademark Office/Patent Trial and Appeal Board, upon the
`patent owner’s attorneys of record:
`
`Martin M. Zoltick
`ROTHWELL, FIGG, ERNST & MANBECK, P.C.
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
`E‐mail: SRA‐IPR@rfem.com
`
`
`/ Heidi L. Keefe /
`Heidi L. Keefe
`Reg. No. 40,673
`
`
`
`3
`
`
`
`
`
`COOLEY LLP
`ATTN: Heidi L. Keefe
`Patent Docketing
`1299 Pennsylvania Ave. NW
`Suite 700
`Washington, D.C. 20004
`Tel: (650) 843‐5001
`Fax: (650) 849‐7400
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
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.
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.
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
