`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`PRINTING INDUSTRIES OF AMERICA
`
`Petitioner
`
`v.
`
`CTP INNOVATIONS, LLC
`
`Patent Owner
`
`U.S. Patent No. 6,738,155 to Vogt et a1.
`
`IPR Trial No. 2013-00489
`
`NOTICE OF DEFECTIVE CERTIFICATE OF SERVICE
`
`OF CTP INNOVATIONS, LLC’S
`PRELIMINARY RESPONSE TO PETITION
`
`(Lead Counsel)
`John M. Adams
`Reg. No. 26,697
`
`Price & Adams, P.C.
`4135 Brownsville Road
`P.O. Box 98127
`
`15227-0127
`PA
`Pittsburgh,
`(412)882-7170
`Telephone No.
`(412)884-6650
`Facsimile No.
`Email:
`paip.law@verizon.net
`
`Lawrence G. Zurawsky (Back-up Counsel)
`Reg. No. 22,776
`
`Zurawsky & Associates
`429 Forbes Avenue, Suite 600
`Pittsburgh, PA
`15219
`Telephone No.
`(412)281-7766
`Facsimile No.
`(412)281-7769
`Email:
`szurawsky@ao1.com
`
`
`
`Petitioner, Printing Industries of America (“Petitioner”)
`
`brings to the Board's attention the failure of Patent Owner, CTP
`
`Innovations, LLC (“Patent Owner”)
`
`to serve its Preliminary
`
`Response to Petitioner’s Petition for Inter Partes Review of
`
`U.S. Patent No. 6,738,;55 (“the ‘l55 Patent”)
`
`in conformance
`
`with the Certificate of Service that was filed with the
`
`Preliminary Response to Petition.
`
`On October 4, 2013, Patent Owner filed its Preliminary
`
`Response to Petitioner's Petition for Inter Partes Review
`
`(“Preliminary Response”) of the ‘l55 patent.
`
`The Certificate of
`
`Service that was filed with the Preliminary Response indicated
`
`that the Preliminary Response was served on October 4, 2013 in
`
`its entirety by U.S. Express Mail, postage prepaid, and
`
`electronic mail upon Petitioner's Lead Counsel and Backwup
`
`Counsel.
`
`A copy of the Certificate of Service attached to
`
`Patent Owner's Preliminary Response is attached hereto as
`
`Exhibit
`
`l2l5.
`
`The Certificate of Service was electronically
`
`executed by Patent Owner's Lead Counsel W. Edward Ramage.
`
`Petitioner's Lead Counsel and Backwup Counsel did not
`
`receive Patent Owner’s Preliminary Response in accordance with
`
`the Certificate of Service.
`
`Lead Counsel received a copy of the
`
`Preliminary Response by U.S. Priority Mail on October 12, 2013.
`
`A copy of the front of the envelope containing the Preliminary
`
`
`
`Response addressed to and received by Petitioner's Lead Counsel
`
`is attached hereto as Exhibit 1216.
`
`The metered postage on the
`
`envelope indicates that it was posted in Nashville, Tennessee on
`
`October 9, 2013 by priority mail.
`
`Petitioner’s Back—up Counsel received a copy of Patent
`
`Owner's Preliminary Response on October 11, 20l3 by U.S.
`
`Priority Mail.
`
`A copy of the front of the envelope containing
`
`the Preliminary Response addressed to and received by
`
`Petitioner’s Back—up Counsel
`
`is attached hereto as Exhibit 1118.
`
`The metered postage on the envelope indicates that it was posted
`
`in Nashville, Tennessee on October 9, 2013 by priority mail.
`
`Notwithstanding the fact that Petitioner's Lead Counsel and
`
`Back~up Counsel received a copy of Patent Owner's Preliminary
`
`Response, Patent Owner did not execute service on the date nor
`
`in the manner of delivery as indicated on the Certificate of
`
`Service.
`
`The Preliminary Response was not served on October 4,
`
`2013 via U.S. Express Mail and electronic mail, as evidenced by
`
`Exhibits l216 and 1217.
`
`
`
`Accordingly, Petitioner requests that the Board take notice
`
`of Patent Owner’s failure to serve upon Petitioner's counsel
`
`the
`
`Preliminary Response in accordance with the Certificate of
`
`Service attached to the Preliminary Response and take whatever
`
`action is deemed appropriate against Patent Owner.
`
`Dated: December 3, 2013
`
`Respectfully submitted,
`
`PRICE & ADAMS
`
`By:/s/John M. Adams
`John M. Adams
`
`Registration No. 26,697
`Price & Adams, P.C.
`4135 Brownsville Road
`P.O. Box 98127
`
`PA
`Pittsburgh,
`Telephone No.
`
`l5227
`(412)882-7170
`
`Facsimile No.
`
`(412)884-6658
`
`Counsel for Petitioner,
`Printing Industries of
`America
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on December 3, 2013
`
`the foregoing Notice of Defective Certificate of Service of CT?
`
`Innovations, LLC’s Preliminary Response to Petition was served
`
`in its entirety via First Class, U.S. Mail upon the following:
`
`W. Edward Ramage(Lead Counsel)
`Baker, Donelson, Bearman,
`Caldwell
`& Berkowitz, P.C.
`Baker Donelson Center
`
`211 Commerce Street, Suite 800
`Nashville, Tennessee 37201
`
`Email:
`
`eramage@bakerdonelson.com
`
`L. Clint Crosby(Back—up Counsel)
`Baker, Donelson, Bearman,
`Caldwell
`& Berkowitz, P.C.
`Monarch Plaza, Suite 1600
`3414 Peachtree Road NE
`
`30326
`Atlanta, Georgia
`Email:
`ccrosby@bakerdonelson.com
`
`Dated: December 3, 2013
`
`By:/s/John M. Adams
`John M. Adams
`
`Registration No. 26,697
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