`
`Case IPR2013-00509
`Patent 6,451,300
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_________________________
`
`
`CONOPCO, INC. d/b/a UNILEVER
`Petitioner
`
`v.
`
`THE PROCTER & GAMBLE COMPANY
`Patent Owner
`
`_________________________
`
`
`Case IPR2013-00509
`Patent 6,451,300
`
`_________________________
`
`
`
`PATENT OWNER’S LIST OF PROPOSED MOTIONS
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`
`
`
`In view of the initial conference to be held on March 7, 2014, The Procter &
`
`Case IPR2013-00509
`Patent 6,451,300
`
`
`
`Gamble Company (“Patent Owner”) hereby files and serves the following list of
`
`proposed motions:
`
`I. CONTINGENT MOTION UNDER 37 C.F.R. § 42.221 TO AMEND
`
`Patent Owner may move to amend one or more of the involved claims of
`
`the ’300 patent. Any such claim amendments will be made to respond to one or
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`more of the grounds of unpatentability involved in the trial and will not enlarge the
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`scope of the claims of the ’300 patent (37 C.F.R. § 42.221(a)(2)(i)) or introduce
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`new matter (37 C.F.R. § 42.221(a)(2)(ii)).
`
`II. CONTINGENT MOTION UNDER 37 C.F.R. § 42.54 FOR A
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`PROTECTIVE ORDER
`
`Patent Owner may move for a protective order under 37 C.F.R. § 42.54(a)(7)
`
`to protect from public view Patent Owner’s trade secret, or other confidential
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`research, development, or commercial information that it may submit as objective
`
`evidence of non-obviousness, including evidence of unexpected results over the
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`prior art and of the commercial success of products that practice the ’300 patent.
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`
`
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`
`
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`March 5, 2014
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`
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`
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`
`
`Case IPR2013-00509
`Patent 6,451,300
`
`Respectfully submitted,
`
`
`/s/ David M. Maiorana
`David M. Maiorana (Reg. No. 41,449)
`John V. Biernacki (Reg. No. 40,511)
`Michael S. Weinstein (Reg. No. 62,446)
`JONES DAY
`North Point
`901 Lakeside Avenue
`Cleveland, Ohio 44114-1190
`Tel: (216) 586-3939 / Fax: (216) 579-0212
`
`Steven W. Miller (Reg. No. 31,984)
`Kim W. Zerby (Reg. No. 32,323)
`Carl J. Roof (Reg. No. 37,708)
`Angela K. Haughey (Reg. No. 56,373)
`THE PROCTER & GAMBLE COMPANY
`299 E. Sixth Street; Cincinnati, Ohio 45202
`Tel: (513) 983-1100 / Fax: (513) 945-2729
`
`Attorneys For Patent Owner
`The Procter & Gamble Company
`
`1
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6, the undersigned certifies that on March 5,
`
`2014, a copy of the foregoing PATENT OWNER’S LIST OF PROPOSED
`
`MOTIONS was served by electronic mail (per the parties’ agreement), on the
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`following counsel of record for Petitioner:
`
`Eldora L. Ellison, Esq.
`eellison-PTAB@skgf.com
`Robert G. Sterne, Esq.
`rsterne-PTAB@skgf.com
`STERN, KESSLER, GOLDSTEIN & FOX
`1100 New York Avenue, N.W.
`Washington, DC 20005
`
`/s/ David M. Maiorana
`David M. Maiorana
`Registration No. 41,449
`JONES DAY
`North Point
`901 Lakeside Avenue
`Cleveland, Ohio 44114-1190
`
`Attorney For Patent Owner
`The Procter & Gamble Company
`
`
`
`
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`
`
`
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