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`IPR2013-00571
`US Patent No. 8,135,398
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
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`BEFORE THE PATENT AND TRIAL APPEAL BOARD
`________________________
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`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
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`v.
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`VIRGINIA INNOVATION SCIENCES, INC.
`Patent Owner
`
`________________________
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`Case IPR2013-00571
`Patent 8,135,398
`________________________
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`PETITIONER’S INITIAL LIST OF PROPOSED MOTIONS
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`________________________
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`Submitted: March 20, 2014
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`Petitioner’s Initial List of Proposed Motions
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`IPR2013-00571
`US Patent No. 8,135,398
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`An initial conference call is scheduled in this matter for Monday, March 24,
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`2014, at 2:00 pm. Petitioner submits this initial listing of proposed motions which
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`it may bring during this trial. This listing is without prejudice to Petitioner’s right
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`to seek authorization to bring additional motions, or to decide not to bring motions
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`as circumstances may warrant.
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`1. Motion to Submit Supplemental Information under Rule 42.123.
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`2. Motion for Admission Pro Hac Vice for one additional attorney.
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`3. Motion for Observations on Cross-Examination – if applicable.
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`4. Motion to Exclude Evidence Under Rule 42.64.
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`5. Motion to Seal regarding Confidential Information.
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`6. Motion for Additional Discovery.
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`For the sake of completeness, the Board is advised that Petitioner anticipates
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`that a Motion for Joinder with this Petition under Rule 42.122(b) in a Related
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`Petition for Inter Partes Review directed to claims 58 and 63 of U.S. Patent No.
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`8,135,398 may be filed.
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`Petitioner does not anticipate additional motions at this time. If the grounds
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`of rejection are modified during this proceeding, Petitioner may request additional
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`motions as appropriate. Petitioner also desires to file opposition(s), if appropriate,
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`to motions filed by patent owner as permitted under the Rules and authorized by
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`the Board.
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`1
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`Petitioner’s Initial List of Proposed Motions
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`Dated: March 20, 2014
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`IPR2013-00571
`US Patent No. 8,135,398
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`Respectfully submitted,
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`/Joseph S. Presta/
`Joseph S. Presta
`Reg. No. 35,329
`Updeep (Mickey) S. Gill
`Reg. No. 37,334
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`Counsel for Petitioner Samsung
`Electronics Co., Ltd.
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`2
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`Petitioner’s Initial List of Proposed Motions
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`CERTIFICATE OF SERVICE
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`IPR2013-00571
`US Patent No. 8,135,398
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`I hereby certify that, on March 20, 2014, I caused a true and correct copy of
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`the foregoing materials:
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`• Petitioner’s Initial List of Proposed Motions
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`to be served via email (under an agreement between the parties) upon on the
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`following:
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`D. Richard Anderson, Lead Counsel
`George S. Dolina, Back-up Counsel
`BIRCH, STEWART, KOLASCH & BIRCH, LLP
`8110 Gatehouse Road, Suite 100 East
`Falls Church, VA 22042-1248
`Email: dra@bskb.com
`Email: gsd@bskb.com
`Email: mailroom@bskb.com
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`/Joseph S. Presta/
`Joseph S. Presta
`Reg. No. 35,329
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`3
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