`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________
`
`
`
`YAMAHA CORPORATION OF AMERICA
`Petitioner
`
`v.
`
`BLACK HILLS MEDIA, LLC
`Patent Owner
`
`__________________
`
`Case IPR2013-00594
`Patent 8,050,652 B2
`
`___________________
`
`PATENT OWNER’S LIST OF ANTICIPATED 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
`
`
`
`
`
`
`An initial conference call is scheduled for Tuesday, April 22, 2014 at 1:00pm EST.
`
`Pursuant to the Office Patent Trial Practice Guide, 77 Fed. Reg. 48756, 48765-66 (Aug. 14,
`
`2012), Patent Owner Black Hills Media, LLC (“Black Hills”) submits the following list of
`
`proposed motions it currently is considering filing.
`
`Although a first motion to amend claims, motions for observations on cross-examination,
`
`and motions to exclude evidence are automatically authorized by the Board, Patent Owner
`
`identifies such motions to preserve its right to file them. This list is provided without prejudice
`
`to Patent Owner’s right to seek authorization to file additional motions or to decide not to file
`
`motions listed.
`
`List of Proposed Motions
`
`Pursuant to 37 C.F.R. § 42.121(a), a possible motion to amend claims;
`
`A motion for observations on cross-examination testimony of a Petitioner’s reply
`
`1.
`
`2.
`
`witness; and
`
`3.
`
`Pursuant to 37 C.F.R. § 42.64(c), a motion to exclude evidence.
`
`
`
`Respectfully submitted,
`
`/Thomas Engellenner/
`Thomas Engellenner (Reg. No. 28,711)
`Lead Attorney for Patent Owner Black Hills
`Media, LLC
`
`
`
`Date: April 18, 2014
`PEPPER HAMILTON LLP
`125 High Street
`19th Floor – High Street Tower
`Boston, MA 02110-2736
`(617) 204-5100
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the above-captioned “PATENT OWNER’S LIST
`
`OF ANTICIPATED PROPOSED MOTIONS” was served in its entirety on April 18, 2014,
`
`via email upon the following counsel of record for the Petitioner:
`
`David L. Fehrman
`Mehran Arjomand
`Morrison & Foerster LLP
`707 Wilshire Boulevard
`Los Angeles, CA 90017-3543
`Tel: (213) 892-5630
`Fax: (323) 210-1329
`
`dfehrman@mofo.com
`marjomand@mofo.com
`
`
`
`Respectfully submitted,
`
`/Thomas Engellenner/
`Thomas Engellenner (Reg. No. 28,711)
`Lead Attorney for Patent Owner Black Hills
`Media, LLC
`
`
`
`
`
`
`
`
`Date: April 18, 2014
`PEPPER HAMILTON LLP
`125 High Street
`19th Floor – High Street Tower
`Boston, MA 02110-2736
`(617) 204-5100
`
`
`
`
`
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