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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
`
`Patent No. 8,050,652
`Issue Date: November 1, 2011
`Title: METHOD AND DEVICE FOR AN
`INTERNET RADIO CAPABLE OF OBTAINING
`PLAYLIST CONTENT FROM A CONTENT SERVER
`_______________
`
`Inter Partes Review No. IPR2013-00594 (SGW)
`____________________________________________________________
`
`
`PETITIONER’S LIST OF PROPOSED MOTIONS
`
`
`
`
`
`
`

`

`Attorney Docket No.: 393032805800
`
`
`
`IPR2013-00594
`
`Pursuant to the Decision of the Board to institute inter partes review (Paper
`
`17) and the Office Patent Trial Practice Guide, 77 Fed. Reg. 48756 (August 14,
`
`2012), Petitioner Yamaha Corporation of America does not currently anticipate
`
`filing any motions.
`
`Petitioner has not listed motions already authorized by the Board, such as set
`
`forth in the Scheduling Order (Paper 18), and reserves the right to file those
`
`motions and to seek authorization to file any other motions as necessary. See
`
`Office Patent Trial Practice Guide, at 48765 (“Submission of a list would not
`
`preclude the filing of additional motions not contained in the list.”).
`
`Respectfully submitted,
`
`By: __/David L. Fehrman/____
`David L. Fehrman
`Registration No.: 28,600
`MORRISION & FOERSTER LLP
`707 Wilshire Blvd.
`Los Angeles, California 90017
`(213) 892-5601
`
`
`By: __/Mehran Arjomand/____
`Mehran Arjomand
`Registration No.: 48,231
`MORRISION & FOERSTER LLP
`707 Wilshire Blvd.
`Los Angeles, California 90017
`(213) 892-5630
`
`Dated: April 18, 2014
`
`
`
`la-1248196
`
`

`

`Attorney Docket No.: 393032805800
`
`
`
`IPR2013-00594
`
`
`
`Certificate of Service (37 C.F.R. § 42.6(e)(4))
`
`I hereby certify that the attached Petitioner’s List of Proposed Motions was
`
`served as of the below date via electronic mail (by agreement) upon the following
`
`counsel of record for Patent Owner.
`
`
`Thomas Engellenner (engellennert@pepperlaw.com)
`Reza Mollaaghababa (mollaaghababar@pepperlaw.com)
`PEPPER HAMILTON LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`
`Theodosios Thomas (ted.thomas@sceneralabs.com)
`BLACK HILLS MEDIA, LLC
`5400 Trinity Road, Suite 303
`Raleigh, NC 27607
`
`
`
`Dated: April 18, 2014
`
`___/Mehran Arjomand/_____
`Mehran Arjomand
`
`
`
`
`
`
`
`
`
`
`
`
`la-1248196
`
`

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