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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
`___________________
`
`Case No. IPR2013-00594
`U.S. Patent 8,050,652
`___________________
`
`JOINT NOTICE OF STIPULATION TO AMEND SCHEDULING ORDER
`AND CONDUCT OF DEPOSITIONS
`
`
`
`
`
`IPR2013-00594
`U.S. Patent 8,050,652
`
`
`Stipulation 1
`
`In accordance with the Board’s Scheduling Order (Paper No. 18), Petitioner
`
`and Patent Owner hereby jointly submit this notice that the parties have stipulated
`
`to change DUE DATES 1 and 2, as follows:
`
`Event
`
`Original
`Due Date
`
`Stipulated
`Due Date
`
`May 22, 2014
`
`June 13, 2014
`
`July 22, 2014
`
`August 5, 2014
`
`DUE DATE 1
`Patent Owner response to the petition and
`motion to amend
`DUE DATE 2
`Petitioner reply to Patent Owner response
`and opposition to motion to amend
`
`The parties have also agreed to consider further amendments to the
`
`
`
`Scheduling Order. Specifically, the parties have agreed to discuss stipulated
`
`changes, if any, to DUE DATE 3 after the stipulated DUE DATE 1 of June 13,
`
`2014.
`
`None of the stipulated dates for DUE DATES 1 and 2 are later than DUE
`
`DATE 4, and this stipulation does not affect or otherwise modify DUE DATES 4
`
`through 7 as set forth in the Scheduling Order.
`
`Stipulation 2
`
`Pursuant to 37 C.F.R. 42.53(c)(2), the parties have stipulated to limit cross-
`
`examination of the respective parties’ expert declarant in the Petition and the
`
`1
`
`
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`expert declarant in the Patent Owner’s Response to the Petition to seven (7) hours
`
`IPR2013-00594
`U.S. Patent 8,050,652
`
`
`combined, to limit redirect examination of the respective parties’ expert declarant
`
`to four (4) hours combined, and to limit re-cross-examination of the respective
`
`parties’ expert declarant to two (2) hours combined for this proceeding and that of
`
`IPR2013-00593.
`
`Specifically, Patent Owner has agreed to limit the cross-examination of
`
`Petitioner’s expert declarant Dr. V. Michael Bove, Jr. to seven (7) hours combined
`
`and the re-cross-examination to two (2) hours combined for IPR2013-00593 and
`
`IPR2013-00594. Petitioner has also agreed to limit the redirect examination of Dr.
`
`Bove to four (4) hours combined for IPR2013-00593 and IPR-00594. The
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`deposition of Dr. Bove for IPR2013-00593 and IPR2013-00594 is scheduled for
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`May 30, 2014. Notice of the deposition has been filed with the Board in
`
`accordance with 37 C.F.R. 42.53(d).
`
`Likewise, Petitioner has agreed to limit the cross-examination of the Patent
`
`Owner’s expert declarant in IPR2013-00593 and IPR2013-00594 to seven (7)
`
`hours combined and the re-cross-examination to two (2) hours combined. Patent
`
`Owner has also agreed to limit the redirect examination of Patent Owner’s expert
`
`declarant to four (4) hours combined for IPR2013-00593 and IPR-00594. The time
`
`and location of the cross-examination will be determined in accordance with 37
`
`C.F.R. 42.53(d). Notice of the deposition will be filed with Board in accordance
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`2
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`
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`with 37 C.F.R. 42.53(d). This stipulation is based on Patent Owner presenting a
`
`IPR2013-00594
`U.S. Patent 8,050,652
`
`
`single expert declarant in its Response to the Petition.
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`The parties by this paper do not make any stipulation concerning cross-
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`examination, redirect examination, or re-cross-examination of any declarant relied
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`upon in a Patent Owner Motion to Amend or any party’s reply declarant.
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`
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`Respectfully submitted,
`
`Dated: May 2, 2014
`
`
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`
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`Respectfully submitted,
`
`Dated: May 2, 2014
`
`
`
`
`
`
`By: /Thomas Engellenner/
`Thomas Engellenner, Reg. No. 28,711
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`Counsel for Patent Owner
`
`
`By: /Mehran Arjomand/
`David L. Fehrman, Reg. No. 28,600
`Mehran Arjomand, Reg. No. 48,231
`Morrison & Foerster LLP
`707 Wilshire Boulevard
`Los Angeles, CA 90017-3543
`(213) 892-5630 (telephone)
`(323) 210-1329 (facsimile)
`Counsel for Petitioner
`
`3
`
`
`
`IPR2013-00594
`U.S. Patent 8,050,652
`
`
`CERTIFICATE OF SERVICE
`
`dfehrman@mofo.com
`marjomand@mofo.com
`
`Respectfully submitted,
`
`By: /Thomas Engellenner/
`Thomas Engellenner, Reg. No. 28,711
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`Counsel for Patent Owner
`
`
`
`
`
`
`
`
`
`
`
` I
`
`
`
`
`
`
` hereby certify that on May 2, 2014, a true and accurate copy of this paper, JOINT
`NOTICE OF STIPULATION TO AMEND SCHEDULING ORDER AND CONDUCT OF
`DEPOSITIONS, was served on the following counsel for Petitioner Yamaha
`Corporation of America via email:
`
`David L. Fehrman
`Mehran Arjomand
`Morrison & Foerster LLP
`707 Wilshire Boulevard
`Los Angeles, CA 90017-3543
`Tel: (213) 892-5630
`Fax: (323) 210-1329
`
`
`Dated: May 2, 2014
`
`
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