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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`DELL, INC., HEWLETT-PACKARD COMPANY, and NETAPP, INC,
`Petitioners,
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`V.
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`ELECTRONICS AND TELECOMMUNICATIONS RESEARCH INSTITUTE,
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`Patent Owner.
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`Case IPR2013-00635
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`Patent No. 6,978,346
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`PETITIONERS’ NOTICE OF PROPOSED MOTIONS
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`Petitioner’s Notice of Proposed Motions
`IPR2013-00635 /Patent No. 6,978,346
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`NOTICE OF PROPOSED MOTIONS
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`The initial conference call in this matter is set for April 22, 2014 at 2:30 pm.
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`Eastern time. Pursuant to the instructions for initial conference calls set forth in
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`the Office Trial Practice Guide, Petitioners gives notice that they do not presently
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`intend to file any motions but nevertheless reserves the right to file a motion to
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`exclude evidence or a motion for observation on the dates set forth in the
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`scheduling order for this case.
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`Respectfully submitted,
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`By: §J\nggh >_
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`David L. McCombs
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`Registration No. 32,271
`Counsel for Petitioners
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`Dated: April 21, 2014
`HAYNES AND BOONE, LLP
`2323 Victory Avenue, Suite 700
`Dallas, Texas 75219
`Telephone: 214/651-5533
`Facsimile: 214/200—0853
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`
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`Petitioner’s Notice of Proposed Motions
`IPR2013-00635 / Patent No. 6,978,346
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing notice was served on
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`April 21, 2014, by sending an electronic copy of the document to counsel of record
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`Via email, as agreed to by counsel, at the following email addresses:
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`Matthew.phillips@renaissanceiplaw.com
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`Derek.meeker@renaissanceiplaw.com
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`agiza@raklaw.com
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`Dated: April 21, 2014
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`Respectfully submitted,
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`$3.1M. N a:
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`David L. McCombs
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`Registration No. 32,271
`Counsel for Petitioners
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`