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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`
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`AKER BIOMARINE AS
`Petitioner
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`v.
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`NEPTUNE TECHNOLOGIES AND BIORESSOURCES INC.
`Patent Owner
`
`
`
`CASE NO. IPR2014-00003
`U.S. Patent No. 8,278,351
`
`
`
`PATENT OWNER’S LIST OF PROPOSED MOTIONS
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`
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`1
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`PATENT OWNER’S LIST OF PROPOSED MOTIONS
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`Case No.: IPR2014-0003
`Patent Owner’s List of Proposed Motions
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`
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`Pursuant to the Office Patent Trial Practice Guide, 77 Fed. Reg. 48756, 48765-66
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`(August 14, 2012), Patent Owner, Neptune Technologies and Bioressources Inc. (the
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`“Patent Owner” or “Neptune”), submits the following list of proposed motions it is currently
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`contemplating filing. This list is provided without prejudice to Patent Owner’s right to seek
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`authorization to file additional motions or to not file the motions listed herein.
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`I. Motion to Amend the Patent
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`
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`Pursuant to 37 CFR § 42.121(a), Patent Owner contemplates filing a motion to
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`amend one or more claims of U.S. Pat. No. 8,278,351, after conferring with the Board
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`regarding such a motion.
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`II. Motion to Exclude Evidence
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`
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`Pursuant to 37 CFR § 42.64(c), Patent Owner reserves the right to file a motion to
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`exclude evidence. While such a motion is automatically authorized, Patent Owner identifies
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`such a motion to preserve its right to file the same.
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`III. Motion for Observations on Cross-Examination
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`
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`Pursuant to 37 CFR § 42.20(a), Patent Owner reserves the right to file a motion for
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`observations on cross-examination. Patent Owner identifies such a motion to preserve its
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`right to file the same.
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`2
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`IV. Motion for Pro Hac Vice Admission
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`Case No.: IPR2014-0003
`Patent Owner’s List of Proposed Motions
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`
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`Pursuant to 37 CFR § 42.10(c), Patent Owner contemplates filing a motion for
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`admission pro hac vice for at least one additional counsel. Patent Owner identifies such a
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`motion to preserve its right to file the same.
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`V. Motion to Submit Supplemental Information
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`
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`Pursuant to 37 CFR § 42.123, Patent Owner contemplates filing a motion to submit
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`Supplemental Information. Patent Owner identifies such a motion to preserve its right to file
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`the same.
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`VI. Motion to Seal
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`Pursuant to 37 CFR § 42.54, Patent Owner contemplates filing a motion to seal
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`regarding confidential information. Patent Owner identifies such a motion to preserve its
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`right to file the same.
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`VII. Motion to Waive Page Limits
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`
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`Pursuant to 37 CFR § 42.24(a)(2), Patent Owner contemplates filing a motion to
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`waive page limits. Patent Owner identifies such a motion to preserve its right to file the
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`same.
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`
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`Patent Owner reserves the right to seek authorization, as required, to file additional
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`motions not listed herein.
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`Case No.: IPR2014-0003
`Patent Owner’s List of Proposed Motions
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`Respectfully submitted,
`COOLEY LLP
`
`/ Stephen L. Altieri /
`Stephen L. Altieri, Ph.D.
`Reg. No. 63,133
`
`
`
`
`By:
`
`
`
`DATE: APRIL 23, 2014
`
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Avenue NW, Suite 700
`Washington, DC 20004
`
`Tel: (617) 937-2371
`Fax: (202) 842-7899
`
`
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`4
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`
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`CERTIFICATION OF SERVICE UNDER 37 C.F.R. §§ 42.6(e), 42.105(a))
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`Case No.: IPR2014-0003
`Patent Owner’s List of Proposed Motions
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`
`
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`I, Stephen L. Altieri, Ph.D., hereby certify that the foregoing PATENT OWNER’S
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`LIST OF PROPOSED MOTIONS was served electronically (as consented to by Petitioner),
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`on the 23rd day of April, 2014, the same day as the filing of the above-identified document in
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`the United States Patent and Trademark Office (USPTO), upon:
`
`J. Mitchell Jones
`jmjones@casimirjones.com and docketing@casimirjones.com
`Hand delivery address:
`CASIMIR JONES SC
`2275 Deming Way, St. 310
`Middleton, WI 53562
`Telephone: (608) 662-1277
`Facsimile: (608) 662-1276
`Reg. No. 44,174
`
`
`Amanda Hollis
`amanda.hollis@kirkland.com
`Hand delivery address:
`KIRKLAND & ELLIS
`300 North LaSalle
`Chicago, IL 60654
`Telephone: 312-862-2011
`Facsimile: 312-862-2200
`Reg. No. 55,629
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`5
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`Case No.: IPR2014-0003
`Patent Owner’s List of Proposed Motions
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`Respectfully submitted,
`COOLEY LLP
`
`/ Stephen L. Altieri /
`Stephen L. Altieri, Ph.D.
`Reg. No. 63,133
`
`
`
`
`By:
`
`
`
`DATE: APRIL 23, 2014
`
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Avenue NW, Suite 700
`Washington, DC 20004
`
`Tel: (617) 937-2371
`Fax: (202) 842-7899
`
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`106265944 v1
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