`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`GOOGLE INC.
`Petitioner
`
`v.
`
`B.E. TECHNOLOGY, LLC
`Patent Owner
`____________
`
`Case IPR2014-00038
`Patent 6,628,314
`____________
`
`Before SALLY C. MEDLEY, KALYAN K. DESHPANDE and LYNNE E.
`PETTIGREW, Administrative Patent Judges.
`
`NOTICE OF PROPOSED MOTIONS BY PETITIONER GOOGLE INC.
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`NOTICE OF PROPOSED MOTIONS
`
`CASE IPR2014-00038
`Patent 6,628,314
`
`An initial conference call is scheduled for 2:00 PM EST on Tuesday, May 6,
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`2014. Pursuant to the Decision on Institution of Inter Partes Review (Paper 9) and
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`Office Patent Trial Practice Guide, 77 Fed. Reg. 48756, 48765-66 (Aug. 14, 2012),
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`Petitioner Google Inc. provides notice that it does not presently intend to file any
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`motions but reserves the right to file a motion to exclude evidence or a motion for
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`observation on the dates set for the Scheduling Order (Paper 10).
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`To the extent necessary, Petitioner may need, and reserves the right, to seek
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`authorization from the Board (if required) to file additional motions depending on
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`the arguments Patent Owner may raise and events that may occur during the
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`proceeding.
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`Date: May 2, 2014
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`Respectfully submitted,
`
`By: /Clinton Brannon/
`Clinton Brannon (Reg. No. 57,887)
`Brian Rosenthal (pro hac vice granted)
`Mayer Brown, LLP
`1999 K Street, N.W.
`Washington, D.C. 20006-1101
`(202) 263-3440
`
`2
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`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this day, May 2, 2014, a copy of this NOTICE OF
`
`PROPOSED MOTIONS BY PETITIONER GOOGLE INC was served upon
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`Patent Owner, by sending an electronic copy and placing into Express Mail
`
`directed to the attorney of record for the patent at the following address:
`
`Jason S. Angell
`Robert E. Freitas
`Freitas Tseng & Kaufman LLP
`100 Marine Parkway, Suite 200
`Redwood Shores, CA 94065
`jangell@ftklaw.com
`rfreitas@ftklaw.com
`
`Date: May 2, 2014
`
`By: /Clinton Brannon/
`Clinton Brannon
`Reg. No. 57,887
`Counsel for Petitioner
`
`