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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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`FACEBOOK, INC.,
`Petitioner
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`v.
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`B.E. TECHNOLOGY, LLC
`Patent Owner
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`Case No. IPR2014-0052
`Patent No. 6,628,314
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`FACEBOOK’S LIST OF PROPOSED MOTIONS
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`Pursuant to the Patent Trial and Appeal Board instituting trial on April
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`9, 2014, and in advance of the initial conference call scheduled for May 6,
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`2014, Petitioner Facebook, Inc. hereby provides a list of the proposed motions
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`it may file in the above-captioned inter partes review proceeding. Although
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`motions to exclude evidence and motions for observations on cross-
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`examination have been authorized by the Board, Facebook identifies such
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`motions here to preserve its right to file them. Petitioner lists those motions it
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`presently expects it may file. Petitioner reserves the right to seek permission
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`to file additional motions not listed below pursuant to the Board's
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`authorization.
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`PETITIONER'S PROPOSED MOTIONS
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`1. Motion for discovery concerning conception and reduction to practice
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`should patent owner attempt to antedate any of petitioner’s prior art
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`references;
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`2. Motion to consolidate related proceedings;
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`3. Motion pursuant to 37 C.F.R. § 42.223 to file supplemental information;
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`4. Motion pursuant to 37 C.F.R. § 42.64(c) to exclude evidence;
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`5. Motion pursuant to 37 C.F.R. § 42.51 for observations on cross
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`examination; and
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`6. Motion to enlarge trial to include grounds denied as redundant.
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`Respectfully submitted,
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`/Heidi Keefe/
`Heidi Keefe
`Registration No. 40,673
`Counsel for Petitioners
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`Cooley LLP
`ATTN: Patent Group
`1299 Pennsylvania Ave., NW, Suite 700
`Washington, DC 20004
`Tel: (650) 843-5001
`Fax: (650) 849-7400
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`DATED: May 5, 2014
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`2.
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`The undersigned hereby certifies that a copy of the foregoing
`Facebook’s List of Proposed Motions together with all exhibits and other
`papers filed therewith were served on May 5, 2014 by electronic mail on the
`Patent Owner via its attorneys of record:
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`Jason S. Angell
`Robert E. Freitas
`Freitas Tseng & Kaufman LLP
`jangell@ftklaw.com
`rfreitas.ftklaw.com
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`Dated: May 5, 2014
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`CERTIFICATE OF SERVICE
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`106728721 v1
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`/Heidi Keefe/
`Heidi Keefe
`Registration No. 40,673
`Counsel for Petitioners
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`Cooley LLP
`ATTN: Patent Group
`1299 Pennsylvania Ave., NW, Suite 700
`Washington, DC 20004
`Tel: (650) 843-5001
`Fax: (650) 849-7400
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