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`BEFORE THE PATENT TRIAL AND APPEAL BOARD IN THE UNITED
`STATES PATENT AND TRADEMARK OFFICE
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`
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`Trial No.:
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`IPR 2014-00059
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`In re:
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`U.S. Patent No. 6,415,280
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`Patent Owners:
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`PersonalWeb Technologies, LLC & Level 3 Communications
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`Petitioner:
`Inventors:
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`Rackspace US, Inc. and Rackspace Hosting, Inc.
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`David A. Farber and Ronald D. Lachman
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`For: IDENTIFYING AND REQUESTING DATA IN NETWORK USING
`IDENTIFIERS WHICH ARE BASED ON CONTENTS OF DATA
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`* * * * * * * * * * *
`
`April 25, 2014
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`
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`PATENT OWNER’S INITIAL LIST OF PROPOSED MOTIONS FOR
`DISCUSSION DURING INITIAL CONFERENCE CALL
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`An initial conference call is scheduled in this matter for Tuesday, April 29,
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`2014, at 3:00 pm. Patent Owner submits this initial listing of proposed motions
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`which it may bring during this trial. This listing is without prejudice to Patent
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`Owner’s right to seek authorization to bring additional motions, or to decide not to
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`bring motions as indicated, as circumstances may warrant.
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`1. Motion to Exclude Under Rule 42.64.
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`2. Motion for Observations on Cross-Examination – if applicable.
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`3. Motion for admission pro hac vice for one additional attorney.
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`2335527
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`Patent owner would also like to discuss how to coordinate discovery
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`between the five IPRs: 2014-00057, -00058, -00059, -00062, and -00066.
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`Patent owner also desires to file opposition(s), if appropriate, to motions
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`filed by petitioner as permitted under the Rules.
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`Respectfully submitted,
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`NIXON & VANDERHYE P.C.
`
`
`By: /Joseph A. Rhoa/
`Joseph A. Rhoa
`Reg. No. 37,515
`Updeep (Mickey) S. Gill
`Reg. No. 37,334
`Counsel for Patent Owner PersonalWeb
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`
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`
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`JAR:caj
`Nixon & Vanderhye, PC
`901 North Glebe Road, 11th Floor
`Arlington, VA 22203-1808
`Telephone: (703) 816-4000
`Facsimile: (703) 816-4100
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`CERTIFICATE OF SERVICE
`I hereby certify service of the foregoing Patent Owner’s Initial List of
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`Proposed Motions for Discussion During Initial Conference Call to the following
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`lead counsel for petitioner on April 25, 2014 via email (pursuant to agreement
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`between the parties):
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`J. Andrew Lowes
`HAYNES AND BOONE, LLP
`2323 Victory Avenue, Suite 700
`Dallas, TX 75219
`(andrew.lowes.ipr@haynesboone.com)
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`
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`By: /Joseph A. Rhoa/
`Joseph A. Rhoa
`Reg. No. 37,515
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`2335527
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