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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Reloaded Games, Inc.
`Petitioner
`v.
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`Parallel Networks LLC
`Patent Owner
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`Inter Partes Review Control No. IPR2014-00136
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`In re U.S. Patent No. 7,188,145 (Lowery et al.)
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`PATENT OWNER’S LIST OF ANTICIPATED PROPOSED MOTIONS
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`IPR2014-00136
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`Pursuant to the Trial Practice Guide, 77 Fed. Reg. 48,756, 48,765-66 (Aug.
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`14, 2012), in advance of the initial conference call with the Board scheduled for
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`June 3, 2014 at 11:00 a.m. EST, Patent Owner Parallel Networks LLC (“Parallel”)
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`submits the following list of motions that Parallel is considering filing in this
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`matter. This list includes motions that are anticipated as of the date of this filing.
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`Parallel may seek Board authorization to file additional motions in the future.
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`A. Contingent Motion to Amend Under 37 C.F.R. § 42.121
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`Parallel may file a contingent motion to amend one or more of the
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`challenged claims of the ‘145 patent. Any such motion would respond to the
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`grounds of unpatentability alleged in this trial and would not seek to enlarge the
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`scope of the claims of the patent or introduce new subject matter.
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`B. Motion to Exclude Evidence Under 37 C.F.R. § 42.64(c)
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`Parallel may file a motion to exclude any exhibit to which it serves
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`objections pursuant to 37 C.F.R. § 42.64(b)(1). The bases for any such motion
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`would be set forth in objections served pursuant to 37 C.F.R. § 42.64(b)(1) and
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`expanded upon in the motion to exclude.
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`C. Motion for Observations on Cross-Examination
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`Parallel may seek to file observations on cross-examination. In the event
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`that a deposition occurs after the last substantive papers have been filed, and
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`testimony needs to be called to the Board’s attention, Parallel reserves the right to
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`file observations on cross-examination.
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`IPR2014-00136
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`Date: May 30, 2014
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`Respectfully submitted,
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` /Darren W. Collins/
`Darren W. Collins
`Registration No. 44,625
`Aaron J. Pickell
`Registration No. 60,614
`MCGUIREWOODS LLP
`1717 McKinney Ave., Suite 700
`Dallas, TX 75202
`(214) 593-7143
`Attorney for Patent Owner
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`IPR2014-00136
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the above-captioned Parallel Networks
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`LLC’s List of Anticipated Proposed Motions was served on this 30th day of May,
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`2014, by filing this document through the Patent Review Processing System as
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`well as delivering a copy via electronic mail upon the following attorneys of record
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`for the Petitioner:
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`Eric A. Buresh
`Mark C. Lang
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`eric.buresh@eriseip.com
`mark.lang@eriseip.com
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`57493952_1
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`Respectfully submitted,
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` /Darren W. Collins/
`Darren W. Collins
`Registration No. 44,625
`Aaron J. Pickell
`Registration No. 60,614
`MCGUIREWOODS LLP
`1717 McKinney Ave., Suite 700
`Dallas, TX 75202
`(214) 593-7143
`Attorney for Patent Owner
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