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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`NORMAN INTERNATIONAL, INC.
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`Petitioner
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`v.
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`ANDREW J. TOTI TESTAMENTARY TRUST, RUSSELL L. HINCKLEY, SR.
`(CO-TRUSTEE), and ROBERT F. MILLER (CO-TRUSTEE)
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`Patent Owner
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`CASE: Unassigned
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`Patent No. 6,283,192 B2
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`TRANSMITTAL LETTER FOR PETITION FOR INTER PARTES REVIEW
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`Patent Trial and Appeal Board,
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`Petitioner and Real Party in Interest NORMAN INTERNATIONAL, INC.
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`hereby submits the following documents for filing a petition for inter partes review
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`of U.S. Patent No. 6,283,192 B2 entitled “FLAT SPRING DRIVE SYSTEM AND
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`WINDOW COVER” which issued September 4, 2001.
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`-1-
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`Petitioner requests review and rejection of claims 17, 18, 26, 31, 35, 36, 38,
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`42, and 43 of the U.S. Patent No. 6,283,192 B2 and cancellation of U.S. Patent No.
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`6,283,192 B2.
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`I. List of Documents Filed with This Petition
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`1. Transmittal Letter for Petition for Inter Partes Review (4 pages);
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`2. Petition for Inter Partes Review of U.S. Patent No. 6,283,192 B2
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`2.1. Table of Contents (4 pages)
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`2.1. Exhibit List (1 page)
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`2.3. Main Body of Petition (53 pages)
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`2.4. Certificate of Service (2 pages)
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`2.5. Nine (9) Exhibits in Support of the Petition:
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`Ex. 1001: U.S. Patent No. 6,283,192 B2 (“the 192 Patent”)
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`Ex. 1002: Japanese Patent Application Publication
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`S54-38648 (“Tachikawa”):
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`Pages 1-4: English Translation
`Pages 5-8: Original Japanese Publication
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`Ex. 1003: U.S. Patent No. 6,056,036 (“Todd”)
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`Ex. 1004: U.S. Patent No. 5,531,257 (“Kuhar”)
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`Ex. 1005: U.S. Patent No. 5,641,229 (“McClintock”)
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`Ex. 1006: U.S. Patent No. 4,096,903 (“Ringle”)
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`Ex. 1007: U.S. Patent No. 3,216,528 (“Lohr”)
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`Ex. 1008: Declaration of Lawrence E. Carlson in Support of
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`Petition for Inter Partes Review of U.S. Patent No.
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`6,283,192 B2 (“Carlson Declaration on 192
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`Patent”)
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`Ex. 1009: Definition of “inherent inertia”” in The New
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`Merriam-Webster Dictionary, Copyright 1989,
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`Pg. 380.
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`3. Power of Attorney Executed by Petitioner Norman International, Inc. (2
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`pages)
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`-2-
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`II. Payment of Fees
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`The Office is authorized to charge $23,000 to Deposit Account No. 50-5252
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`as required under 37 C.F.R. § 42.15(a) and pursuant to the official fee schedule
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`effective on March 19, 2013. The above total fee of $23,000 includes $9,000 in
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`inter partes review request fees for up to 20 claims and $14,000 in post-institution
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`fees for up to 15 claims.
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`The Office is further authorized to charge any other fees, or apply any credit
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`in connection with this Petition, to the Deposit Account No. 50-5252.
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`III. Counsel for Petitioner
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`Petitioner appoints the following counsel and information for service:
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`LEAD COUNSEL
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`BACK-UP COUNSEL
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`Bing Ai
`USPTO Reg. No. 43,312
`Perkins Coie LLP
`11988 El Camino Real, Suite 350
`San Diego, California 92130
`Phone: 858-720-5707
`Fax: 858-720-5799
`Ai@perkinscoie.com
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`Kourtney Mueller Merrill
`USPTO Reg. No. 58,195
`Perkins Coie LLP
`1900 Sixteenth Street, Suite 1400
`Denver, Colorado 80202
`Phone: 303-291-2388
`Fax: 303-291-2400
`KMerrill@perkinscoie.com
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`Pursuant to 37 C.F.R. § 42.10(b), a Power of Attorney for appointing the
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`above designated counsel for this Petition by Norman International, Inc. is
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`concurrently filed.
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`V. Compliance Statements
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`This submission meets statutory requirements under 35 U.S.C. §§ 311 and
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`312 and complies with requirements under relevant patent rules, inter alia, 35
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`C.F.R. §§ 42.6, 42.8, 42.22 and 42.100 through 42.106. In addition, this
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`submission complies with requirements under The Office Patent Trial Practice
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`Guide issued on August 12, 2012.
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`Dated: December 20, 2013
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`PERKINS COIE LLP
`11988 El Camino Real, Suite 350
`San Diego, CA 92130
`(858) 720-5700
`norman-hd-ipr@perkinscoie.com
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`Respectfully submitted,
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`/Bing Ai/
`Lead Counsel
`Bing Ai, Reg. No. 43,312
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`Back-Up Counsel
`Kourtney Mueller Merrill, Reg. No. 58,195
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`Attorneys for Norman International, Inc.
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`-4-
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