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Paper No. ___
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`MICRO MOTION, INC.
`
`Petitioner,
`
`v.
`
`INVENSYS SYSTEMS, INC. and
`SCHNEIDER ELECTRIC SA,
`
`Patent Owner.
`
`_______________
`
`Case IPR 2014-00393
`
`U.S. Patent No. 7,571,062
`
`____________________
`
`
`
`Before WILLIAM V. SAINDON, MICHAEL R. ZECHER, and
`JENNIFER M. MEYER, Administrative Patent Judges.
`
`
`
`
`
`
`
`PATENT OWNERS’ NOTICE OF PROPOSED MOTIONS
`
`

`

`An initial conference call with the Board is scheduled for Tuesday, August
`
`Case IPR 2014-00393
`U.S. Patent No. 7,571,062
`
`
`
`
`26, 2014, at 3:00 p.m. ET. Pursuant to the Office Patent Trial Practice Guide, 77
`
`Fed. Reg. 48756, 48765-66 (Aug. 14, 2012), patent owners Invensys Systems, Inc.
`
`and Schneider Electric SA (“Patent Owners”) provide the following list of
`
`proposed motions that Patent Owners are considering. The list is submitted
`
`without prejudice. Patent Owners reserve the right to request authorization to file
`
`additional motions and Patent Owners may choose not to file any or all of the listed
`
`motions. Further, although motions to amend, exclude evidence, and observations
`
`on cross-examination are listed in the Scheduling Order, Patent Owners identify
`
`such motions here to preserve the right to file them.
`
`
`
`1.
`
`A motion to amend or a motion to amend in the alternative pursuant to
`
`37 C.F.R. § 42.121;
`
`
`
`2.
`
`A motion for a protective order and to seal regarding confidential
`
`information pursuant to 37 C.F.R. §§ 42.14, 42.54, and 42.55;
`
`
`
`3.
`
`A motion for discovery or for additional discovery pursuant to 37
`
`C.F.R. § 42.51;
`
`
`
`
`
`
`
`
`
`
`
`4.
`
`5.
`
`A motion for observation on cross-examination; and
`
`A motion to exclude evidence pursuant to 37 C.F.R. § 42.64.
`
`1
`
`

`

`
`Dated: August 22, 2014
`
`Case IPR 2014-00393
`U.S. Patent No. 7,571,062
`
`
`
`Respectfully submitted,
`
`DLA PIPER LLP
`
`
`
`
`
`/Jeffrey L. Johnson/
`Jeffrey L. Johnson (Registration No. 53,078)
`DLA PIPER LLP (US)
`1000 Louisiana, Suite 2800
`Houston, TX 77002
`Telephone: 713.425.8400
`Facsimile: 713.425.8401
`Jeffrey.Johnson@dlapiper.com
`Inveneys_Micro_IPR@dlapiper.com
`
`LEAD COUNSEL FOR PATENT OWNER
`
`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned hereby certifies that a true copy of the foregoing instrument
`
`was served on Petitioner, Micro Motion, Inc., by emailing a copy to counsel at the
`
`email addresses listed below:
`
`Andrew S. Baluch
`WASH-Abaluch-PTAB@foley.com
`
`Jeffrey N. Costakos
`jcostakos@foley.com
`
`
`
`
`
`
`
`/Jeffrey L. Johnson/
`Jeffrey L. Johnson
`Reg. No. 53,078
`Jeffrey.johnson@dlapiper.com
`Counsel for Invensys Systems, Inc.
`
`
`
`
`
`2
`
`
`Dated: August 22, 2014
`
`EAST\80952758.1
`
`
`
`

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