`Patent Trial & Appeal Board
`_________________________________________
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`IPR2014-00439
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`Patent No. 7,365,871
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`IRON DOME LLC
`Petitioner
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`v.
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`E-WATCH, INC.
`Patent Owner
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`_________________________________________
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`Petitioner’s List of Anticipated Motions For
`Discussion in Initial Conference Call
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`Steven Yu (Reg. No. 58,776)
`Lead Counsel for Petitioner
`P.O. Box 10034
`Gaithersburg, MD 20898
`Tel: 202.262.0426
`Email: syu@irondome.com
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`August 22, 2014
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`IPR2014-00439
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`Petitioner’s List of Anticipated Motions For
`Discussion in Initial Conference Call
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`An initial conference call is scheduled in this matter for August 26, 2014 at 2:30
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`PM. Pursuant to the Office Patent Trial Practice Guide (OPTPG), 77 Fed. Reg.,
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`48765 (Aug. 14, 2012), Petitioner submits this list of motions it may bring during this
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`trial. Petitioner reserves the right to seek authorization to bring additional motions, or
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`to decide not to bring motions as indicated, as circumstances may warrant.
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`Motion to Take Discovery Relating to Conception and Reduction to Practice
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`The Patent Owner seeks to remove the Parulski and Reele references as prior
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`art with a swear-behind affidavit filed under 37 C.F.R. § 1.131. The Board has
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`determined that Patent Owner’s 2004 Monroe Declaration (swear-behind affidavit)
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`does not properly antedate Parulski and Reele. Petitioner anticipates on filing a
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`motion to take additional discovery regarding Patent Owner’s contentions on
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`conception and reduction to practice. More specifically, the additional discovery will
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`seek information about the dates for conception and reduction to practice (and
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`evidence thereof) for each claim and evidence of diligence.
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`By:
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`IRON DOME LLC
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`/Steven Yu/
`Steven Yu (Reg. No. 58,776)
`Lead Counsel for Petitioner
`P.O. Box 10034
`Gaithersburg, MD 20898
`Tel: 202.262.0426
`Email: syu@irondome.com
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`IPR2014-00439
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`CERTIFICATE OF SERVICE
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`The parties have agreed to electronic service in this matter. The undersigned
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`hereby certifies that the foregoing PETITIONER’S REPLY TO PATENT OWNER’S
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`PRELIMINARY RESPONSE was served on August 22, 2014 by filing though the Patent
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`Review Processing System.
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`Robert C. Curfiss
`bob@curfiss.com
`19826 Sundance Drive
`Humble, Texas 77346
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`David O. Simmons
`dsimmons1@sbcglobal.net
`P. O. Box 26584
`Austin, Texas 78755
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`/Steven Yu/
`Steven Yu
`Lead Counsel for Petitioner
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