`Paper No. 19
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
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`SAMSUNG ELECTRONICS CO. LTD.; SAMSUNG ELECTRONICS
`AMERICA, INC.; SAMSUNG TELECOMMUNICATIONS AMERICA, LLC;
`AND SAMSUNG AUSTIN SEMICONDUCTOR, LLC;
`Petitioner
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`v.
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`REMBRANDT WIRELESS TECHNOLOGIES, LP
`Patent Owner
`___________
`
`Case IPR2014-00518
`Patent 8,023,580
`___________
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`PETITIONER’S INITIAL LIST OF PROPOSED MOTIONS
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`IPR2014-00518
`Paper No. 19
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`Pursuant to the Decision of the Board to institute inter partes review (Paper
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`16, September 23, 2014) and the Office Patent Trial Practice Guide, 77 Fed. Reg.
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`48756 (August 14, 2012), Samsung Electronics Co. Ltd.; Samsung Electronics
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`America, Inc.; Samsung Telecommunications America, LLC; and Samsung Austin
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`Semiconductor, LLC. (Collectively, “Petitioner”) do not currently anticipate filing
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`any motions.
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`Petitioner has not listed motions already authorized by the Board, such as set
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`forth in the Scheduling Order (Paper 17), and reserves the right to file those
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`motions and to seek authorization to file any other motions as necessary. See
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`Office Patent Trial Practice Guide, at 48765 (“Submission of a list would not
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`preclude the filing of additional motions not contained in the list.”).
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`For the sake of completeness, the Board is advised that Petitioner anticipates
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`that a Motion for Joinder with this Petition under Rule 42.122(b) in a Related
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`Petition for Inter Partes Review directed to claims 2, 19, 49, 52, 53, and 59 of U.S.
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`Patent No. 8,023,580 may be filed. Petitioner does not anticipate additional
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`motions at this time.
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`Dated: October 10, 2014
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`Respectfully submitted,
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`/s/ Jeffrey A. Miller
`
`Jeffrey A. Miller
`Registration No. 35,287
`DICKSTEIN SHAPIRO LLP
`1841 Page Mill Road
`Palo Alto, CA 94305
`Tel.: (650) 690-9500
`Counsel for Petitioners
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`1
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`CERTIFICATE OF SERVICE
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`IPR2014-00518
`Paper No. 19
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`The undersigned certifies that a copy of the foregoing Patent Owner
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`Preliminary Response is being served on counsel of record by filing this document
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`through the Patent Review Processing System as well as delivering a copy via
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`Email directed to:
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`
`
`Thomas Engellenner
`Reza Mollaaghababa
`Lana Gladstein
`PEPPER HAMILTON LLP
`engellennert@pepperlaw.com
`mollaaghababar@pepperlaw.com
`gladsteinl@pepperlaw.com
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`Respectfully submitted,
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`:
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`/s/ Jeffrey A. Miller
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`Jeffrey A. Miller
`Registration No. 35,287
`DICKSTEIN SHAPIRO LLP
`1841 Page Mill Road
`Palo Alto, CA 94305
`Tel.: (650) 690-9500
`
`Counsel for Petitioners
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`Dated: October 10, 2014
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