`___________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________
`
`EASTMAN KODAK COMPANY, AGFA CORPORATION,
`ESKO SOFTWARE BVBA, and HEIDELBERG, USA
`Petitioners
`
`v.
`
`CTP INNOVATIONS, LLC
`Patent Owner
`___________________________
`
`Case IPR2014-00788
`Patent 6,738,155
`___________________________
`
`PATENT OWNER'S LISTING OF ANTICIPATED MOTIONS FOR
`
`DISCUSSION IN INITIAL CONFERENCE CALL
`
`
`
`
`
`
`
`
`An initial conference call is scheduled in this matter for December 11, 2014
`
`at 11:00 am ET. Pursuant to 37 C.F.R. 42.21(a) and the Office Patent Trial
`
`Practice Guide, 77 Fed. Reg. 48756, 48765 (Aug. 14, 2012), Patent Owner submits
`
`this initial listing of motions it anticipates bringing during this trial. Patent Owner
`
`reserves the right to seek authorization to bring additional motions as future
`
`discovery or filings in this matter may warrant.
`
`1. Motion to Amend the Claims
`
`Patent Owner is evaluating the Board's Decision to institute inter partes
`
`review in this matter. Patent Owner has taken note of the Board's comments with
`
`regard to certain terms in the claim preambles not forming part of the claims, and
`
`is evaluating whether to amend one or more of the claims to incorporate one or
`
`more of these terms, or other terms supported by the written description, in light of
`
`the factors set forth in IPR2012-0027 (Paper 66). Patent Owner requests that a
`
`conference call to discuss the proposed motion to amend be set for two weeks
`
`before the deadline to file a motion to amend.
`
`
`
`
`
`
`
`
`
`2
`
`
`
`Dated: December 9, 2014
`
`
`
`
`
`
`
`Respectfully submitted,
`
`BAKER, DONELSON, BEARMAN,
`CALDWELL & BERKOWITZ, P.C.
`
`
`
`/W. Edward Ramage/
`W. Edward Ramage, Reg. No. 50,810
`Samuel F. Miller
`BAKER, DONELSON, BEARMAN,
`CALDWELL & BERKOWITZ, P.C.
`Baker Donelson Center
`211 Commerce Street, Suite 800
`Nashville, Tennessee 37201
`Tel: (615) 726-5771
`Fax: (615) 744-5771
`Email: eramage@bakerdonelson.com
`smiller@bakerdonelson.com
`
`
`for Patent Owner CTP
`Counsel
`Innovations, LLC
`
`
`
`
`
`3
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that, on December 9, 2014, the foregoing
`
`Listing of Anticipated Motions was served in its entirety via U.S. Express Mail,
`
`postage prepaid, and electronic mail upon the following:
`
`
`
`Scott A. McKeown
`OBLON, SPIVAK, MCCLELLAND,
`MAIER & NEUSTADT, LLP.
`1940 Duke Street
`Alexandria, VA 22314
`Tel: (703) 412-6297
`Fax: (703) 413-2220
`Email: cpdocketmckeown@oblon.com
` cpdocketkiklis@oblon.com
`
`
`
`
`
`
`
`/W. Edward Ramage/
`W. Edward Ramage, Reg. No. 50,810
`
`
`
`
`
`4
`
`
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