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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`TMM, INC.
`Petitioner
`v.
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`DIMENSION, INC.
`Patent Owner
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`Case IPR2014-00904
`Patent 8,639,053
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`PATENT OWNER’S LIST OF ANTICIPATED
`AND POTENTIAL MOTIONS
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`Submitted on behalf of Dimension, Inc. by:
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`Luke Anderson
`Maxwell & Anderson LLC
`1230 Peachtree St., NE Suite 1900
`Atlanta, GA 30319
`Tel: 404-991-2241
`Fax: 404-935-0927
`
`
`Jack D. Todd
`Todd Partners, P.C.
`1718 Peachtree St. NW, Suite 195
`Atlanta, GA 30309
`Tel: 404-386-1263
`Fax: 404-809-2455
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`In preparation for the December 4, 2014 initial conference call scheduled for
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`1:30 p.m. (EST) in this proceeding, and pursuant to the Office Patent Trial Practice
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`Guide, 77 Fed. Reg. 48756, 48765-66 (Aug. 14, 2012), Patent Owner Dimension,
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`Inc. (“Dimension”) hereby provides the following list of motions it currently is
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`considering filing. Dimension has not made a decision yet as to whether any of the
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`listed motions are necessary; all are merely possibilities at this time.
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`This list is provided without prejudice to Patent Owner’s right to seek
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`authorization to file additional motions or to decide not to file motions listed.
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`1. Motion to Amend pursuant to 37 C.F.R. §42.121;
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`2. Motion for Additional Discovery pursuant to 37 C.F.R. §42.51(b)(2);
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`3. Motion to File Supplemental Information pursuant to 37 C.F.R.
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`§42.123;
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`4. Motion to Exclude Evidence pursuant to 37 C.F.R. § 42.64; and,
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`5. Motion to Permit the Video-Recording of Depositions and For Use of
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`Video-Recorded Testimony Pursuant to 37 C.F.R. § 42.53(a).
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`Dimension also requests that the Due Dates established in the Scheduling
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`Order (Paper 7 entered November 12, 2014) be extended by two (2) weeks. This
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`modification to the Schedule, if granted, will not delay the completion of this
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`Proceeding.
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`1
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`If granted, the new proposed Due Dates would be:
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`Due Date
`No.
`Due Date 1
`Due Date 2
`Due Date 3
`Due Date 4
`Due Date 5
`Due Date 6
`Due Date 7
`(if requested)
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`Current Due Date Proposed Due Date
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`February 4, 2015
`April 27, 2015
`June 4, 2015
`June 25, 2015
`July 9, 2015
`July 16, 2015
`July 29, 2015
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`February 18, 2015
`May 11, 2015
`June 18, 2015
`July 9, 2015
`July 23, 2015
`July 30, 2015
`August 12, 2015
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`2
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`Respectfully submitted this 3rd day of December, 2014.
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`By: /Luke Anderson/
`Luke Anderson
`USPTO Reg. No. 44,507
`Maxwell & Anderson LLC
`1230 Peachtree St., NE Suite 1900
`Atlanta, GA 30319
`Tel: 404-991-2241
`Fax: 404-935-0927
`LAnderson@MaxwellAndersonLaw.com
`
`Jack D. Todd
`USPTO Reg. No. 44,375
`Todd Partners, P.C.
`1718 Peachtree St. NW, Suite 195
`Atlanta, GA 30309
`Tel: 404-386-1263
`Fax: 404-809-2455
`jack@toddpartners.com
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`Attorneys for Patent Owner Dimension,
`Inc.
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`CERTIFICATE OF SERVICE
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`
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`Pursuant to 37 C.F.R. §42.6(e), the undersigned hereby certifies that a copy
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`of the within and forgoing PATENT OWNER’S LIST OF ANTICIPATED
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`AND POTENTIAL MOTIONS was served on Petitioner’s counsel of record, on
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`the date set forth below, by email to the following email address authorized by the
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`Petitioner in its Petition for IPR:
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`Daniel W. McDonald
`Merchant & Gould P.C.
`80 South 8th St., Suite 3200
`Minneapolis, MN 55402
`DMcDonald@merchantgould.com
`IPR.17358.0005USWX@merchantgould.com
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`
`Dianna G. El Hioum
`Merchant & Gould P.C.
`767 Third Avenue, 23rd Floor
`New York, NY 10017-2023
`DElHioum@merchantgould.com
`IPR.17358.0005USWX@merchantgould.com
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`Dated: December 3, 2014.
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`By: /Luke Anderson/
`Luke Anderson
`US Patent Reg. No. 44,507
`LAnderson@MaxwellAndersonLaw.com
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`3
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