`IPR2014-00829 (U.S. 6,805,779)
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`Paper No.
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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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`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`TSMC NORTH AMERICA CORPORATION,
`FUJITSU SEMICONDUCTOR LIMITED,
`FUJITSU SEMICONDUCTOR AMERICA, INC.,
`ADVANCED MICRO DEVICES, INC., RENESAS ELECTRONICS
`CORPORATION, RENASAS ELECTRONICS AMERICA, INC.,
`GLOBAL FOUNDRIES U.S., INC., GLOBAL FOUNDRIES DRESDEN
`MODULE ONE LLC & CO. KG, GLOBAL FOUNDRIES DRESDEN
`MODULE TWO LLC & CO. KG, TOSHIBA AMERICA ELECTRONIC
`COMPONENTS, INC., TOSHIBA AMERICA INC., TOSHIBA
`AMERICA INFORMATION SYSTEMS, INC.,
`TOSHIBA CORPORATION, and
`THE GILLETTE COMPANY,
`Petitioners,
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`v.
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`ZOND, LLC,
`Patent Owner
`____________________________________________
`
`Case IPR2014-008291
`Patent 6,805,779 B2
`____________________________________________
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`PETITIONERS’ NOTICE OF PROPOSED MOTIONS
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`1 Cases IPR 2014-00859, IPR2014-01072, and IPR2014-01020 have been joined
`with the instant proceeding.
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`Petitioners’ Notice of Proposed Motions
`IPR2014-00829 (U.S. 6,805,779)
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`NOTICE OF PROPOSED MOTIONS
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`The present notice of proposed motions is filed as a consolidated filing. The
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`initial conference call in this proceeding is scheduled for December 17, 2014 at
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`2:00 pm Eastern Time. Pursuant to the instructions for initial conference calls set
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`forth in the Office Trial Practice Guide, Petitioners provide the following notice
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`regarding anticipated motions in this proceeding.
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`Proposed Motions: As authorized in the Notice of Filing Date Accorded
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`(Paper No. 3), Petitioner Taiwan Semiconductor Manufacturing Company, Ltd.
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`and TSMC North America (collectively “TSMC”) has or will file a motion asking
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`that the Board recognize Mr. Anthony J. Fitzpatrick as counsel pro hac vice during
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`this proceeding for TSMC.
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`Petitioners do not presently intend to file any other motions but nevertheless
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`reserve the right to file a motion to exclude evidence or a motion for observation
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`on the dates set forth in the scheduling order for this case, as well as to request
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`permission to file any other motions that become necessary as the case develops
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`(e.g., a motion for discovery).
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`Also, it is noted that Petitioners and Patent Owner are discussing possible
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`changes to the dates set forth in the scheduling order and may file a notice
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`stipulating to such changes, if agreement is reached.
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`Petitioners’ Notice of Proposed Motions
`IPR2014-00829 (U.S. 6,805,779)
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`Respectfully submitted,
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`/David M. O’Dell/
`David M. O’Dell
`Lead Counsel for Petitioner TSMC
`Registration No. 42,044
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`Date: November 20, 2014
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`Petitioners’ Notice of Proposed Motions
`IPR2014-00829 (U.S. 6,805,779)
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(a), this is to certify that I
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`caused to be served a true and correct copy of the foregoing “PETITIONERS’
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`NOTICE OF PROPOSED MOTIONS” as detailed below:
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`Date of service November 20, 2014
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`Manner of service Email: gonsalves@gonsalveslawfirm.com;
`bbarker@chsblaw.com; kurt@rauschenbach.com
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`Documents served PETITIONERS’ NOTICE OF PROPOSED MOTIONS
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`Persons Served Dr. Gregory J. Gonsalves
`2216 Beacon Lane
`Falls Church, Virginia 22043
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`Bruce Barker
`Chao Hadidi Stark & Barker LLP
`176 East Mail Street, Suite 6
`Westborough, MA 01581
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`/David M. O’Dell/
`David M. O’Dell
`Lead Counsel for Petitioner TSMC
`Registration No. 42,044
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