`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`
`FORD MOTOR COMPANY
`Petitioner,
`
`v.
`
`PAICE LLC
`Patent Owner.
`
`______________
`
`
`U.S. Patent No. 7,455,134 to Severinsky et al.
`
`IPR Case No.: IPR2014-00852
`
`
`______________
`
`
`
`
`
`PETITIONER’S UPDATED MANDATORY NOTICE
`UNDER 37 C.F.R. § 42.8
`
`
`
`
`
`
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.8, the Petitioner hereby submits the following update
`
`to the Mandatory Notice originally provided in the Petition for Inter Partes Review of U.S.
`
`Patent No. 7,455,134 (“the ‘134 patent”).
`
`
`
`Related Matters - 37 C.F.R. § 42.8(b)(2)
`
`Petitioner identifies the following related judicial matter: Paice, LLC and the
`
`Abell Foundation, Inc. v. Ford Motor Company, Case Number 1-14-cv-00492 filed on
`
`February 19, 2014 in the District of Maryland, Baltimore Division. The ‘134 Patent is
`
`being asserted in this proceeding, along with four other patents within the same
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`family. On October 8, 2014, the Maryland District Court has issued an order denying
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`the Patent Owner’s motion for a preliminary injunction to enjoin Petitioner from
`
`pursuing the present Petition.
`
`Petitioner is also aware that the ‘134 patent is being asserted in Paice LLC and
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`The Abell Foundation, Inc. v. Hyundai Motor America, Kia Motors Corporation, Hyundai Motor
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`Company and Kia Motors America, Inc., Case Number 1:2012-cv-00499, District of
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`Maryland, Baltimore Division filed on February 16, 2012.
`
`Petitioner has filed the following related petitions: IPR2014-00568, IPR2014-
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`00570, IPR2014-00571, IPR2014-01416, IPR2014-00875, IPR2014-00579, IPR2014-
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`00884, IPR2014-01415 and IPR2014-00904.
`
`
`
`1
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`
`
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`
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`Dated: October 20, 2014
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
` /Sangeeta G. Shah/
`Sangeeta G. Shah (Reg. No. 38,614)
`Frank A. Angileri (Reg. No. 36,733)
`Michael D. Cushion (Reg. No. 55,094)
`Andrew B. Turner (Reg. No. 63,121)
`Brooks Kushman P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`(248) 358-4400
`
`Lissi Mojica (Reg. No. 63,421)
`Kevin Greenleaf (Reg. No. 64,062)
`Dentons US LLP
`1530 Page Mill Road; Suite 200
`Palo Alto, CA 94304-1125
`F +1 650 798 0310
`
`Attorneys for Patent Owner
`
`2
`
`
`
`
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`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on October 20, 2014, a complete and
`
`entire copy of Petitioner’s Updated Mandatory Notice Under 37 C.F.R. § 42.8,
`
`was served via electronic mail by serving the correspondence email address of record
`
`as follows:
`
`LEAD COUNSEL
`Timothy W. Riffe, Reg. No. 43,881
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Tel: (202) 783-5070
`Fax: (202) 783-2331
`Email: Riffe@fr.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`BACK-UP COUNSEL
`Kevin E. Greene, Reg. No. 46,031
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Tel: (202) 783-5070
`Fax: (202) 783-2331
`Email: Greene@fr.com
`
`
`
`Respectfully submitted,
`
`
`
` /Sangeeta G. Shah/
`Sangeeta G. Shah (Reg. No. 38,614)
`Frank A. Angileri (Reg. No. 36,733)
`Michael D. Cushion (Reg. No. 55,094)
`Andrew B. Turner (Reg. No. 63,121)
`Brooks Kushman P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`(248) 358-4400
`
`Lissi Mojica (Reg. No. 63,421)
`Kevin Greenleaf (Reg. No. 64,062)
`Dentons US LLP
`1530 Page Mill Road; Suite 200
`Palo Alto, CA 94304-1125
`F +1 650 798 0310
`
`Attorneys for Petitioner
`
`3
`
`
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