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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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`HTC CORPORATION and HTC AMERICA, INC.
`Petitioners
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`v.
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`E-WATCH, INC. and E-WATCH CORPORATION
`Patent Owner
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`CASE: IPR2014-00989
`Patent No. 7,643,168 B2
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`PETITIONER’S LIST OF PROPOSED MOTIONS
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`January 6, 2015
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`The Patent Trial and Appeal Board instituted an IPR trial in case number
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`PTAB Case No. IPR2014-00989
`Patent 7,643,168 B2
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`IPR2014-00989 on December 9, 2014 (Institution Decision, Paper 6). In advance
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`of the initial conference call scheduled for Thursday, January 8, 2015, Petitioners
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`HTC Corporation and HTC America, Inc. (collectively “Petitioners”) hereby
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`provide a list of the proposed motions it may file in the above-captioned inter
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`partes review proceeding. Although motions to exclude evidence and motions for
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`observations on cross-examination have been authorized by the Board in the
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`Scheduling Order (Paper 7 at 3-6), Petitioners identify a list of motions here to
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`preserve the right to file them. Petitioners reserve the right to seek permission to
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`file additional motions not listed below pursuant to the Board’s authorization.
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`PETITIONER’S PROPOSED MOTIONS
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`1. Motions to submit supplemental information;
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`2. Motions to submit supplemental evidence;
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`3. Motions to exclude evidence;
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`4. Motion for observation on cross examination;
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`5. Motions for additional discovery;
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`6. Motion to request oral argument/hearing; and
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`1
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`PTAB Case No. IPR2014-00989
`Patent 7,643,168 B2
`7. Additional motions as permitted by the Board trial rules and procedures, or
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`as authorized by the Board.
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`Dated: January 6, 2015
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`PERKINS COIE LLP
`11988 El Camino Real, Suite 350
`San Diego, CA 92130
`(858) 720-5700
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`Respectfully submitted,
` /Bing Ai/
`Lead Counsel,
`Bing Ai, Reg. No. 43,312
`Back-Up Counsel
`Cheng C. (Jack) Ko, Reg. No. 54,227
`Kevin Patariu, Reg. No. 63,210
`Babak Tehranchi, Reg. No. 55,937
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`HTC Corporation and HTC America, Inc.
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`2
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`PTAB Case No. IPR2014-00989
`Patent 7,643,168 B2
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true copy of the foregoing
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`PETITIONER’S LIST OF PROPOSED MOTIONS has been served in its entirety
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`this 6th day of January 2015 by electronic mail as agreed upon by the parties on
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`the Patent Owner via its attorneys of record:
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`Robert C. Curfiss
`19826 Sundance Drive
`Humble, Texas 77346-1402
`bob@curfiss.com
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`David O. Simmons
`IVC Patent Agency
`P.O. Box 26584
`Austin, Texas 77755
`Dsimmons1@sbcglobal.net
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`Dated: January 6, 2015
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`PERKINS COIE LLP
`11988 El Camino Real, Suite 350
`San Diego, CA 92130
`(858) 720-5700
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`Respectfully submitted,
` /Bing Ai/
`Lead Counsel,
`Bing Ai, Reg. No. 43,312
`Back-Up Counsel
`Cheng C. (Jack) Ko, Reg. No. 54,227
`Kevin Patariu, Reg. No. 63,210
`Babak Tehranchi, Reg. No. 55,937
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`HTC Corporation and HTC America, Inc.
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