`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`ARTSANA USA, INC.,
`Petitioner
`v.
`KOLCRAFT ENTERPRISES, INC.,
`Patent Owner
`____________
`Case IPR2014-01053
`Patent 8,388,501
`____________
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`PATENT OWNER’S LIST OF PROPOSED MOTIONS
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`IPR2014-01053
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`Pursuant to the Scheduling Order [Paper 15] regarding the initial conference
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`call scheduled for January 20, 2015 at 1:00 PM Eastern Time, and the requirement
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`that the parties prepare for the call as directed in the Office Trial Practice Guide,
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`77 Fed. Reg. 48756, Patent Owner Kolcraft Enterprises, Inc. (“Kolcraft” or “Patent
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`Owner”) states as follows:
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`List of Motions:
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`1. A motion to amend the patent; and
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`2. A motion to substitute counsel.
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`Kolcraft may move to amend one or more claims of the ‘501 patent. As
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`Kolcraft is still evaluating the Board’s Decision, as well as the cited references and
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`arguments addressed therein, Kolcraft expressly reserves the right not to file the
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`motion to amend. Kolcraft’s motion to substitute counsel is discussed below.
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`Other Matters:
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`1. Although Kolcraft does not believe it is necessary, Kolcraft is willing to
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`provide an opposition to Petitioner’s pending request for rehearing should it be
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`useful to the Board in any respect.
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`2. Kolcraft seeks the Board’s authorization to move to substitute the below-
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`listed practitioners associated with customer number 64,194 as the new counsel for
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`Kolcraft and concurrently withdraw the practitioners associated with customer
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`number 98,580, specifically, attorneys Robert A. Conley (Reg. No. 55,846) and
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`IPR2014-01053
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`Brian E. Haan (Reg. No. 62,567). The previously accepted pro hac vice power of
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`attorney to Raymond P. Niro, Jr. will not be revoked. Following the substitution,
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`Kolcraft’s counsel will be as follows:
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`Lead Counsel
`Anthony E. Dowell, Reg. No. 39,661
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`aedowell@niro-mcandrews.com
`Postal and Hand-Delivery Address:
`Niro, McAndrews, Dowell &
`Grossman, LLC
`200 West Madison Street
`Suite 2040
`Chicago, Illinois 60606
`Telephone: (312) 755-8578
`Fax: (312) 674-7481
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`Dated: January 16, 2015
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`Back-up Counsel
`Raymond P. Niro, Jr., Previously
`Admitted Pro Hac Vice
`rnirojr@niro-mcandrews.com
`Postal and Hand-Delivery Address:
`Niro, McAndrews, Dowell &
`Grossman, LLC
`200 West Madison Street
`Suite 2040
`Chicago, Illinois 60606
`Telephone: (312) 755-8576
`Fax: (312) 674-7481
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`Respectfully submitted,
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`/ Brian E. Haan /
`Brian E. Haan (Reg. No. 62,567)
`NIRO, HALLER & NIRO
`181 West Madison, Suite 4600
`Chicago, IL 60602
`Phone: (312) 236-0733
`Fax: (312) 236-3137
`Email: BHaan@nshn.com
`Attorney for Patent Owner
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`IPR2014-01053
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`Certificate of Service
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`Pursuant to 37 CFR § 42.6(e), the undersigned hereby certifies that on
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`January 16, 2015 the foregoing PATENT OWNER’S LIST OF PROPOSED
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`MOTIONS was filed electronically via the Patent Review Processing System and
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`served via electronic transmission on the following, as agreed to by Petitioner's
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`Service Information Under 37 C.F.R. § 42.8(b)(4) in the June 27, 2014 Petition:
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`Anthony S. Volpe, Reg. No. 28,377
`Ryan W. O'Donnell, Reg. No. 53,401
`Volpe and Koenig, P.C.
`30 South 17th Street, Suite 1800
`Philadelphia, PA 19103-4009
`Telephone: (215) 568-6400
`Facsimile: (215) 568-6499
`Email: patents@vklaw.com
`avolpe@vklaw.com
`rodonnell@vklaw.com
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`Respectfully submitted,
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`Dated: January 16, 2015
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`/ Brian E. Haan /
`Brian E. Haan (Reg. No. 62,567)
`NIRO, HALLER & NIRO
`181 West Madison, Suite 4600
`Chicago, IL 60602
`Phone: (312) 236-0733
`Fax: (312) 236-3137
`Email: BHaan@nshn.com
`Attorney for Patent Owner
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