`IPR2014-01087 (U.S. 7,147,759)
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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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`GLOBALFOUNDRIES U.S., INC., GLOBALFOUNDRIES DRESDEN
`MODULE ONE LLC & CO. KG, and GLOBALFOUNDRIES DRESDEN
`MODULE TWO LLC & CO. KG.
`Petitioner
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`v.
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`ZOND, INC.
`Patent Owner
`____________________________________________
`
`Case IPR2014-010871
`U.S. PATENT NO. 7,147,759
`Title: HIGH-POWER PULSED MAGNETRON SPUTTERING
`____________________________________________
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`Before KEVIN F. TURNER, DEBRA K. STEPHENS, JONI Y. CHANG,
`SUSAN L.C. MITCHELL, and JENNIFER M. MEYER,
` Administrative Patent Judges
`__________________________________________________________________
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`PETITIONER’S NOTICE OF PROPOSED MOTIONS
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`1 Case IPR 2014-00984 has been joined with the instant proceeding.
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`Petitioner’s Notice of Proposed Motions
`IPR2014-01087 (U.S. 7,147,759)
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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 October 27, 2014 at 2:00
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`p.m. Eastern Time. Pursuant to the instructions for initial conference calls set forth
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`in the Office Trial Practice Guide, GLOBALFOUNDRIES U.S., Inc.,
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`GLOBALFOUNDRIES Dresden Module One LLC & Co. KG, and
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`GLOBALFOUNDRIES Dresden Module Two LLC & Co. KG (collectively
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`“GlobalFoundries” or “Petitioner”), provides the following notice regarding
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`anticipated motions in this proceeding.
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`Proposed Motions: Petitioner has or will file a motion asking that the Board
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`recognize Mr. Brett C. Rismiller as counsel pro hac vice during this proceeding for
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`GlobalFoundries.
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`Petitioner does not presently intend to file any other motions but
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`nevertheless reserves the right to file a motion to exclude evidence or a motion for
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`observation on the dates set forth in the scheduling order for this case, as well as to
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`request permission to file any other motions that become necessary as the case
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`develops (e.g., a motion for discovery).
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`Also, it is noted that Petitioner 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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`
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`Petitioner’s Notice of Proposed Motions
`IPR2014-01087 (U.S. 7,147,759)
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`Date: October 24, 2014
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`Respectfully submitted,
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`/s/ David M. Tennant
`David M. Tennant
`Lead Counsel for Petitioner
`GlobalFoundries
`Registration No. 48,362
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`Petitioner’s Notice of Proposed Motions
`IPR2014-01087 (U.S. 7,147,759)
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`CERTIFICATE OF SERVICE
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`
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`
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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 “PETITIONER’S
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`NOTICE OF PROPOSED MOTIONS” as detailed below:
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`
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`Date of service October 24, 2014
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`Manner of service Email: gonsalves@gonsalveslawfirm.com;
`bbarker@chsblaw.com; kurt@rauschenbach.com
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`Documents served PETITIONER’S 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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`
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`/s/ David M. Tennant
`David M. Tennant
`Registration No. 48,362
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