`___________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________
`
`ZHONGSHAN BROAD OCEAN MOTOR CO., LTD.
`Petitioner
`
`v.
`
`NIDEC MOTOR CORPORATION
`Patent Owner
`___________________________
`
`Case IPR2014-01121
`Patent 7,626,349
`___________________________
`
`PETITIONER’S LIST OF ANTICIPATED MOTIONS
`IN ADVANCE OF INITIAL CONFERENCE CALL
`
`NY 785597v.1
`
`
`
`In advance of the Initial Conference Call on February 24, 2015 at 3:00 p.m.
`
`(ET), Petitioner Zhongshan Broad Ocean Motor Co., Ltd., et al. (“Petitioner”)
`
`submits the following list of motions that it either has already filed or that it
`
`anticipates filing during this trial. See Office Patent Trial Practice Guide, Fed. Reg.
`
`Vol. 77, No. 157 at 48765 (Aug. 14, 2012). This listing is without prejudice to
`
`Petitioner’s right to seek authorization to bring additional motions as circumstances
`
`warrant. See Office Patent Trial Practice, Fed. Reg. Vol. 77, No. 157 at 48763
`
`(Aug. 14, 2012).
`
`•
`
`•
`
`•
`
`Petitioner has filed a Request for Rehearing (Paper No. 22).
`
`Petitioner has filed a Second Petition on the patent at
`
`issue,
`
`IPR2015-00762, and a motion to join the subject inter partes trial,
`
`IPR2014-01121.
`
`If the Joinder Motion is granted, Petitioner anticipates filing a motion
`
`to expedite Patent Owner’s Preliminary Response under 37 C.F.R.
`
`§42.5(c)(1).
`
`Dated: February 20, 2015
`
`Respectfully submitted,
`
`/ Steven F. Meyer /
`Steven F. Meyer (Reg. No. 35,613)
`LOCKE LORD LLP
`smeyer@lockelord.com
`Attorneys for Petitioner Zhongshan, Broad Ocean
`Motor Co., Ltd.;, Broad Ocean Motor LLC; and
`Broad Ocean Technologies, LLC
`
`NY 785597v.1
`
`1
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §42.6(e) and 37 C.F.R. §42.105(b), the undersigned
`hereby certifies that on February 20, 2015, a complete and entire copy of the
`foregoing Petitioner’s List of Anticipated Motions in Advance of Initial
`Conference Call was electronically served in its entirety on the Patent Owner of
`record
`(as
`agreed
`upon
`by
`counsel)
`at
`sbrown@hoveywilliams.com,
`mwalters@hoveywilliams.com, and litigation@ hoveywilliams.com.
`
`Additionally, the undersigned certifies that on February 20, 2015, a complete
`and entire copy of the foregoing Petitioner’s List of Anticipated Motions in
`Advance of Initial Conference Call was electronically served on the Patent
`Owner’s below-listed counsel of
`record at
`jschwent@thompsoncoburn.com,
`djinkins@thompsoncoburn.com,
`and
`syoo@thompsoncoburn.com,
`in
`the
`co-pending litigation Nidec Motor Corporation v. Broad Ocean Motor LLC et al.,
`Civil Action No. 4:13-CV-01895-JCH (E.D. Mo.), as agreed upon by the parties.
`
`Dated: February 20, 2015
`
`/ Steven F. Meyer /
`Steven F. Meyer (Reg. No. 35,613)
`LOCKE LORD LLP
`Three World Financial Center
`New York, New York 10281-2101
`(212) 415-8535
`smeyer@lockelord.com
`
`Attorneys for Petitioner Zhongshan
`Broad Ocean Motor Co., Ltd.;
`Broad Ocean Motor LLC; and
`Broad Ocean Technologies, LLC
`
`NY 785597v.1
`
`
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