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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`ZHONGSHAN BROAD OCEAN MOTOR CO., LTD.
`Petitioner
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`V.
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`NIDEC MOTOR CORPORATION
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`Patent Owner
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`Case IPR2014-01121
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`Patent 7,626,349
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`RESPONSE TO NOTICE OF FILING DATE ACCORDED T0 PETITION
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`AND TIME FOR FILING PATENT OWNER PRELIMINARY RESPONSE
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`Dear Sirs:
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`In response to the Notice of Filing Date Accorded to Petition And Time For
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`Filing Patent Owner Preliminary Response mailed July 24, 2014, submitted
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`herewith please find Petitioner’s Corrected Petition for Inter Partes Review of US.
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`Patent No. 7,626,349.
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`40870264.]
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`_1_
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`
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`The Petition has been revised to place the material contained within claim
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`charts in the original Petition to text format within the revised Petition document.
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`No substantive changes (e.g., new grounds) have been made to the petition.
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`In addition,
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`the first page of each Exhibit has been labeled with the
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`Petitioner’s name and Exhibit number in accordance with the Notice.
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`Petitioner believes that no fee is due with this response. The Commissioner
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`is hereby authorized to charge any fee which may be required in connection with
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`this submission to Deposit Account No. 06-23 80, under Order No.
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`1 1405494 from
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`which the undersigned is authorized to draw.
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`Dated: July 28, 2014
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`Respectful :ubmitted,
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`Nathan J. Rees (Reg. No. 63,820)
`Daniel A. Prati (Reg. No. 65,869)
`FULBRIGHT & JAWORSKI L.L.P.
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`2200 Ross Avenue, Suite 2800
`Tel: 214.855.7164
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`Fax: 214.855.8200
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`natc.rees@nortonrosefulbright.com
`danny.prati@nortonrosefulbright.com
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`Attorneys for Petitioners Zhongshan
`Broad Ocean Motor Co., Ltd., Broad
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`Ocean Motor LLC, and Broad Ocean
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`Technologies, LLC
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`Case 1PR2014-01121
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`40370264.]
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`_2_
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`
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`Certificate of Service
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`Pursuant to 37 C.F.R. § 42.8(e) and 37 C.F.R. § 42.105(b), the undersigned
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`certifies that on July 28, 2014, a complete and entire copy of this Response to
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`Notice of Filing Date Accorded to Petition And Time For Filing Patent Owner
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`Preliminary Response was electronically served on the Patent Owner of record (as
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`agreed
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`upon
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`by
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`counsel)
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`at
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`sbrown@hoveywilliamscom,
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`mwalters@hoveywilliams.com, and litigation@hoveywilliams.com.
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`Additionally, the undersigned certifies that on July 28, 2014, a complete and
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`entire copy of this Response to Notice of Filing Date Accorded to Petition And
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`Time For Filing Patent Owner Preliminary Response was electronically served on
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`the
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`Patent
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`Owner’s
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`below-listed
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`counsel
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`of
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`record
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`at
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`jschwent@thompsoncobumcom,
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`dj inkins@thompsoncoburn.com,
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`and
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`syoo@thomponsoburn.com, in the co—pending litigation Nidec Motor Corporation
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`v. Broad Ocean Motor LLC et 51]., Civil Action No. 4:13—CV—01895—JCH (E. D.
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`Mo.) as agreed upon by the parties.
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`Respwubmitted,
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`Nathan J. Rees (Reg.\N0.—6'3';SZUj/l
`FULBRIGHT & JAWORSKI L.L.P.
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`2200 Ross Avenue, Suite 2800
`Tel: 214.855.7164
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`Fax: 214.855.8200
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`nate.rees@nortonrosefulbright.com
`Attorney for Petitioners Zhongshan Broad Ocean
`Motor Co., Ltd, Broad Ocean Motor LLC, and
`Broad Ocean Technologies, LLC
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`408702641
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`_3 _
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`