`Paper No. 11
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`
`ATopTech, Inc.
`Petitioner
`
`v.
`
`Synopsys, Inc.
`Patent Owner
`___________
`
`Case IPR2014-01145
`Patent 6,237,127
`___________
`
`Before TRENTON A. WARD, PETER P. CHEN, and FRANCES L.
`IPPOLITO, Administrative Patent Judges
`
`PETITIONER’S INITIAL LIST OF PROPOSED MOTIONS
`
`
`
`IPR2014-1145
`Paper No. 11
`
`Pursuant to the Decision of the Board to institute inter partes review (Paper
`
`7, January 21, 2015) and the Office Patent Trial Practice Guide, 77 Fed. Reg.
`
`48756 (August 14, 2012), Petitioner ATopTech, Inc. does not currently anticipate
`
`filing any motions.
`
`Petitioner advises the Board that on February 18, 2015, Petitioner filed a
`
`new related IPR, Case No. IPR2015-00760 (the “`760 IPR”), which challenges
`
`claims 5 and 6 of U.S. Patent No. 6,237,127, the same patent involved in this
`proceeding. The Board denied institution of claims 5 and 61 in the present
`proceeding. The `760 IPR was filed with a motion for joinder under Rule
`
`42.122(b). Petitioner proposes discussing a briefing schedule for the motion for
`
`joinder in the `760 IPR as well as the due date for Patent Owner’s preliminary
`
`response in that proceeding at the telephone conference.
`
`Dated: February 23, 2015
`
`Respectfully submitted,
`/s/ Jeffrey A. Miller
`Jeffrey A. Miller
`Registration No. 35,287
`KAYE SCHOLER LLP
`Two Palo Alto Square, Suite 400
`3000 El Camino Real
`Palo Alto, CA 94306
`Tel.: (650) 319-4500
`Fax: (650) 319-4700
`Email: Jeffrey.miller@kayescholer.com
`
`Counsel for Petitioner
`
`1 The Board also did not institute trial on claims 12 and 13 of the `127 patent in this
`proceeding, but those claims are not challenged in the new `760 IPR.
`
`1
`
`
`
`IPR2014-1145
`Paper No. 11
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that a copy of the foregoing is being served on
`
`counsel of record by filing this document through the Patent Review Processing
`
`System as well as delivering a copy via Email directed to:
`
`David B. Cochran
`Joseph M. Sauer
`JONES DAY
`North Point
`901 Lakeside Avenue
`Cleveland, Ohio 44114
`dcochran@jonesday.com
`jmsauer@jonesday.com
`
`David W. Wu
`JONES DAY
`1755 Embarcadero Road
`Palo Alto, CA 94303
`dwwu@jonesday.com
`
`Dated: February 23, 2015
`
`Respectfully submitted,
`
`:
`
`/s/ Jeffrey A. Miller
`Jeffrey A. Miller
`Registration No. 35,287
`KAYE SCHOLER LLP
`Two Palo Alto Square, Suite 400
`3000 El Camino Real
`Palo Alto, CA 94306
`Tel.: (650) 319-4500
`Fax: (650) 319-4700
`Email:
`Jeffrey.miller@kayescholer.com
`
`Counsel for Petitioner
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