`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`SAMSUNG ELECTRONICS CO., LTD; SAMSUNG ELECTRONICS AMERICA,
`INC.; SAMSUNG TELECOMMUNICATIONS AMERICA, LLC
`Petitioners
`v.
`
`AFFINITY LABS OF TEXAS, LLC
`Patent Owner
`______________
`
`Case IPR2014-01181
`Patent 8,532,641
`______________
`
`
`
`Before KEVIN F. TURNER, LYNNE E. PETTIGREW, and JON B.
`TORNQUIST, Administrative Patent Judges.
`
`
`
`
`PATENT OWNER’S LIST OF PROPOSED MOTIONS
`
`Further to the Board’s Scheduling Order (Paper 11) setting an Initial
`
`Conference Call for March 3, 2015 that was rescheduled to March 5, 2015 through
`
`stipulation by the parties and granted by the Board, and in light of the requirements
`
`listed on pages 48765-66 of the Office Trial Practice Guide, 77 Fed. Reg. 48756 (Aug.
`
`14, 2012), Patent Owner hereby submits a list of proposed motions presently
`
`contemplated by Patent Owner and which Patent Owner intends to raise during the
`
`Initial Conference Call:
`
`
`
`1
`
`
`
` A possible motion to expunge under 37 C.F.R. §§ 42.7 and 42.23(b) any
`
`new evidence or arguments presented by Petitioners in their reply brief in support of
`
`the Petition. In the alternative, Patent Owner will request a sur-reply to address new
`
`arguments or evidence raised by Petitioners in their reply brief;
`
` A possible motion to amend one or more of the claims upon which inter
`
`partes review has been instituted pursuant to Rule 42.121;
`
` A possible motion(s) to exclude evidence based on the Federal Rules of
`
`Evidence.
`
`
`
`Patent Owner further notes that, although it does not at this time have reason
`
`to believe a Motion for Protective Order pursuant to Rule 42.54 will be necessary,
`
`should such a need arise Patent Owner would contemplate approaching the Board
`
`with a proposed protective order after conferring with counsel for Petitioners.
`
`Respectfully submitted,
`
`/Ryan M. Schultz/
`Registration No. 65,143
`Robins Kaplan LLP
`2800 LaSalle Plaza
`800 LaSalle Ave
`Minneapolis, MN 55402
`
`
`
`Dated: March 3, 2015
`
`
`
`
`
`
`
`
`2
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
` I hereby certify that on this 3rd of March 2015, a copy of this Patent Owner’s
`List of Proposed Motions has been served in its entirety by e-mail on the Petitioners:
`
`Respectfully submitted,
`
`/Ryan M. Schultz/
`Registration No. 65,143
`Attorney for Patent Owner
`
`
`Steven.baughman@ropesgray.com
`Gabrielle.higgins@ropesgray.com
`SamsungIPRService@ropesgray.com
`
`
`
`Dated: March 3, 2015
`
`
`
`
`
`
`3
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