`U.S. Patent No. 8,532,641 110797-0004-656
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`SAMSUNG ELECTRONICS CO., LTD;
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioners
`v.
`
`AFFINITY LABS OF TEXAS, LLC
`Patent Owner
`______________
`
`Case IPR2014-01182
`Patent 8,532,641
`______________
`
`Before the Honorable KEVIN F. TURNER, LYNNE E. PETTIGREW, and
`JON B. TORNQUIST, Administrative Patent Judges.
`
`PETITIONERS’ LIST OF PROPOSED MOTIONS
`
`
`
`Further to the Board’s Scheduling Order (Paper 11) setting an Initial
`
`Conference Call for March 3, 2015, and directing the parties to pages 48,756, 48, 765-
`
`66 of the Office Patent Trial Practice Guide, 77 Fed. Reg. 48,756, 48,765-66 (Aug. 14,
`
`2012), and Board’s February 24, 2014 email rescheduling the Initial Conference Call
`
`for March 5th, 2015, Petitioners Samsung Electronics Co., Ltd., and Samsung
`
`Electronics America, Inc., (“Petitioners”) hereby submit a list of proposed motions
`
`presently contemplated by Petitioners and which Petitioners intend to raise during the
`
`Initial Conference Call:
`
`
`
`IPR2014-01182 Attorney Docket No.
`U.S. Patent No. 8,532,641 110797-0004-656
` Potential motion(s) for Pro Hac Vice Admission pursuant to Rule 42.10(c)
`
`(as previously authorized by the Board in Paper 3); and
`
` Potential motion(s) to exclude evidence based on the Federal Rules of
`
`Evidence (as scheduled by the Board in Paper 11).
`
`During the Initial Conference Call Petitioners also expect—in light of the Board’s
`
`coordination of the schedule in this proceeding with the schedules in IPR2014-01181
`
`and IPR2014-01184—to respectfully request that the Board confirm that it expects to
`
`issue concurrent final written decisions in these proceedings. Although these are, as
`
`noted, the motions presently contemplated by Petitioners,
`
`it
`
`is Petitioners’
`
`understanding that, as stated in the Trial Practice Guide (at 48,765) “[s]ubmission of
`
`[this] list would not preclude the filing of additional motions not contained in the
`
`list.”
`
`Respectfully submitted,
`
`
`
`
`
`
`
`March 3, 2015
`
`
`
`By: /J. Steven Baughman/
`Gabrielle E. Higgins (Backup Counsel)
`J. Steven Baughman (Lead Counsel)
`Reg. No. 38,916
`Reg. No. 47,414
`ROPES & GRAY LLP
`ROPES & GRAY LLP
`1900 University Avenue – Suite 600
`One Metro Center, 700 12th St. – Ste. 900
`East Palo Alto, CA 94303
`Washington, DC 20005-3948
`P: 650-617-4000 /F: 650-617-4090
`P: 202-508-4606 / F: 202-383-8371
`steven.baughman@ropesgray.com
`gabrielle.higgins@ropesgray.com
`
`Mailing address for all PTAB correspondence: ROPES & GRAY LLP
`IPRM – Floor 43, Prudential Tower, 800 Boylston Street, Boston, MA 02199-3600
`
`Attorneys for Petitioners, Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc.
`
`
`
`2
`
`
`
`
`
`
`
`
`
`IPR2014-01182 Attorney Docket No.
`U.S. Patent No. 8,532,641 110797-0004-656
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of PETITIONERS’ LIST OF
`
`
`
`PROPOSED MOTIONS has been served
`
`in
`
`its entirety by causing
`
`the
`
`aforementioned document to be electronically mailed, pursuant to the Samsung and
`
`HTC Petitioners’ and Patent Owner’s agreement, to the following attorneys of record
`
`for the Patent Owner listed below:
`
`
`
`
`Patent Owner’s
`Counsel of Record:
`
`Ryan M. Schultz
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`rmschultz@rkmc.com
`
`Thomas R. DeSimone
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`TRDeSimone@rkmc.com
`
`/Carolyn L. Redding/
`Carolyn L. Redding
`
`ROPES & GRAY LLP
`
`
`
`
`
`March 3, 2015
`
`
`Dated:
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