`______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
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`SAMSUNG ELECTRONICS CO., LTD; SAMSUNG ELECTRONICS AMERICA,
`INC.; SAMSUNG TELECOMMUNICATIONS AMERICA, LLC
`Petitioners
`v.
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`AFFINITY LABS OF TEXAS, LLC
`Patent Owner
`______________
`
`Case IPR2014-01184
`Patent 8,532,641
`______________
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`
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`Before KEVIN F. TURNER, LYNNE E. PETTIGREW, and JON B.
`TORNQUIST, Administrative Patent Judges.
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`PATENT OWNER’S LIST OF PROPOSED MOTIONS
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`Further to the Board’s Scheduling Order (Paper 11) setting an Initial
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`Conference Call for March 3, 2015 that was rescheduled to March 5, 2015 through
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`stipulation by the parties and granted by the Board, and in light of the requirements
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`listed on pages 48765-66 of the Office Trial Practice Guide, 77 Fed. Reg. 48756 (Aug.
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`14, 2012), Patent Owner hereby submits a list of proposed motions presently
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`contemplated by Patent Owner and which Patent Owner intends to raise during the
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`Initial Conference Call:
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`1
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` A possible motion to expunge under 37 C.F.R. §§ 42.7 and 42.23(b) any
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`new evidence or arguments presented by Petitioners in their reply brief in support of
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`the Petition. In the alternative, Patent Owner will request a sur-reply to address new
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`arguments or evidence raised by Petitioners in their reply brief;
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` A possible motion to amend one or more of the claims upon which inter
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`partes review has been instituted pursuant to Rule 42.121;
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` A possible motion(s) to exclude evidence based on the Federal Rules of
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`Evidence.
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`Patent Owner further notes that, although it does not at this time have reason
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`to believe a Motion for Protective Order pursuant to Rule 42.54 will be necessary,
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`should such a need arise Patent Owner would contemplate approaching the Board
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`with a proposed protective order after conferring with counsel for Petitioners.
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`Respectfully submitted,
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`/Ryan M. Schultz/
`Registration No. 65,143
`Robins Kaplan LLP
`2800 LaSalle Plaza
`800 LaSalle Ave
`Minneapolis, MN 55402
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`Dated: March 3, 2015
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`2
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`CERTIFICATE OF SERVICE
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` 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:
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`Respectfully submitted,
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`/Ryan M. Schultz/
`Registration No. 65,143
`Attorney for Patent Owner
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`Steven.baughman@ropesgray.com
`Gabrielle.higgins@ropesgray.com
`SamsungIPRService@ropesgray.com
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`Dated: March 3, 2015
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`3