`U.S. Patent No. 8,532,641 110797-0004-657
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
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`SAMSUNG ELECTRONICS CO., LTD;
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioners
`v.
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`AFFINITY LABS OF TEXAS, LLC
`Patent Owner
`______________
`
`Case IPR2014-01184
`Patent 8,532,641
`______________
`
`Before the Honorable KEVIN F. TURNER, LYNNE E. PETTIGREW, and
`JON B. TORNQUIST, Administrative Patent Judges.
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`PETITIONERS’ 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, and directing the parties to pages 48,756, 48, 765-
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`66 of the Office Patent Trial Practice Guide, 77 Fed. Reg. 48,756, 48,765-66 (Aug. 14,
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`2012), and Board’s February 24, 2014 email rescheduling the Initial Conference Call
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`for March 5th, 2015, Petitioners Samsung Electronics Co., Ltd., and Samsung
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`Electronics America, Inc., (“Petitioners”) hereby submit a list of proposed motions
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`presently contemplated by Petitioners and which Petitioners intend to raise during the
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`Initial Conference Call:
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`
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`IPR2014-01184 Attorney Docket No.
`U.S. Patent No. 8,532,641 110797-0004-657
` Potential motion(s) for Pro Hac Vice Admission pursuant to Rule 42.10(c)
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`(as previously authorized by the Board in Paper 3);
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` Potential motion(s) to exclude evidence based on the Federal Rules of
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`Evidence (as scheduled by the Board in Paper 11);
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` The modified schedule Petitioners have proposed in their pending request
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`for joinder of this proceeding with IPR2015-00820, as set forth in their
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`Motion For Joinder and Request For Shortened Response Time For Patent
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`Owner’s Preliminary Response (IPR2015-00820, Paper 3), to resolve these
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`two proceedings together without delaying resolution of the above-
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`captioned proceeding.
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`During the Initial Conference Call Petitioners also expect—in light of the Board’s
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`coordination of the schedule in this proceeding with the schedules in IPR2014-01181
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`and IPR2014-01182—to respectfully request that the Board confirm that it expects to
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`issue concurrent final written decisions in these proceedings. Although these are, as
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`noted, the motions presently contemplated by Petitioners,
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`it
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`is Petitioners’
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`understanding that, as stated in the Trial Practice Guide (at 48,765) “[s]ubmission of
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`[this] list would not preclude the filing of additional motions not contained in the
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`list.”
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`Respectfully submitted,
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`
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`March 3, 2015
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`2
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`IPR2014-01184 Attorney Docket No.
`U.S. Patent No. 8,532,641 110797-0004-657
`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
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`Mailing address for all PTAB correspondence: ROPES & GRAY LLP
`IPRM – Floor 43, Prudential Tower, 800 Boylston Street, Boston, MA 02199-3600
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`Attorneys for Petitioners, Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc.
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`3
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`IPR2014-01184 Attorney Docket No.
`U.S. Patent No. 8,532,641 110797-0004-657
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of PETITIONERS’ LIST OF
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`
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`PROPOSED MOTIONS has been served
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`in
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`its entirety by causing
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`the
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`aforementioned document to be electronically mailed, pursuant to the Samsung and
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`HTC Petitioners’ and Patent Owner’s agreement, to the following attorneys of record
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`for the Patent Owner listed below:
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`Patent Owner’s
`Counsel of Record:
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`Ryan M. Schultz
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`rmschultz@rkmc.com
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`Thomas R. DeSimone
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`TRDeSimone@rkmc.com
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`/Carolyn L. Redding/
`Carolyn L. Redding
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`ROPES & GRAY LLP
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`
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`March 3, 2015
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`Dated: