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UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`ORACLE CORPORATION, NETAPP INC. and
`HUAWEI TECHNOLOGIES CO., LTD,
`Petitioners,
`
`v.
`
`CROSSROADS SYSTEMS, INC.
`Patent Owner
`
`____________
`
`Case IPR2014-01207
`Patent No. 7,051,147
`____________
`
`
`
`PATENT OWNER’S CERTIFICATION REGARDING CORRECTED
`EXHIBITS AND MOTION TO EXPUNGE
`
`
`
`

`
`Concurrently herewith, Patent Owner files the following substitute exhibits,
`
`with the changes to the original exhibit noted:
`
`1) Exhibit 2053, Declaration of Dr. John Levy, Ph.D (corrections:
`
`addition of Appendices A-C (Resume, Litigation Experience and
`
`Materials Considered) and updated page numbering to reflect the
`
`new total number of pages).
`
`The substitute exhibit is identical to the originally filed exhibit except for the
`
`identified corrections. The errors
`
`in
`
`the originally filed document were
`
`unintentional and the result of clerical error.
`
`Authority for filing the substitute exhibits was granted by the Board pursuant
`
`to orders in related proceedings IPR2015-00822 (Paper 13) and IPR2015-00825
`
`(Paper 15).1 Petitioners do not oppose these corrections.
`
`
`1 On July 7, 2015, the Board held a conference call in related proceedings
`
`IPR2015-00822 and -00825. Counsel for all parties in this proceeding were
`
`present. During the call, counsel for Patent Owner requested the Board’s guidance
`
`regarding how to correct certain of Patent Owner’s exhibits which were filed with
`
`clerical errors. The request pertained to this proceeding (and others), and was
`
`understood as such by all counsel, but not the -00822 and -00825 proceedings.
`
`
`
`
`
`1
`
`

`
`Also, pursuant to the Board’s orders in these related proceedings, Patent
`
`Owner requests the Board expunge the originally filed Exhibit 2053 pursuant to its
`
`authority to manage the record under 37 C.F.R. §§ 42.5 and 42.7.
`
`Respectfully submitted,
`SPRINKLE IP LAW GROUP
`
`
`/John L. Adair/
`John L. Adair
`Registration No. 48,828
`Counsel for Patent Owner
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Dated: August 7, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`However, the Board’s order authorizing filing of the substitute exhibit(s) was
`
`issued in the -00822 and -00825 proceedings. See IPR2015-00822, Paper 13 at 2
`
`and IPR2015-00825, Paper 15 at 2.
`
`
`
`2
`
`

`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned certifies service of Patent Owner’s Certification Regarding
`Corrected Exhibits and Motion to Expunge, and substitute Exhibit 2053, on August
`7, 2015 on counsel for Petitioners by e-mail (pursuant to agreement) at the below
`e-mail addresses:
`
`
`Greg Gardella – CPDocketGardella@oblon.com
`Scott McKeown – CPDocketMckeown@oblon.com
`Oblon
`1940 Duke Street
`Alexandria, VA 22314
`
`By:
`
`
` /John L. Adair/
`John L. Adair

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