`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`MERCEDES-BENZ USA, LLC
`and MERCEDES-BENZ U.S. INTERNATIONAL, INC.,
`Petitioner,
`
`v.
`
`VELOCITY PATENT, LLC,
`Patent Owner.
`
`
`Case IPR2014-01247
`Patent 5,954,781
`
`
`
`PETITIONER’S NOTICE OF COMPLIANCE AND
`TRANSMITTAL OF CORRECTED PETITION
`
`
`
`
`
`In the Board’s Notice of Filing Date Accorded to Petition (Paper No. 3), the
`
`Board identified defects in the claim charts and spacing in the Petition for this
`
`proceeding filed August 4, 2014.
`
`The Board indicated that the claim charts “should only be used to provide an
`
`element-by-element showing as to how the prior art teaches the limitations of a
`
`claim (e.g., citations to a prior art reference, quotations from a prior art reference)”
`
`and that the charts “may not include arguments, claim construction, statements of
`
`the law, or detailed explanations as to why a claim limitation is taught or rendered
`
`obvious by the prior art.” Paper No. 3 at page 2. The Board further indicated that
`
`the document must be double-spaced and pointed out that the footnotes in the
`
`Petition should be reformatted accordingly. Id.
`
`The Board stated that Petitioner should submit a Corrected Petition for the
`
`present case. Id. Petitioner is filing a Corrected Petition concurrently with this
`
`Notice in accordance with the comments in Paper No. 3. Petitioner submits that
`
`the Corrected Petition complies with the Board’s rules. Specifically, Petitioner has
`
`removed all the claim charts in the Corrected Petition and has presented the content
`
`previously in the claim charts as prose. The footnotes have also been reformatted
`
`(i.e., double-spaced) as requested.
`
`Petitioner submits that no substantive changes have been made to the
`
`Petition due to the reformatting to remove the charts and correct the spacing in the
`
`
`
`
`
`footnotes. Petitioner requests entry of the Corrected Petition and institution of
`
`Inter Partes Review on the grounds identified therein.
`
`Respectfully submitted,
`
`
`
`
` /Celine J. Crowson/
`Celine Jimenez Crowson (Reg. No. 40,357)
`Raymond A. Kurz (pro hac vice motion to be filed)
`Joseph J. Raffetto (Reg. No. 66,218)
`HOGAN LOVELLS US LLP
`555 13th Street, N.W.
`Washington, D.C. 20004
`Telephone: 202.637.5600
`
`Counsel for Petitioner Mercedes-Benz USA, LLC
`and Mercedes-Benz U.S. International, Inc.
`
`
`
`
`
`
`
`Dated: August 20, 2014
`
`
`
`
`
`Certificate of Service
`
`I certify that on August 20, 2014, a copy of this Notice has been served on
`
`
`
`Patent Owner via Federal Express at the following address:
`
`RICHARDS PATENT LAW, P.C.
`233 S. Wacker Dr., 84th Floor
`Chicago, IL 60606
`
`
` /Joseph J. Raffetto/
`Joseph J. Raffetto (Reg. No. 66,218)
`Counsel for Petitioner Mercedes-Benz USA, LLC
`and Mercedes-Benz U.S. International, Inc.
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