`__________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`__________________________________
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`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
`__________________________________
`
`PATENT OWNER’S REQUEST FOR CANCELATION OF
`CLAIMS 31 AND 32
`
`INTER PARTES REVIEW OF
`U.S. PATENT NO. 5,954,781
`__________________________________
`
`Filed on behalf of Patent Owner:
`James A. Shimota (appearing pro hac vice)
`Howard Levin (Reg. No. 50,480)
`Aaron Taggart (pro hac vice motion to be filed)
`MAVRAKAKIS LAW GROUP LLP
`180 North LaSalle Street, Suite 2215
`Chicago, IL 60610
`Telephone: 312-216-1620
`
`Patrick Richards (Reg. No. 48,905)
`RICHARDS PATENT LAW, PC.
`233 S. Wacker Dr., 84th Floor
`Chicago, IL 60606
`Telephone: 312-283-8555
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`REQUEST
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`Pursuant to 37 C.F.R. § 42.73, the Patent Owner respectfully requests
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`the cancelation of claims 31 and 32 of U.S. Patent No. 5,954,781 (“the ‘781
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`patent”). Further, as ordered by the Board on December 15, 2014, a copy of
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`the statutory disclaimer for claims 31 and 32 of the ‘781 patent, which was
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`recorded on December 10, 2014, is attached hereto as Exhibit 2001.
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`CONCLUSION
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`For the foregoing reasons, Patent Owner respectfully requests
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`cancelation of claims 31 and 32 of the ‘781 patent.
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`Dated: December 29, 2014
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`Respectfully submitted,
`
`/Patrick D. Richards/
`Patrick Richards (Reg. No. 48,905)
`Richards Patent Law P.C.
`Willis (Sears) Tower
`233 S. Wacker Dr., 84th Floor
`Chicago, IL 60606
`Telephone: (312) 283-8555
`
`Counsel for Patent Owner
`
`
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