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`Paper No. 10
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`LG ELECTRONICS, INC., LG ELECTRONICS U.S.A., INC., AND LG
`ELECTRONICS MOBILECOMM U.S.A, INC.
`Petitioner,
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`v .
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`CYPRESS SEMICONDUCTOR CORP.,
`Patent Owner
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`Case No. IPR2014-01302
`Patent 8,059,015
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`PATENT OWNER’S LIST OF PROPOSED MOTIONS
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`PATENT OWNER’S LIST OF PROPOSED MOTIONS
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`Pursuant to the Office Patent Trial Practice Guide (OPTPG), 77 Fed. Reg.,
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`48765 (Aug. 14, 2012), Patent Owner submits this initial listing of motions that
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`Patent Owner now contemplates and for which Patent Owner intends to request
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`authorization during the March 9, 2015, telephonic conference.
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`1. Motion to Amend or Substitute Claims
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`Patent Owner may move to amend or propose substitute claims pursuant to
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`37 C.F.R. § 42.121. Any such claim amendments or substitutions will respond to
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`one or more of the grounds of unpatentability involved in the trial and will not
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`enlarge the scope of the claims (37 C.F.R. § 42.221(a)(2)(i)) or introduce new
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`matter (37 C.F.R. § 42.221(a)(2)(ii)).
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`2. Motion to Consolidate IPRs for Purposes of Depositions
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`Patent Owner notes that three related inter partes review proceedings were
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`instituted on February 9, 2015, between the Patent Owner and Petitioner, LG
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`Electronics. See IPR2014-01302, IPR2014-01342 and IPR2014-01343. The parties
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`have discussed the possibility of consolidating the cases for purposes of cross-
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`examination such that each declarant would be subject to one deposition, rather
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`than three separate depositions, in order to streamline and simplify proceedings in
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`the separate IPR proceedings. The cross-examination consolidation would have no
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`other effect on the separate IPR proceedings. If the parties reach agreement on this
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`issue, Patent Owner requests leave to file a motion to consolidate for purposes of
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`cross-examination depositions, if such a motion is deemed necessary by the Board.
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`Dated: March 5, 2015
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`Respectfully submitted,
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`By: /s/Robert R. Laurenzi
`Robert R. Laurenzi
`Reg. No. 45,557
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`Kaye Scholer LLP
`250 West 55th Street
`New York, NY 10019-9710
`T: 212-836-7235
`F: 212-836-6427
`Email: rlaurenzi@kayescholer.com
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`Counsel for Patent Owner
`Cypress Semiconductor Corporation
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR §§ 42.6(e)(4) and 42.205(b), the undersigned certifies
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`that on March 5, 2015, a complete and entire copy of this PATENT OWNER’S
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`LIST OF PROPOSED MOTIONS was provided via email to the Petitioner by
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`serving the correspondence email address of record as follows:
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`Jason Shapriro
`Soumya Panda
`ROTHWELL, FIGG, ERNST & MANBECK
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
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`Email:
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`jshapiro@rothwellfigg.com
`spanda@rothwellfigg.com
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`By: /s/Robert R. Laurenzi
`Robert R. Laurenzi
`Kaye Scholer LLP
`250 West 55th Street
`New York, NY 10019-9710
`T: 212-836-7235
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