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` Paper ____
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` Filed: March 5, 2015
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`Filed on behalf of: LG Electronics, Inc.,
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` LG Electronics U.S.A., Inc., and
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` LG Electronics Mobilecomm U.S.A., Inc.
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`By:
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`Jason M. Shapiro, Lead Counsel
`Soumya P. Panda, Back-up Counsel
`ROTHWELL, FIGG, ERNST & MANBECK, P.C.
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
`Phone: 202-783-6040
`Facsimile: 202-783-6031
`Emails: jshapiro@rothwellfigg.com
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` spanda@rothwellfigg.com
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`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.
`_______________
`
`Case IPR2014-01343
`Patent 8,519,973 B1
`_______________
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`PETITIONER’S LIST OF PROPOSED MOTIONS
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`Pursuant to the Decision of the Board to institute inter partes review (Paper
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`Case IPR2014-01343
`Patent 8,519,973 B1
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`
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`7, February 9, 2015) and the Office Patent Trial Practice Guide, 77 Fed. Reg.
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`48756 (August 14, 2012), LG Electronics, Inc., LG Electronics U.S.A., Inc., and
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`LG Electronics Mobilecomm U.S.A., Inc. (“Petitioner”), do not currently
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`anticipate filing any motions not already authorized by the Board.
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`Petitioner has not listed motions already authorized by the Board, such as
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`those set forth in the Scheduling Order (Paper 8), and reserve the right to file such
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`motions and to seek authorization to file any other motions that may become
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`necessary or appropriate in response to any motions filed or action taken by Patent
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`Owner, or in view of any further events or submissions in these proceedings.
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`Date: March 5, 2015
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`Respectfully Submitted,
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`By: /Jason M. Shapiro/
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`Jason M. Shapiro, Reg. No. 35,354
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`Soumya P. Panda, Reg. No. 60,447
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`Rothwell, Figg, Ernst & Manbeck, P.C.
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
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`Counsel for Petitioners
`LG Electronics, Inc.,
`LG Electronics U.S.A., Inc., and
`LG Electronics Mobilecomm U.S.A., Inc.
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`2
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`Case IPR2014-01343
`Patent 8,519,973 B1
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`CERTIFICATE OF SERVICE
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`I hereby certify that on this 5th day of March, 2015, a true and correct copy
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`of the foregoing PETITIONER’S LIST OF PROPOSED MOTIONS was
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`served, via electronic mail upon the following counsel for Patent Owner Cypress
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`Semiconductor Corp.:
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`Robert R. Laurenzi, Esq.
`Kaye Scholer LLP
`425 Park Avenue
`New York, NY 10022
`Phone: (212) 836-8000
`Email: robert.laurenzi@kayescholer.com
`
`Robert S. Magee, Esq.
`Kaye Scholer LLP
`Two Palo Alto Square, Suite 400
`3000 El Camino Real
`Palo Alto, CA 94306
`Phone: (650) 319-4500
`Email: robert.magee@kayescholer.com
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`
`
`
` /Erik van Leeuwen/
`Erik van Leeuwen
`Litigation Operations Coordinator
`Rothwell, Figg, Ernst & Manbeck, P.C.
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`3
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