`
`U.S. Patent No. 6,009,469
`Petitioner’s Proposed Motions
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC. &
`SAMSUNG TELECOMMUNICATIONS AMERICA, LLC.
`Petitioner,
`
`v .
`
`STRAIGHT PATH IP GROUP, INC.
`Patent Owner
`
`INTER PARTES REVIEW OF U.S. PATENT NO. 6,009,469
`
`
`Case IPR2014-01367
`
`
`PETITIONER’S PROPOSED MOTIONS
`
`
`
`
`
`
`
`
`
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`WEST\255704003.3
`
`
`
`U.S. Patent No. 6,009,469
`Petitioner’s Proposed Motions
`Pursuant to the Decision Instituting Trial (Paper 12) and the Office Trial
`
`Practice Guide, 77 Fed. Reg. 48756 at 48765-66, Petitioner identifies, without
`
`limitation, the following proposed motions that it might file in the above-
`
`captioned inter partes review proceeding:
`
`
`
`1.
`
`A motion for pro hac vice admission of counsel pursuant to 37
`
`C.F.R. § 42.10;
`
`
`
`2.
`
`A motion to amend the scheduling order for this case pursuant to 37
`
`C.F.R. § 42.51;
`
`
`
`3.
`
`A motion for additional discovery pursuant to 37 C.F.R. § 42.20 and
`
`42.51(b)(2) relating to any issues that Patent Owner might raise in its response to
`
`the petition, in any motion to amend U.S. Pat. No. 6,009,469, or otherwise in the
`
`course of this proceeding;
`
`
`
`
`
`4.
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`5.
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`A motion to exclude evidence pursuant to 37 C.F.R. § 42.64;
`
`A motion for observation on cross-examination pursuant to 37
`
`C.F.R. § 42.20(a); and,
`
`
`
`6.
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`A motion to file supplemental information pursuant to 37 C.F.R. §
`
`42.123, including information relating to the related case Straight Path IP
`
`Group, Inc. v. Sipnet EU S.R.O., No. 15-1212 (Fed. Cir.), which is Straight
`
`Path’s appeal of the Final Written Decision in related case Sipnet EU S.R.O. v.
`
`Straight Path IP Group, Inc., IPR2013-00246.
`
`WEST\255704003.3
`
`1
`
`
`
`U.S. Patent No. 6,009,469
`Petitioner’s Proposed Motions
`Although motions to exclude evidence, motions for observations on cross-
`
`
`
`examination, and motions for pro hac vice admission have been authorized by the
`
`Board, Petitioner identifies such motions here and preserves its right to file them.
`
`In addition, Petitioner may seek authorization, as necessary, to file
`
`additional motions not identified in the above list. See Office Trial Practice
`
`Guide, 77 Fed. Reg. 48756 at 48756 (“Submission of a list would not preclude
`
`the filing of additional motions not contained in the list.”).
`
`
`
`Dated: March 24, 2015
`
` Respectfully Submitted,
`
`
`
`/s/ Brian Erickson
`Brian K. Erickson
`Registration No. 48,895
`DLA PIPER LLP (US)
`401 Congress Avenue, Suite 2500
`Austin, TX 78701-3799
`Telephone: 512-457-7000
`Facsimile: 512-457-7001
`Email: Samsung-SP-
`IPR@dlapiper.com
`
`
`WEST\255704003.3
`
`2
`
`
`
`U.S. Patent No. 6,009,469
`Petitioner’s Proposed Motions
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned certifies service of a copy of this document on the Patent
`
`Owner’s counsel of record pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b) by
`
`electronic mail to StraightPathIPRs@mintz.com.
`
`Dated: March 24, 2015
`
`
`
`
`
` /s/ Brian Erickson
`Brian K. Erickson
`Registration No. 48,895
`DLA PIPER LLP (US)
`401 Congress Avenue, Suite 2500
`Austin, TX 78701-3799
`Telephone: 512-457-7000
`Facsimile: 512-457-7001
`Email: Samsung-SP-
`IPR@dlapiper.com
`
`WEST\255704003.3
`
`3
`
`
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