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Paper ____
`
`Filed on behalf of: LG Electronics, Inc.,
`
`
`
` LG Electronics U.S.A., Inc., and
`
`
`
` LG Electronics Mobilecomm, Inc.
`
`
`
`
`By:
`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
`
`Email: jshapiro@rothwellfigg.com
` spanda@rothwellfigg.com
`
`
`
` Filed: March 5, 2015
`
`
`
`
`
`

`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`LG ELECTRONICS, INC.,
`LG ELECTRONICS U.S.A., INC., and
`LG ELECTRONICS MOBILECOMM U.S.A., INC.,
`Petitioner,
`
`v.
`
`CYPRESS SEMICONDUCTOR CORP.,
`Patent Owner.
`_______________
`
`Case IPR2014-01386
`Patent 6,012,103
`_______________
`
`
`
`PETITIONER’S LIST OF PROPOSED MOTIONS
`
`
`
`

`

`LG Electronics, Inc., LG Electronics U.S.A., Inc., and LG Electronics
`
`Case IPR2014-01386
`Patent 6,012,103
`
`
`
`Mobilecomm U.S.A., Inc. (“Petitioner”) respectfully identify the following
`
`motions that Petitioner currently anticipates it might file, pursuant to Office Trial
`
`Practice Guide, 77 Fed. Reg. 48756 at 48765-66:
`
` Motion to Submit Supplemental Information (37 C.F.R. § 42.123)
`
`Petitioner understands that it need not file any motion to serve and file
`
`supplemental evidence pursuant to 37 C.F.R. § 42.64(b)(2) in response to the
`
`Patent Owner’s evidentiary objections. To the extent any authorization by the
`
`Board were deemed necessary or appropriate for Petitioner to file the supplemental
`
`evidence, Petitioner reserves the right to seek such authorization.
`
`
`
`Petitioner has not listed motions already authorized by the Board, such as
`
`those set forth in the Scheduling Order (Paper 9), and reserves the right to file such
`
`motions and to seek authorization to file any other motions that may become
`
`necessary or appropriate in response to any motions filed or action taken by Patent
`
`Owner, or in view of any further events or submissions in these proceedings.
`
`
`Date: March 5, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`By:
`
`
`
`
`
`
`/Jason M. Shapiro/
`Jason M. Shapiro, Reg. No. 35,354
`
`Soumya P. Panda, Reg. No. 60,447
`Rothwell, Figg, Ernst & Manbeck, P.C.
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
`

`
`2
`
`

`

`
`
`
`

`
`Case IPR2014-01386
`Patent 6,012,103
`
`
`Counsel for Petitioner
`LG Electronics, Inc.,
`LG Electronics U.S.A., Inc., and
`LG Electronics Mobilecomm U.S.A., Inc.
`
`
`
`3
`
`

`

`
`
`Case IPR2014-01386
`Patent 6,012,103
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 5th day of March, 2015, a true and correct copy
`
`of the foregoing PETITIONER’S LIST OF PROPOSED MOTIONS was
`
`served, via electronic mail upon the following counsel for Patent Owner Cypress
`
`Semiconductor Corp.:
`
`
`

`
`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



`
` /Erik van Leeuwen/
`Erik van Leeuwen
`Litigation Operations Coordinator
`Rothwell, Figg, Ernst & Manbeck, P.C.
`
`
`
`
`
`
`
`
`4
`
`

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