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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`DELL, INC., EMC CORPORATION,
`HEWLETT PACKARD, INC., MONSTER WORLDWIDE, INC.,
`ORACLE CORPORATION and THOMSON REUTERS CORPORATION,
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`Petitioner
`v.
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`SELENE COMMUNICATION
`TECHNOLOGIES, LLC,
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`Patent Owner
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`
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`CASE IPR2014-01411
`
`Patent No. 6,363,377
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`PETITIONERS’ PROPOSED MOTIONS
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`EAST\96930753.1
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`1
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`Pursuant to the Decision Instituting Trial (Paper 23) and the Office Trial
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`Practice Guide, 77 Fed. Reg. 48756 at 48765-66, Petitioners hereby provide a list
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`of proposed motions that they may file during the trial:
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` A motion under 37 C.F.R. § 42.122(b) for Joinder of IPR2015-00856 with
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`IPR2014-01411, accompanied by a Proposed Joint Schedule in the event that
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`joinder is granted. For the avoidance of doubt Petitioner has been
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`information by Patent Owner that Patent Owner does not consent to the
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`institution of Trial for IPR2015-00856 or Joinder of that proceeding with
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`this proceeding. Rather Patent Owner is only agreeing to the attached
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`proposed joint schedule in the event that IPR2015-000856 is instituted and
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`joined with this proceeding.
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`Petitioners hereby request authorization to file this motion.
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`Respectfully Submitted,
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`
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`
`
` /James M. Heintz/
`James M. Heintz
`Registration Number 41,828
`DLA Piper LLP (US)
`11911 Freedom Drive, Suite 300
`Reston, VA 20190
`(703) 773-4148
`
`Timothy Lohse
`Registration Number 35,255
`
`EAST\96930753.1
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`2
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`
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`DLA Piper LLP (US)
`2000 University Avenue
`East Palo Alto, CA 94303-2215
`(650) 833-2055
`Attorneys for Petitioner
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`EAST\96930753.1
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`Patent No. 6,363,377
`Proposed Motions
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`CERTIFICATE OF SERVICE
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`
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`The undersigned hereby certifies that a true copy of the foregoing instrument
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`was served on Patent Owner, by emailing a copy to counsel at the email addresses
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`listed below:
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`
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`
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`Tarek N. Fahmi: tarek.fahmi@ascendalaw.com
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`Ascenda Law Group, PC: patents@ascendalaw.com
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`
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`By:
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` /James M. Heintz/
`James M. Heintz
`
`Reg. No. 41828
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`Counsel for Petitioner
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`EAST\96930753.1
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`1
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