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IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`MERCEDES-BENZ USA, LLC,
`Petitioner
`
`v.
`
`Z-DIMENSIONAL, LLC,
`Patent Owner.
`
`
`
`
`CASE: IPR2014-01521
`
`PATENT: 7,729,530
`
`
`
`
`
`
`PATENT OWNER’S MANDATORY NOTICES
`
`
`In compliance with 37 CFR 42.8, Patent Owner Z-Dimensional, LLC files its required
`
`notices now in PDF format, in addition to and after providing the same information through the
`
`PRPS system online.
`
`MANDATORY NOTICES:
`
`1.
`
`Real Parties-in-Interest: a) Z-Dimensional, LLC, a Texas limited liability company with
`
`a principal place of business at 1333 W. McDermott Drive, Suite 241, Allen, Texas 75013; and
`
`b) Daniel F. Perez, the president of Z-Dimensional, LLC and a resident of the state of Texas.
`
`2.
`
`Related Matters: There are currently nine lawsuits (as listed below) claiming
`
`infringement of U.S. Pat. No. 7,729,530, all pending in The United States District Court for the
`
`Eastern District of Texas, Marshall Division before the Honorable Judge Rodney Gilstrap:
`
`a) 2:13-cv-1149, Z-Dimensional, LLC v. Mercedes-Benz USA, LLC, filed 12/31/13;
`b) 2:14-cv-76, Z-Dimensional, LLC v. LG Electronics Mobilcomm USA, Inc., filed 02/12/14;
`c) 2:14-cv-147, Z-Dimensional, LLC v. TigerDirect, Inc., filed 02/27/14; and
`d) 2:14-cv-366, Z-Dimensional, LLC v. GoPro, Inc., filed 04/15/14.
`
`
`
`[1]
`
`

`

`All four of these cases were filed and pending prior to the initiation of the IPR by the Petitioner.
`The first three of the above-listed cases have been consolidated.
`
`3.
`
`Lead Counsel: Ronald W. Burns, Esq.; 15139 Woodbluff Drive, Frisco, TX 75035; (972)
`
`632-9009; rburns@burnsiplaw.com; USPTO Reg. No. 44044.
`
`
`
`Back-up Counsel: Kenneth Emanuelson; Ross Joyner PLLC; 1700 Pacific Avenue, Suite
`
`3750, Dallas, Texas 75201; (469) 363-5808; kemanuelson@rossjoynerlaw.com; USPTO Reg.
`
`No. 46684.
`
`4.
`
`Service Information: Service should be made to Z-Dimensional, LLC; having postal and
`
`hand-delivery address at 1333 W. McDermott Drive, Suite 241, Allen, Texas 75013; with a copy
`
`to Ronald W. Burns, Esq.; 15139 Woodbluff Drive, Frisco, TX 75035 (postal and hand-
`
`delivery); (972) 632-9009; rburns@burnsiplaw.com.
`
`
`
`Dated: October 17, 2014
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully Submitted,
`
` By: /s/ Ronald W. Burns
`
`Ronald W. Burns
`
`Reg. No. 44044
`
`Ronald W. Burns, Esq.
`
`15139 Woodbluff Drive
`
`Frisco, Texas 75035
`
`Phone: 972-632-9009
`
`rburns@burnsiplaw.com
`
`
`
`
`
`
`
`
`COUNSEL FOR PLAINTIFF
`Z-DIMENSIONAL, LLC
`
`
`[2]
`
`

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