`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`
`
`CATERPILLAR INC.,
`Petitioner,
`
`v.
`
`ESCO CORPORATION,
`Owner.
`
`Case IPR2015-01032
`Patent 8,689,472 B2
`
`Related Prior Case IPR2015-00409
`Same Patent, Same Claims
`____________
`
`
`
`ERRATA TO PATENT OWNER PRELIMINARY RESPONSE
`
`TO THE PETITION FOR INTER PARTES REVIEW
`
`IN THIS SECOND CASE
`
`
`
`
`
`1
`
`
`
`Caterpillar v. ESCO IPR2015-01032
`ESCO Exhibit 2051 Page 1
`
`
`
` Please take notice of the following errors and corrections to the patent owner
`
`preliminary response:
`
`Location of Error
`
`Correction
`
`Reason for Correction
`
`Table of Authorities ref-
`
`Delete
`
`Typographical error – not
`
`erence to 37 C.F.R. 42.6
`
`cited in preliminary re-
`
`sponse
`
`Page 16 lines 8 and 10
`
`Change to “V.C.” and
`
`Typographical error - in-
`
`references to “V.C.2” and
`
`“V.B.”
`
`correct references, incor-
`
`“V.C.D, E”
`
`
`
`rect comma
`
`Page 18 fn. 4 line 4 “pro-
`
`Change to “produced in
`
`Typographical error –
`
`duced the Litigation”
`
`the Litigation”
`
`missing word
`
`Page 25 line 12 “the
`
`Delete “the”
`
`Typographical error - ex-
`
`CAT”
`
`traneous word
`
`Page 26 lines 1-5 quota-
`
`Delete identified quo-
`
`Typographical errors –
`
`tion marks before the
`
`taiton marks, insert quota-
`
`quotation marks in wrong
`
`words Expanding and said
`
`tion marks as follows with
`
`places
`
`and after the words opera-
`
`their associated words:
`
`tions and management.
`
`Line 1 ‘“Expanding
`
`(Quotation marks to iden-
`
`Line 3 operations’
`
`2
`
`
`
`Caterpillar v. ESCO IPR2015-01032
`ESCO Exhibit 2051 Page 2
`
`
`
`tify “Expanding” and the
`
`Line 3 “said
`
`like as words not included
`
`Line 4 President,”
`
`here to avoid confusion.)
`
`Page 35 illustration
`
`Delete illustration and
`
`Typographical error – not
`
`substitute the petitioner’s
`
`the petitioner’s illustration
`
`illustration below this row
`
`described on page 35 lines
`
`8-9
`
`Page 37 line 14 “tools
`
`Change to “tools other
`
`Typographical error –
`
`than a hammer”
`
`than a hammer”
`
`missing word
`
`
`
`
`
`3
`
`Caterpillar v. ESCO IPR2015-01032
`ESCO Exhibit 2051 Page 3
`
`
`
`Page 45 line 3 reference
`
`Change “6” to “5”
`
`Typographical error – ref-
`
`to “image on 6”
`
`erence to wrong page
`
`Page 45 line 5, “frequen-
`
`Correct period mark and
`
`Typographical errors – in
`
`cy. See, e.g., image on 7”
`
`capital letter of “see” in
`
`appropriate period and
`
`phrase so that phrase is as
`
`capital in middle of sen-
`
`follows: “frequency, see,
`
`tence
`
`e.g., image on 7”
`
`Page 47 line 4 “of in”
`
`Delete “in”
`
`Typographical error - un-
`
`necessary word
`
`Page 49 line 13 “Z”
`
`Delete “Z”
`
`Typographical error - in-
`
`correct reference – no axis
`
`“Z” present in prelimi-
`
`nary response
`
`Page 49 line 14 “also”
`
`Delete “also”
`
`Typographical error –
`
`same as with “Z”
`
`Page 54 line 10 “re-
`
`Change to “re-
`
`Typographical error –
`
`modificatoin”
`
`modification”
`
`spelling error
`
`
`
`
`
`
`
`4
`
`Caterpillar v. ESCO IPR2015-01032
`ESCO Exhibit 2051 Page 4
`
`
`
`Page 59 lines 3 and 4
`
`Change to “V.C.”
`
`Typographical error – in-
`
`“V.C.1”
`
`
`
`correct reference
`
`Date: July 31, 2015
`
` Respectfully submitted,
`
` By: /Charles W. Shifley/
`Charles W. Shifley
`Reg. No. 28,042
`
`Binal J. Patel
`Reg. No. 42,065
`
`Timothy J. Rechtien
`Reg. No. 70,501
`
`Robert H. Resis
`Reg. No. 32,168
`
`All at:
`Banner & Witcoff, Ltd.
`10 S. Wacker Drive, Suite 3000
`Chicago, Illinois 60606
`P: 312.463.5000
`F: 312.463.5001
`Service Email:
`ESCO472IPR@bannerwitcoff.com
`
`Attorneys for ESCO Corporation,
`Patent Owner
`
`
`
`1
`
`Caterpillar v. ESCO IPR2015-01032
`ESCO Exhibit 2051 Page 5
`
`
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