`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`
`MICRON TECHNOLOGY, INC., AND
`MICRON MEMORY JAPAN, INC.,
`Petitioners
`
`v.
`
`MASSACHUSETTS INSTITUTE OF TECHNOLOGY,
`Patent Owner
`________________________
`
`Case IPR2015-01087
`U.S. Patent No. 6,057,221
`________________________
`
`
`
`PATENT OWNER'S NOTICE OF LIST OF PROPOSED MOTIONS
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313
`
`
`
`
`
`
`
`
`
`The undersigned, on behalf of Massachusetts Institute of Technology
`
`(“MIT” or “Patent Owner”), hereby provides Notice to the Board that the attached
`
`list of proposed motions to be filed was served to Micron Technology, Inc., and
`
`Micron Memory Japan, Inc. ("Micron" or “Petitioner”) pursuant to 37 C.F.R.
`
`§ 42.21(a). See also Trial Practice Guide, 77 Fed. Reg. 48756, 48765 (Aug. 14,
`
`Respectfully submitted,
`
`by: /Steven J. Pollinger/
`Steven J. Pollinger
`Registration No. 35,326
`Ramzi R. Khazen
`Registration No. 55,810
`
`Counsel for Massachusetts Institute of
`Technology
`
`
`
`2012).
`
`
`
`Date: December 14, 2015
`
`
`
`
`
`1
`
`
`
`
`
`Case No. IPR2015-01087
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`
`MICRON TECHNOLOGY, INC., AND
`MICRON MEMORY JAPAN, INC.,
`Petitioners
`
`v.
`
`MASSACHUSETTS INSTITUTE OF TECHNOLOGY,
`Patent Owner
`________________________
`
`Case IPR2015-01087
`U.S. Patent No. 6,057,221
`________________________
`
`PATENT OWNER'S LIST OF PROPOSED MOTIONS
`
`
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313
`
`
`
`
`
`
`
`
`
`PATENT OWNER'S LIST OF PROPOSED MOTIONS
`
`The Patent Trial and Appeal Board ("Board") issued a decision on
`
`November 5, 2015 instituting Inter Partes Review of U.S. Patent No. 6,057,221,
`
`assigned Case IPR2015-01087. The Board scheduled an initial conference call for
`
`Wednesday, December 16, 2015 at 3:30pm Eastern Time. Pursuant to the Office
`
`Patent Trial Practice Guide, 77 Fed. Reg. 48756, 48765-66 (Aug. 14, 2012),
`
`Massachusetts Institute of Technology (“MIT” or “Patent Owner”) submits the
`
`following list of proposed motions it is currently considering filing. This list is
`
`provided without prejudice to MIT's right to seek authorization to file additional
`
`motions or to decide not to file motions listed.
`
`I. Motion to Exclude Evidence
`Pursuant to 37 C.F.R. § 42.64(c), MIT reserves the right to file a motion to
`
`exclude evidence. While such a motion is automatically authorized, MIT identifies
`
`such a motion to preserve its right to file it.
`
`II. Motion for Observations on Cross-Examination
`Pursuant to 37 C.F.R. § 42.20(a), MIT reserves the right to file a motion for
`
`observations on cross-examination. MIT identifies potentially filing such a motion
`
`to preserve its right.
`
`
`
`
`
`
`
`III. Motion for Admission Pro Hac Vice
`Pursuant to 37 C.F.R. § 42.10(c), MIT reserves the right to file a motion for
`
`one additional counsel to appear pro hac vice. While such a motion is
`
`automatically authorized, MIT identifies potentially filing such a motion to
`
`preserve its right.
`
`IV. Motion to Modify the Scheduling Order
`MIT expects to request, in light of the number of claims at issue, and the
`
`intervening holidays, that the due date for Patent Owner’s response be extended
`
`from January 20, 2016 to February 17, 2016. MIT expects to request that the
`
`deadline for cross examination be extended from January 13, 2016 to January 27,
`
`2016.
`
`V. Motion to Seal
`Pursuant to 37 C.F.R. § 42.14, MIT reserves the right to file a motion to seal
`
`certain confidential documents or things. While such a motion is automatically
`
`authorized, MIT identifies potentially filing such a motion to preserve its right.
`
`Respectfully submitted,
`
`by: /Steven J. Pollinger/
`Steven J. Pollinger
`Registration No. 35,326
`Ramzi R. Khazen
`Registration No. 55,810
`
`Counsel for Massachusetts Institute of
`Technology
`
`
`
`
`Date: December 14, 2015
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`I hereby certify that a true and correct copy of PATENT OWNER'S
`NOTICE OF LIST OF PROPOSED MOTIONS and PATENT OWNER'S
`LIST OF PROPOSED MOTIONS has been served on Petitioner via electronic
`mail at the following correspondence address:
`
`Michael S. Turner
`mturner@kenyon.com
`Rose Cordero Prey
`rcordero@kenyon.com
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004
`Tel.: (212) 908-6210
`Fax.: (212) 425-5288
`
`
`Respectfully submitted,
`
`by: /Steven J. Pollinger/
`Steven J. Pollinger
`Registration No. 35,326
`Ramzi R. Khazen
`Registration No. 55,810
`
`Counsel for Massachusetts Institute of
`Technology
`
`Date: December 14, 2015
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