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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC., MOTOROLA MOBILITY LLC, and
`TOSHIBA AMERICA INFORMATION SYSTEMS, INC.,
`Petitioners
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`v.
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`GLOBAL TOUCH SOLUTIONS, LLC
`Patent Owner
`________________
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`Case IPR2015-01173
`Patent 7,329,970 B2
`________________
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`PATENT OWNER’S UNOPPOSED MOTION TO WITHDRAW
`MOTION TO EXCLUDE
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`Pursuant to the Board’s authorization via email of July 28, 2016, Patent
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`Owner Global Touch Solutions, LLC, respectfully submits this Patent Owner’s
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`Unopposed Motion to Withdraw Motion to Exclude (Paper 34) in accordance with
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`37 C.F.R. §42.22.
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`I. STATEMENT OF MATERIAL FACTS (37 C.F.R. §42.22(a)(2))
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`On June 30, 2016, the Board held a conference call with Patent Owner and
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`Petitioners regarding Petitioners’ seeking permission to correct Petitioners’ Expert
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`Declarations (Exhibit 1003 and 1035). During the call, Judge Shaw ruled that
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`Petitioners would be allowed to file corrected expert declarations, adding only the
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`inadvertently omitted penalty of perjury acknowledgement. Exhibit 1038 at 18:19-
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`19:2. On July 3, 2016, Petitioner filed corrected Declarations of Paul Beard,
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`Exhibit 1003 (Corrected) and Exhibit 1035 (Corrected).
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`On July 11, 2016, Patent Owner filed a Motion to Exclude Exhibit 1003,
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`Exhibit 1003 (Corrected), Exhibit 1035, and Exhibit 1035 (Corrected). (Paper 34).
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`On July 13, 2016, Patent Owner filed with the Board a Patent Owner’s
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`Request for Rehearing (Paper 35). On July 25, 2016, Patent Owner filed an
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`Unopposed Motion to Withdraw Request for Rehearing (Paper 39), which was
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`granted on July 26, 2016. (Paper 40).
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`II. STATEMENT OF RELIEF REQUESTED (37 C.F.R. §42.22(a)(1))
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`Patent Owner hereby requests that the Motion to Exclude (Paper 34) filed in
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`this matter on July 11, 2016, be withdrawn from consideration by the Board.
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`The relief requested is warranted at least because Patent Owner does not
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`wish to dedicate time for argument to or burden the Board with this issue. No harm
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`to Petitioners will come from the Board’s granting of this unopposed Motion. And,
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`Petitioners indicated that they do not oppose filing of this Motion.
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`Respectfully submitted,
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`/nathan cristler/
`Nathan Cristler
`Reg. No: 61,736
`Cristler IP, PLLC
`1801 21st Road North
`Arlington, Virginia 22209
`E-Mail: ncristler@cristlerip.com
`Tel: (512) 576-5166
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`Counsel for Patent Owner
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`Date: July 29, 2016
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6, I hereby certify that on this 29th Day of July,
`2016, the foregoing PATENT OWNER’S UNOPPOSED MOTION TO
`WITHDRAW MOTION TO EXCLUDE, was served by e-mail on counsel for
`Petitioner:
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`Robert Steinberg
`bob.steinberg@lw.com
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`Matthew Moore
`matthew.moore@lw.com
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`Gabriel Gross
`gabe.gross@lw.com
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`James Bender
`james.bender@lw.com
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`Doris Hines
`dori.hines@finnegan.com
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`Luke McCammon
`luke.mccammon@finnegan.com
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`DeAnna Allen
`dallen@cooley.com
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`Phillip Morton
`pmorton@cooley.com
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`Respectfully submitted,
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`/nathan cristler/
`Nathan Cristler
`Reg. No: 61,736
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