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IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`PATENT TRIAL AND APPEAL BOARD
`
`PRONG, INC.
`Petitioner
`
`v.
`
`YEOSHUA SORIAS
`Patent Owner
`
`Inter Partes Review
`
`Case No. IPR2015-01317
`U.S. Patent No. 8,712,486
`
`PATENT OWNER’S PROPOSED FIRST SET OF
`REQUESTS FOR ADMISSION TO PETITIONER
`
`Patent Owner Yeoshua Sorias (“Sorias”) requests that Petitioner Prong Inc.
`
`(“Prong”) respond to the following Request for Admission on or before the
`
`expiration of fourteen (14) days from the date of service of these requests, or at
`
`such other time as the parties may agree or the Board may order.
`
`Sorias Exhibit 2014
`
`

`
`Case No. IPR2015-01317
`U.S. Patent No. 8,712,486
`Definitions and Instructions
`
`
`
`
`
`1. The term “Prong” means Petitioner Prong, Inc. (f/k/a Prong, LLC) and includes,
`
`without
`
`limitation, all affiliates,
`
`related companies, parent companies,
`
`predecessors, divisions, subsidiaries, assigns, and successors in interest thereof,
`
`including but not limited to Anthem Grand LLC, and all other persons acting or
`
`purporting to act on behalf of it, including but not limited to Mr. Jesse Pliner and
`
`Mr. Lloyd Gladstone
`
`
`
`Requests For Admission
`
`
`Request for Admission No. 1
`Admit that the Forefront Law Group was acting on behalf of Prong (whether
`directly or indirectly) when it approached Mr. Max Moskowitz in February, 2012
`on behalf of an anonymous client interested in purchasing U.S. Patent Application
`Serial No. 13/348,066.
`
`
`
`2
`
`
`

`
`Sorias Exhibit 2014
`
`

`
`Case No. IPR2015-01317
`U.S. Patent No. 8,712,486
`
`Date ___________
`
`
`
`
`
`
`
`
`
`_______________________________
`Mitchell S. Feller (Reg. No. 42,530)
`msfeller@grr.com
`Jason R. Wachter (Reg. No. 65,978)
`jwachter@grr.com
`Gottlieb Rackman & Reisman, P.C.
`270 Madison Ave., 8th Floor
`New York, NY 10016
`Phone: 212-684-3900
`Fax: 212-684-3999
`
`For Patent Owner
`Mr. Yeoshua Sorias
`
`3
`
`
`

`
`Sorias Exhibit 2014

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