`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________
`SONY COMPUTER ENTERTAINMENT AMERICA LLC
`Petitioner
`v.
`ROTHSCHILD DIGITAL MEDIA INNOVATIONS, LLC
`Patent Owner
`____________
`
`Case No. IPR2015-01364
`Patent 6,101,534
` ____________
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`PETITIONER’S UPDATED MANDATORY NOTICE
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`I. MANDATORY NOTICES UNDER 37 C.F.R. § 42.8(A)(1)
`A. Real Party-In-Interest and Related Matters
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`Petitioner is the real party-in-interest. 37 C.F.R. § 42.8(b)(1). In addition to
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`Petitioner, Sony Computer Entertainment Inc. is also a real party-in-interest. See
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`37 C.F.R. § 42.8(b)(2). The ’534 Patent was the subject of a patent infringement
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`lawsuit filed on June 9, 2014, by Rothschild Digital Media Innovations, LLC
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`against Petitioner in the United States District Court for the Southern District of
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`Florida. The lawsuit was served on Petitioner on June 12, 2014. This case has
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`since been transferred to the Northern District of California, with case number
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`5:14-cv-03928-PSG, and the case is titled Rothschild Digital Media Innovations,
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`LLC v. Sony Computer Entertainment America LLC. Petitioner identifies the
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`following additional district court cases involving the ‘534 Patent: Rothschild
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`Digital Media Innovations, LLC v. G5 Entertainment, AB, Case No. 1:15-cv-23301
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`(S.D. Fla., filed Sept. 1, 2015)(pending); Rothschild Digital Media Innovations,
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`LLC v. Gameloft, S.A., Case No. 1:15-cv-23302 (S.D. Fla., filed Sept. 1, 2015)
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`(pending); Supercell Oy v. Rothschild Digital Media Innovations, LLC, Case No.
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`2:15-cv-1119 (W.D. Wash., filed July 13, 2015) (pending); ORB Networks v.
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`Rothschild Trust Holdings, LLC, Case no. 3:07-cv-400 (N.D. Cal., filed Jan. 22,
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`2007) (terminated); Rothschild Trust Holdings, LLC v. ORB Networks, Inc., Case
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`No. 1:06-cv-22921 (S.D. Fla., filed Dec. 1, 2006) (terminated); Rothschild Trust
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`Holdings, LLC v. Citrix Systems, Inc., et al., Case No. 1:06-cv-21359 (S.D. Fla.,
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`filed May 31, 2006) (terminated); Trust Licensing, LLC v. Interactual
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`Technologies, Inc., Case No. 1:03-cv-20672 (S.D. Fla., March 24, 2003)
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`(terminated); Trust Licensing, LLC v. Disc Publishing, Inc., Case No. 1:02-cv-
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`21192 (S.D. Fla., filed April 18, 2002) (terminated); In re Intracorp Entertainment,
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`Inc., Case No. 96-16276 (S.D. Fla.) (terminated).1
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`In addition to the foregoing litigation, the Petitioner is aware of the
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`following related matter in the U.S. Patent and Trademark Office: U.S.
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`Reexamination Control No. 90/008,591, which concluded when a re-examination
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`certificate for the ‘534 Patent issued on June 28, 2011.
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`B.
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`Lead and Back-Up Counsel Under 37 C.F.R. § 42.8(b)(3)
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`Petitioner provides the following designation and service information for
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`lead and back-up counsel. 37 C.F.R. § 42.8(b)(3) and (b)(4). Service of any
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`documents via hand-delivery may be made at the postal mailing or e-mail address
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`of the lead and back-up counsel. 37 C.F.R. § 42.8(b)(4).
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`1 Petitioners note that this information was obtained using publicly available search
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`tools and cannot be certain that there are not additional actions presently pending
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`or that additional actions did not exist in the past.
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`Lead Counsel
`Eric A. Buresh (Reg. No. 50,394)
`eric.buresh@eriseip.com
`ERISE IP, P.A.
`6201 College Blvd., Ste. 300
`Overland Park, Kansas 66211
`Telephone: (913) 777-5600
`Fax: (913) 777-5601
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`Back-Up Counsel
`Abran J. Kean (Reg. No. 58,540)
`abran.kean@eriseip.com
`ERISE IP, P.A.
`5600 Greenwood Plaza Blvd., Ste. 200
`Greenwood Village, Colorado 80111
`Telephone: (913) 777-5600
`Fax: (913) 777-5601
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`Dated: January 5, 2016
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`Respectfully submitted,
`ERISE IP, P.A.
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`BY: /s/ Eric A. Buresh
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`Eric A. Buresh, Reg. No. 50,394
`Abran J. Kean, Reg. No. 58,540
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`P: (913) 777-5600
`F: (913) 777-5601
`eric.buresh@eriseip.com
`abran.kean@eriseip.com
`ATTORNEYS FOR PETITIONER
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`CERTIFICATE OF SERVICE ON PATENT OWNER
`UNDER 37 C.F.R. § 42.105(a)
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`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b), the undersigned certifies
`that on January 5, 2016, a complete and entire copy of Petitioner’s Updated
`Mandatory Notice was provided via electronic mail to the following:
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`Respectfully submitted,
`ERISE IP, P.A.
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`/s/ Eric A. Buresh
`Eric A. Buresh, Reg. No. 50,394
`Abran J. Kean, Reg. No. 58,540
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`P: (913) 777-5600
`F: (913) 777-5601
`eric.buresh@eriseip.com
`abran.kean@eriseip.com
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`ATTORNEYS FOR PETITIONER
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`Thomas K. Landry
`Adam C. Underwood
`CAREY RODRIGUEZ O’KEEFE MILIAN GONYA, LLP
`1395 Brickell Avenue, Suite 700
`Miami, FL 33131
`Tel: 305.372.7474
`tlandry@careyrodriguez.com
`aunderwood@carerodriguez.com
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`BY:
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