`Patent 6,101,534
`Paper No. 11
`Filed: January 8, 2016
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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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`SONY COMPUTER ENTERTAINMENT AMERICA LLC,
`Petitioner,
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`v.
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`ROTHSCHILD DIGITAL MEDIA INNOVATIONS, LLC,
`Patent Owner.
`____________
`
`Case IPR2015-01364
`Patent 6,101,534
`____________
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`PATENT OWNER’S LIST OF PROPOSED MOTIONS
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`Mail Stop: Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`–1–
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`Case IPR2015-01364
`Patent 6,101,534
`Pursuant to the notice of practice guide published at 77 Fed. Reg. 48,755,
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`47,765 (Aug. 14, 2012) (codified at 37 C.F.R. pt. 42), and in view of the initial
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`conference call contemplated by the Scheduling Order (see Paper No. 9 at 6),
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`Patent Owner advises the Board and Petitioner that Patent Owner does not
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`currently anticipate the filing of any motions that would be ripe for discussion
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`during the initial conference call. Patent Owner nonetheless observes as follows:
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`1. Counsel for both parties have discussed a stipulated modification of the
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`Scheduling Order as to Due Dates 1, 2 and 3. Petitioner has not yet authorized the
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`stipulation. Patent Owner believes there should be no impediment to stipulation,
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`but cannot rule out the need to pursue motion practice.
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`2. On January 5, 2016, by agreement of the parties, and as directed upon
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`telephone inquiry to Board staff member Maria Vignone, counsel for Patent Owner
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`submitted a request to trials@uspto.gov for a one-week modification of Due Date 7
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`(oral argument) to August 23, 2016, due to a calendar conflict.
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`3. Patent Owner reserves the right to pursue a motion to amend, as to which
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`a different conference-call deadline applies (see Paper No. 9 at 3).
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`Respectfully submitted,
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`/Thomas K. Landry/
`Thomas K. Landry, Lead Counsel
`Registration No. 33,939
`Telephone: (305) 372-7474
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`Date: January 8, 2016
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`–2–
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`CERTIFICATE OF SERVICE
`UNDER 37 C.F.R. §§ 42.6(e)
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`Pursuant to 37 C.F.R. §§ 42.6(e), I certify that I caused to be served
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`electronically by agreement of the parties on this 8th day of January 2016, a true
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`and correct copy of the foregoing Patent Owner’s List of Proposed Motions on
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`counsel of record for Petitioner as follows:
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`Eric A. Buresh, Esq.
`eric.buresh@eriseip.com
`Abran J. Kean, Esq.
`abran.kean@eriseip.com
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
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`Respectfully submitted,
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`/Thomas K. Landry/
`Thomas K. Landry (Reg. No. 33,939)
`tlandry@careyrodriguez.com
`CAREY RODRIGUEZ
`MILIAN GONYA, LLP
`1395 Brickell Avenue, S\uite 700
`Miami, Florida 33131
`Telephone: (305) 372-7474
`Facsimile: (305) 372-7475
`Counsel for Rothschild Digital Media
`Innovations, LLC
`
`Dated: January 8, 2016
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