UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`T-Mobile US, Inc., T-Mobile USA, Inc., TeleCommunication Systems, Inc.,
`Ericsson Inc., and Telefonaktiebolaget LM Ericsson,
`Petitioners,
`
`v.
`
`TracBeam, LLC,
`Patent Owner.
`____________
`
`IPR2015-01708
`Patent 7,525,484
`____________
`
`
`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`Submitted Electronically via the Patent Review Processing System
`
`
`PETITIONERS’ AND PATENT OWNER’S STIPULATED REQUEST TO
`AMEND THE SCHEDULE
`
`
`
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`T-Mobile US, Inc., T-Mobile USA, Inc., TeleCommunication Systems, Inc.,
`Ericsson Inc., and Telefonaktiebolaget LM Ericsson,
`Petitioners,
`
`v.
`
`TracBeam, LLC,
`Patent Owner.
`____________
`
`IPR2015-01708
`Patent 7,525,484
`____________
`
`
`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`Submitted Electronically via the Patent Review Processing System
`
`
`PETITIONERS’ AND PATENT OWNER’S STIPULATED REQUEST TO
`AMEND THE SCHEDULE
`
`
`
`
`
`I.
`
`INTRODUCTION
`
`Petitioners and Patent Owner submit this stipulated request to amend the
`
`schedule in this IPR proceeding as set forth in Section II below.
`
`The parties and the Board held a conference call on April 6, 2016 to discuss
`
`proposed amendments to the schedules in various related IPR proceedings, in view
`
`of Petitioners’ pending request for joinder of certain supplemental IPR proceedings
`
`with the related instituted IPR proceedings. The status of these various IPR
`
`proceedings is identified in the following chart:
`
`Status
`
`instituted
`
`instituted
`
`instituted
`
`instituted
`
`instituted
`
`instituted
`
`institution decision pending;
`requested joinder with IPR2015-01708
`
`institution decision pending;
`requested joinder with IPR2015-01712
`
`institution decision pending;
`requested joinder with IPR2015-01687
`
`IPR Proceeding
`
`Patent
`
`IPR2015-01681
`
`IPR2015-01687
`
`IPR2015-01708
`
`IPR2015-01711
`
`IPR2015-01712
`
`IPR2015-01713
`
`’231 Patent
`
`’231 Patent
`
`’484 Patent
`
`’484 Patent
`
`’327 Patent
`
`’153 Patent
`
`IPR2016-00728
`
`’484 Patent
`
`IPR2016-00729
`
`’327 Patent
`
`IPR2016-00745
`
`’231 Patent
`
`
`
`
`
`1
`
`
`
`The Board authorized the parties to submit stipulated amended schedules in
`
`each of the instituted IPR proceedings, for the purpose of extending the existing
`
`deadlines while the Board considers the supplemental IPR petitions and associated
`
`requests for joinder. See IPR2016-00728, Paper 6 (April 7, 2016). In addition,
`
`pursuant to the parties’ agreement, the Board entered orders setting an April 25,
`
`2016 deadline for the Patent Owner’s Preliminary Responses in the supplemental
`
`IPR proceedings. Finally, on April 7, 2016, Patent Owner filed its oppositions to
`
`Petitioners’ motions for joinder in the supplemental IPR proceedings. Petitioners
`
`will be filing their reply briefs on or before the one-month deadline under 37 §
`
`C.F.R. 42.25(a)(2).
`
`Once the Board issues decisions on institution and joinder of the
`
`supplemental IPR proceedings, the parties agree to meet and confer regarding any
`
`further adjustments to the schedule that may be appropriate, depending on the
`
`timing and outcome of the Board’s decisions and any other relevant circumstances.
`
`For example, if the Board rules on institution and joinder of the supplemental IPR
`
`proceedings in advance of the July 25, 2016 institution deadline,1 the parties may
`
`adjust the schedule to provide additional time between certain due dates. As
`
`1 The July 25, 2016 institution deadline for the supplemental IPR proceedings is
`
`calculated from the parties’ agreed April 25, 2016 deadline for the Patent Owner’s
`
`preliminary response.
`
`
`
`2
`
`
`
`another example, Petitioners may require adjustments to the deadlines associated
`
`with motions for observation regarding cross-examination.2
`
`II. AMENDED SCHEDULE
`Petitioners and Patent Owner request that the Board amend the schedule in
`
`this IPR proceeding as follows:
`
`DUE DATES
`
`CURRENT
`SCHEDULE
`
`AMENDED
`SCHEDULE
`
`DUE DATE 1
`Patent Owner Response
`Patent Owner’s Motion to Amend
`
`DUE DATE 2
`Petitioners’ Reply
`Petitioners’ Opposition to Motion to
`Amend
`
`DUE DATE 3
`Patent Owner’s Reply to Petitioners’
`Opposition to Motion to Amend
`
`May 9, 2016
`
`August 19, 2016
`
`August 8, 2016
`
`September 16, 2016
`
`September 8, 2016 October 17, 2016
`
`
`2 For example, as noted by the Board, if Patent Owner moves to amend the claims
`
`and submits an expert declaration with its reply brief for the motion to amend,
`
`Petitioners would need additional time to file any motion for observation regarding
`
`cross-examination of Patent Owner’s expert. The parties will confer on that if
`
`those circumstances arise.
`
`
`
`3
`
`
`
`DUE DATE 4
`Motion for Observation Regarding
`Cross-Examination of Reply Witness
`Motion to Exclude Evidence
`Request for Oral Argument
`
`DUE DATE 5
`Response to Observation
`Opposition to Motion to Exclude
`
`DUE DATE 6
`Reply to Opposition to Motion to
`Exclude
`
`September 29, 2016 October 17, 2016
`
`October 13, 2016
`
`October 24, 2016
`
`October 20, 2016
`
`October 31, 2016
`
`DUE DATE 7
`Oral Argument
`
`November 8–9,
`2016
`
`NO CHANGE
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`/Brian W. Oaks/
`Brian W. Oaks
`Reg. No. 44,981
`BAKER BOTTS LLP
`Counsel for Petitioners
`
`
`
`4
`
`
`
`DATED: April 18, 2016
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`In accordance with 37 C.F.R. § 42.6(e), the undersigned certifies that on
`
`April 18, 2016, a complete and entire copy of PETITIONERS’ AND PATENT
`
`OWNER’S STIPULATED REQUEST TO AMEND THE SCHEDULE was
`
`served via email to Patent Owner’s counsel of record in this proceeding:
`
`Sean A. Luner, Esq.
`Registration No. 36,588
`DOVEL & LUNER, LLP
`201 Santa Monica Blvd., Suite 600
`Santa Monica, CA 90401
`Telephone (310) 656-7066
`Facsimile: (310) 656-7069
`sean@dovellaw.com
`
`Steven C. Sereboff, Esq.
`Registration No. 37,035
`SOCAL IP LAW GROUP LLP.
`310 N. Westlake Blvd., Suite 120
`Westlake Village, CA 91362
`Telephone (805) 230-1350 ext. 220
`Facsimile (805) 230-1355
`ssereboff@socalip.com
`
`
`
`April 18, 2016
`DATE
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`_____________________________
`Brian W. Oaks (Reg. No. 44,981)
`Baker Botts L.L.P.
`512.322.5470
`
`ATTORNEY FOR PETITIONERS, T-
`MOBILE US, INC., T-MOBILE USA,
`INC., TELECOMMUNICATION
`SYSTEMS, INC., ERICSSON INC., AND
`TELEFONAKTIEBOLAGET LM
`ERICSSON
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