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`________________________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________________________
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`SIRIUS XM RADIO INC.,
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`Petitioner,
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`v.
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`DRAGON INTELLECTUAL PROPERTY, LLC,
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`Patent Owner.
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`________________________________________
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`Case IPR2015-01735
`U.S. PATENT NO. 5,930,444
`________________________________________
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`PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION FOR
`COUNSEL TO WITHDRAW
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`On November 11, 2015, Patent Owner Dragon Intellectual Property, LLC
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`(“Dragon”) filed a Motion for Counsel to Withdraw from the Proceeding and
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`Permit Substitution of Counsel (“Motion”) requesting that Dragon’s designated
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`counsel, Jason S. Angell and Robert E. Freitas, be allowed to withdraw from the
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`present proceeding, and new counsel, Kai Zhu, be designated lead counsel to
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`represent Dragon in this proceeding.
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`Sirius XM does not oppose the pending Motion. However, Sirius XM
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`understands that petitioner DISH Network (“DISH”), in DISH Network, LLC v.
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`Dragon Intellectual Property, LLC, IPR2015-00499 (“DISH Petition”), has not
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`opposed the same Withdrawal Request filed by Dragon, on certain conditions—
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`specifically, that Dragon timely make available for deposition Dragon’s expert
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`Adam Goldberg. DISH Petition, Paper 16. Sirius XM agrees with DISH’s
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`position. Sirius XM further expressly reserves and does not waive its right to
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`pursue attorneys’ fees and costs from either Mr. Angell or Mr. Freitas, in the co-
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`pending District Court action (Dragon Intellectual Property, LLC v. Sirius XM
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`Radio Inc., No. 13-2067-RGA (D. Del.)), including any attorneys’ fees and costs
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`related to this IPR.
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`Respectfully submitted,
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`/Jonathan S. Caplan/
`Jonathan S. Caplan (Reg. No. 38,094)
`1177 Avenue of the Americas
`New York, NY 10036
`212.715.9100
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`Attorneys for Petitioner,
`Sirius XM Radio Inc.
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`2
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`Dated: November 12, 2015
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`CERTIFICATE OF SERVICE
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`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that on
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`the 12th day of November, 2015, a complete and entire copy of the foregoing
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`“PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION FOR
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`COUNSEL TO WITHDRAW” was served on the patent owner and counsel via
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`electronic mail at the addresses below:
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`Jason Angell
`Robert E. Freitas
`Freitas Angell & Weinberg LLP
`350 Marine Parkway
`Suite 200
`Redwood Shores, CA 94065
`jangell@fawlaw.com
`rfreitas@fawlaw.com
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`Kai Zhu (Reg. No. 64,586)
`60 Cody Ln
`Los Altos, CA 94022
`kz@dragonipllc.com
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`/Jonathan S. Caplan/ __________________
`Jonathan S. Caplan (Reg. No. 38,094)
`1177 Avenue of the Americas
`New York, NY 10036
`212.715.9100
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`Attorneys for Petitioner, Sirius XM Radio
`Inc.
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`
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` November 12, 2015
`Date
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