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`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`
`
`COALITION FOR AFFORDABLE DRUGS V LLC;
`HAYMAN CREDES MASTER FUND, L.P.;
`HAYMAN ORANGE FUND SPC – PORTFOLIO A;
`HAYMAN CAPITAL MASTER FUND, L.P.;
`HAYMAN CAPITAL MANAGEMENT, L.P.;
`HAYMAN OFFSHORE MANAGEMENT, INC.;
`HAYMAN INVESTMENTS, LLC;
`NXN PARTNERS, LLC;
`IP NAVIGATION GROUP, LLC;
`J KYLE BASS, and ERICH SPANGENBERG,
`Petitioner,
`
`v.
`
`BIOGEN MA INC.,
`Patent Owner.
`
`____________________________________________
`
`Case: IPR2015-01993
`U.S. Patent No. 8,399,514
`____________________________________________
`
`BIOGEN’S LIST OF PROPOSED MOTIONS
`
`
`
`
`
`

`

`Case No. IPR2015-01993
`Patent 8,399,514
`Pursuant to the Board’s Scheduling Order (Paper 21) setting an Initial
`
`Conference Call for April 19, 2016, and directing the parties to page 48765 of the
`
`Patent Office Trial Practice Guide, 77 Fed. Reg. 48756, Patent Owner Biogen MA
`
`Inc. submits this list of proposed motions presently contemplated by Biogen for
`
`which it intends to request authorization during the Initial Conference Call:
`
`
`
`Motion to Antedate Kappos 2006 (Ex. 1003A) (see Volkswagen Grp.
`
`of Am. v. Emerachem Holdings, LLC, IPR2014-01557, Paper 17
`
`(PTAB May 4, 2015)); and
`
`
`
`Motion to Seal Confidential Information/Motion for Protective Order.
`
`Although Biogen does not presently contemplate filing additional motions, it
`
`reserves the right to seek subsequent authorization for motions consistent with the
`
`Board’s Rules.
`
`Dated: April 15, 2016
`
`
`
`Respectfully submitted,
`
` By: /Erin M. Sommers/
`Michael J. Flibbert, Reg. No. 33,234
`Maureen D. Queler, Reg. No. 61,879
`Erin M. Sommers, Reg. No. 60,974
`Finnegan, Henderson, Farabow, Garrett
` & Dunner, LLP
`901 New York Avenue, NW
`Washington, DC 20001-4413
`(202) 408-4000
`
`Counsel for Patent Owner in
`IPR2015-01993
`
`1
`
`

`

`
`
`CERTIFICATE OF SERVICE
`The undersigned certifies that a copy of the foregoing BIOGEN’S LIST OF
`
`PROPOSED MOTIONS was served electronically via e-mail on April 15, 2016,
`
`in its entirety on the following:
`
`James T. Carmichael
`Carol A. Spiegel
`Carmichael IP, PLLC
`8000 Towers Crescent Drive, 13th Floor
`Tysons Corner, VA 22182
`jim@carmichaelip.com
`carol@carmichaelip.com
`
`Petitioner has agreed to electronic service.
`
`
`
`Dated: April 15, 2016
`
`
`
`
`
`
`
`
` By: /Erin M. Sommers /
`Erin M. Sommers, Reg. No. 60,974
`
`
`
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`

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