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`IPR2016-00118
`PATENT NO. 8,155,342
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`UNIFIED PATENTS INC.
`Petitioner
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`v.
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`BLITZSAFE TEXAS, LLC
`Patent Owner
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`____________
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`IPR2016-00118
`Patent 8,155,342
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`____________
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`NOTICE OF ERROR IN PATENT OWNER PRELIMINARY RESPONSE
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`IPR2016-00118
`PATENT NO. 8,155,342
`It has come to Patent Owner’s attention that Patent Owner’s Preliminary
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`Response (Paper No. 11) contains four errors. In particular, on pages 44, 47, 49,
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`and 53, the Preliminary Response states:
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`“Petitioner does disclose the limitations of [claim #] that are missing
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`from the base references as required by Graham.”
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`Patent Owner inadvertently omitted the word “not” from these sentences. The
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`Preliminary Response should state the following at each of these locations:
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`• Last three lines at the bottom of page 44:
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`“First, Petitioner does not disclose the limitations of Claims 7
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`through 10 that are missing from the base references as required by
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`Graham.”
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`• Lines one through three on page 47:
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`“First, Petitioner does not disclose the limitations of Claim 11 that
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`are missing from the base references as required by Graham.”
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`• Lines five through seven on page 49:
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`“Petitioner does not disclose the limitations of the claims that are
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`missing from the base references as required by Graham.”
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`• Lines eight through ten on page 53:
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`“First, Petitioner does not disclose the limitations of Claim 22 that
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`are missing from the base references as required by Graham.”
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`IPR2016-00118
`PATENT NO. 8,155,342
`Patent Owner notified Petitioner and the Board of these errors, and the
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`Board conducted a conference call where authorization was granted to file this
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`notice. Petitioner indicated that it does not oppose the filing of this notice.
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`Respectfully submitted,
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`By:
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`/s/Peter Lambrianakos/
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`Peter Lambrianakos (Reg. No. 58,279)
`Lead Counsel for Patent Owner
`Brown Rudnick LLP
`7 Times Square
`New York, NY 10036
`Tel: 212-209-4800
`Fax: 212-209-4801
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`April 22, 2016
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`IPR2016-00118
`PATENT NO. 8,155,342
`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6(e)(4) & 42.105(b)
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`A copy of BLITZSAFE TEXAS, LLC’S NOTICE OF ERROR IN PATENT
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`OWNER PRELIMINARY RESPONSE has been served on Petitioner at the
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`correspondence of the Petitioner as follows:
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`Paul C. Haughey
`Kilpatrick Townsend & Stockton LLP
`Two Embarcadero Center, Eighth Floor
`San Francisco, CA 94111
`phaughey@kilpatricktownsend.com
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`Scott E. Kolassa
`Kilpatrick Townsend & Stockton LLP
`1080 Marsh Road
`Menlo Park, CA 94025
`SKolassa@kilpatricktownsend.com
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`Jonathan Stroud
`Unified Patents Inc.
`1875 Connecticut Ave., NW. Floor 10
`Washington, D.C., 20009
`1080 Marsh Road
`jonathan@unifiedpatents.com
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`April 22, 2016
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`By:
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`/s/Peter Lambrianakos/
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`Peter Lambrianakos (Reg. No. 58,279)
`Lead Counsel for Patent Owner
`Brown Rudnick LLP
`7 Times Square
`New York, NY 10036
`Tel: 212-209-4800
`Fax: 212-209-4801
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