`Patent 6,101,534
`Paper No. 8
`Filed: April 15, 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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`GAMELOFT, S.A.,
`Petitioner,
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`v.
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`ROTHSCHILD DIGITAL MEDIA INNOVATIONS, LLC,
`Patent Owner.
`____________
`
`Case IPR2016-00472
`Patent 6,101,534
`____________
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`WAIVER OF PATENT OWNER PRELIMINARY RESPONSE AND
`STATEMENT OF NON-OPPOSITION TO JOINDER
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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 IPR2016-00472
`Patent 6,101,534
`Pursuant to 37 C.F.R. 42.107(b), patent owner Rothschild Digital Media
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`Innovations, LLC (“Patent Owner”) hereby elects to waive the patent owner
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`preliminary response in the above-captioned case number IPR2016-00472.
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`Patent Owner further notes that petitioner Gameloft, S.A. filed a motion for
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`joinder in this case (Paper No. 4 (the “Motion”)), seeking joinder of this case with
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`the trial already instituted in Sony Computer Entertainment America LLC v.
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`Rothschild Digital Media Innovations, LLC, Case No. IPR2015-01364 (the “Sony
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`IPR”). The Motion represents throughout that the petition in the present
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`proceeding is limited to the grounds on which the Sony IPR was instituted. On
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`that basis, and while preserving all arguments made or yet to be made by Patent
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`Owner in the Sony IPR, Patent Owner does not oppose joinder.
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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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`
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`
`
`Date: April 15, 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 15th day of April 2016, a true and
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`correct copy of the foregoing WAIVER OF PATENT OWNER PRELIMINARY
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`RESPONSE AND STATEMENT OF NON-OPPOSITION TO JOINDER, on counsel of
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`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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`Dated: April 15, 2016
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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, Suite 700
`Miami, Florida 33131
`Telephone: (305) 372-7474
`Facsimile: (305) 372-7475
`Counsel for Rothschild Digital Media
`Innovations, LLC
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