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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`VALVE CORPORATION,
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`Petitioner,
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`v.
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`IRONBURG INVENTIONS LTD.,
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`Patent Owner.
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`____________
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`Case IPR2016-00948
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`Patent 8,641,525
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`____________
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`PATENT OWNER’S LIST OF PROPOSED MOTIONS
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`IPR2016-00948
`Patent 8,641,525
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`Pursuant to the Office Patent Trial Practice Guide, 77 Fed. Reg. 48756,
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`48765-66 (August 14, 2012), in advance of the initial conference call scheduled for
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`Wednesday, October 26, 2016, Patent Owner Ironburg Inventions Ltd.
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`(“Ironburg”) hereby submits the following list of proposed motions it is currently
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`contemplating filing. Although motions to amend claims, motions to exclude
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`evidence and motions for observations on cross-examination have been authorized
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`by the Board, Ironburg identifies such motions here to preserve its right to file
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`them. This list is provided without prejudice to Patent Owner’s right to seek
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`authorization to file additional motions pursuant to the Board's authorization or to
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`refrain from filing the motions listed herein.
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`1. A motion to amend the claims of the patent at issue pursuant to 37 C.F.R. §
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`42.121(a);
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`2. A motion to exclude evidence pursuant to 37 C.F.R. § 42.64(c) based at least
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`on the grounds set forth in Patent Owner’s Objections in its Preliminary
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`Response to Petitioner’s Evidence;
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`3. A motion to compel deposition dates and location of declarant in United
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`States;
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`4. A motion for additional discovery pursuant to 37 C.F.R. § 42.51;
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`5. A motion to submit supplemental information pursuant to 37 C.F.R. §
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`42.123; and
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`1
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`IPR2016-00948
`Patent 8,641,525
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`6. A motion to seal, containing a proposed protective order, in the event that
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`Ironburg determines that it intends to rely upon confidential information
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`during the trial phase of this Inter Partes Review proceeding.
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`Respectfully submitted,
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`By: /s/ Ehab M. Samuel
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`Ehab Samuel
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`Attorney for Patent Owner
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`Reg. No. 57,905
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`Danielle Mihalkanin
`Attorney for Patent Owner
`Reg. No. 69,506
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`Date: October 24, 2016
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`IPR2016-00948
`Patent 8,641,525
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b), the undersigned certifies
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`
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`that on October 24, 2016, a complete and entire electronic copy of this Petitioner’s
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`List of Proposed Motions for Inter Partes Review No. 2016-00948, was served
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`PTAB E2E to Petitioner’s counsel of record at the following address:
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`Joshua C. Harrison, Reg. No. 45,686, josh@bhiplaw.com
`Reynaldo C. Barcelo, Reg. No. 42,290, rey@bhiplaw.com
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`Respectfully submitted,
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`By: /s/ Ehab M. Samuel
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`Ehab Samuel
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`Attorney for Patent Owner
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`Reg. No. 57,905
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`Danielle Mihalkanin
`Attorney for Patent Owner
`Reg. No. 69,506
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`Date: October 24, 2016
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`317860491.1
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`3
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