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` Paper No.
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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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`SIERRA WIRELESS AMERICA, INC., SIERRA WIRELESS, INC. AND RPX
`CORP.
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`Petitioners
`v.
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`M2M SOLUTIONS LLC
`Patent Owner
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`Patent No. 8,648,717
`Issue Date: February 11, 2015
`Title: PROGRAMMABLE COMMUNICATOR
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`Inter Partes Review No. IPR2016-01073
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`PETITIONERS’ MOTION TO EXPUNGE EXHIBIT 1130
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`U.S. Patent No. 8,648,717
`Motion to Expunge
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`I.
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`Introduction
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`Petitioners hereby request that Exhibit 1130 be expunged from the record of
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`IPR2016-01073.
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`II.
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`STATEMENT OF REASONS FOR RELIEF REQUESTED
`On May 19, 2016, Petitioners filed a petition for inter partes review in this
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`case with a motion for joinder and a set of Exhibits. Paper 1. This petition is
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`similar to the petition on which proceedings were instituted in IPR2016-00055.
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`See, e.g., Paper 2 at p. 1-3. As set forth in the petition, certain exhibits numbers
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`were not used in this petition in order to maintain consistency between exhibit
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`numbering of this petition and the previously instituted petition in IPR2016-00055.
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`Paper 1, fn. 1. However, despite not using Exhibit 1130 in the petition, Exhibit
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`1130 from IPR2016-00055 was inadvertently filed with the petition on May 19.
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`Because Exhibit 1130 is not relied on in the petition, it should not have been filed
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`with the petition.
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`Therefore, Petitioners submit there is good cause to expunge Exhibit 1130
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`from the record in this proceeding.
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`III. Conclusion
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`For the foregoing reasons, Petitioners respectfully request that Exhibit 1130
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`be expunged from the record of IPR2016-01073.
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`Respectfully submitted,
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`1
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`U.S. Patent No. 8,648,717
`Motion to Expunge
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`Dated: May 27, 2016
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`By:
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`/Jennifer Hayes/
`Reg. No. 50,845
`Nixon Peabody LLP
`P.O. Box 60610
`Palo Alto, CA 94306
`Tel. (650) 320-7763
`Fax (650) 320-7701
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`2
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`U.S. Patent No. 8,648,717
`Motion to Expunge
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a copy of the foregoing Motion for Joinder
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`to Related Instituted Inter Partes Review was served on April 8, 2016 by placing a
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`copy into FEDERAL EXPRESS directed to the attorneys of record for the patent at
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`the following address:
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`Sunstein Kann Murphy & Timbers LLP
`Attn: Jonathan C. Lovely, Reg. No. 60,821
`125 Summer Street
`Boston MA 02110-1618
`Counsel for Patent Owner, M2M SOLUTIONS LLC
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`and upon the attorney of record in the related litigations:
`Marc N. Henschke Foley & Lardner LLP
`111 Huntington Avenue, Suite 2600
`Boston, MA 02199
`A courtesy copy of the Motion for Joinder to Related Instituted Inter Partes Review
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`was served in its entirety on May 27, 2016, by e-mail on the following individuals:
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`Jeffrey Costakos
`jcostakos@foley.com
`Michelle Moran
`mmoran@foley.com
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`By: /Jennifer Hayes/
`Counsel for Petitioner
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`3
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