`U.S. Patent No. 9,015,883
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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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`FREDMAN BROS. FURNITURE COMPANY, INC.
`Petitioner
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`v.
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`BEDGEAR, LLC
`Patent Owner
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`Case: IPR2017-00351
`U.S. Patent No. 9,015,883
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`PATENT OWNER’S NOTICE OF APPEAL
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`Case IPR2017-00351
`U.S. Patent No. 9,015,883
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`Patent Owner Bedgear, LLC (“Bedgear”) hereby gives notice, pursuant to 35
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`U.S.C. § 142 and 37 C.F.R. § 90.2(a), of its appeal to the United States Court of
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`Appeals for the Federal Circuit from the Final Written Decision of the Patent Trial
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`and Appeal Board (“the Board”), entered on June 12, 2018 (Paper 41), and from all
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`orders, decisions, rulings, and opinions underlying the Final Written Decision.
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`In accordance with 37 C.F.R. § 90.2(a)(3)(ii), Bedgear anticipates that the
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`issues on appeal may include the following:
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`1. Whether the Board erred in determining that claims 1-4, 7-10,
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`13-15, 17, 18, and 20 of U.S. Patent No. 9,015,883 are unpatentable under
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`35 U.S.C. § 102.
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`2. Whether the Board erred in determining that claims 5, 6, 12,
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`and 19 of U.S. Patent No. 9,015,883 are unpatentable under 35 U.S.C. § 103.
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`3. Whether the claim constructions adopted by the Board were
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`correct.
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`4. Whether the Board adequately articulated its reasoning in
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`determining any of the above.
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`Bedgear reserves the right to challenge any finding or determination
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`supporting or related to the issues listed above and to challenge any other issues
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`Case IPR2017-00351
`U.S. Patent No. 9,015,883
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`decided adversely to Bedgear in any orders, decisions, rulings, or opinions
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`underlying the Final Written Decision.
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`Copies of Bedgear’s Notice of Appeal are being filed simultaneously with
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`the Director of the United States Patent and Trademark Office, the Patent Trial and
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`Appeal Board, and the Clerk of the United States Court of Appeals for the Federal
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`Circuit.
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`Date: June 14, 2018
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`Respectfully submitted,
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`By: /Joseph J. Richetti, Reg. No. 47024/
`Joseph J. Richetti (Reg. No. 47,024)
`BRYAN CAVE LEIGHTON
`PAISNER LLP
`1290 Avenue of the Americas
`New York, NY 10104
`Phone: (212) 541-1092
`joe.richetti@bclplaw.com
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`Attorney for Patent Owner–
`Bedgear, LLC
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`2
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`Case IPR2017-00351
`U.S. Patent No. 9,015,883
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies
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`that,
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`in addition
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`to being filed
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`electronically through the Patent Trial and Appeal Board's Patent Review
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`Processing System (PRPS), the original version of the foregoing PATENT
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`OWNER’S NOTICE OF APPEAL was filed by Express Mail (Express Mail Label
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`No. EK 633601106 US) on June 14, 2018, with the United States Patent and
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`Trademark Office, at the following address:
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`Office of the Solicitor
`United States Patent and Trademark Office Mail Stop 8
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the foregoing PATENT OWNER’S
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`NOTICE OF APPEAL was electronically filed with the United States Court of
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`Appeals for the Federal Circuit through CM/ECF and pay.gov on June 14, 2018.
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`Case IPR2017-00351
`U.S. Patent No. 9,015,883
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the foregoing PATENT OWNER’S
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`NOTICE OF APPEAL was served electronically via e-mail on June 14, 2018, in its
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`entirety on the following:
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`Jason R. Mudd
`Jason.mudd@eriseip.com
`Eric A. Buresh
`Eric.buresh@eriseip.com
`ptab@eriseip.com
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`ERISE IP, P.A.
`7015 College Blvd., Suite 700
`Overland Park, Kansas 66211
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`Date: June 14, 2018
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`Respectfully submitted,
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`By: /Joseph J. Richetti, Reg. No. 47024/
` Joseph J. Richetti
`Lead Attorney for Patent Owner
`Reg. No. 47,024
`BRYAN CAVE LEIGHTON
`PAISNER LLP
`1290 Avenue of the Americas
`New York, NY 10104
`General Tel: (212) 541-2000
`Direct Tel: (212) 541-1092
`Fax: (212) 541-4630
`Email: joe.richetti@bclplaw.com
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`Attorney for Patent Owner –
`Bedgear, LLC
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