`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`JUNIPER NETWORKS, INC., BROCADE COMMUNICATIONS SYS.,
`INC., AND RUCKUS WIRELESS, INC.
`Petitioner
`
`
`v.
`
`
`MOBILE TELECOMMUNICATIONS TECHNOLOGIES, LLC
`Patent Owner
`
`____________
`
`
`Case IPR2017-00640
`Patent 5,659,891
`
`____________
`
`
`
`PATENT OWNER’S REQUEST FOR ADVERSE JUDGMENT UNDER
`37 C.F.R. § 42.73(b)
`
`
`
`
`
`Case No. IPR2017-00640
`U.S. Patent No. 5,659,891
`
`Trial was instituted with respect to Claims 1-5 of U.S. Patent No.
`
`5,659,891 (the “’891 Patent”) (Paper No. 16). Pursuant to 37 C.F.R. §
`
`42.73(b)(2), “[a] party may request judgment against itself at any time during a
`
`proceeding,” including by “cancellation or disclaimer of a claim such that the
`
`party has no remaining claim in the trial.” Accordingly, Patent Owner Mobile
`
`Telecommunications Technologies, LLC respectfully requests that the Board
`
`cancel all of the claims challenged in this proceeding (claims 1-5 of the ‘891
`
`Patent) and enter adverse judgment against it.
`
`Date: October 23, 2017
`
`Respectfully submitted,
`
`/John R. Kasha/___________________
`John R. Kasha, Lead Counsel
`Registration No. 53,100
`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(703) 867-1886, telephone
`(301) 340-3022, facsimile
`Email: john.kasha@kashalaw.com
`
`
`
`
`
`
`2
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 23rd day of October, 2017, a true and correct
`
`copy of the foregoing PATENT OWNER’S REQUEST FOR ADVERSE
`
`JUDGMENT UNDER 37 C.F.R. § 42.73(b) was duly served via electronic mail
`
`upon nhefazi@irell.com (Nima Hefazi), rcarson@irell.com (Rebecca Carson),
`
`jkagan@irell.com (Jonathan Kagan), ronw@ruyakcherian.com (Ronald
`
`Wielkopolski), donl@ruyakcheriam.com (Don F. Livornese),
`
`sunnyc@ruyakcherian.com (Korula T. Cherian) - counsel of record for Juniper
`
`Networks, Inc., Brocade Communications Sys., Inc., and Ruckus Wireless, Inc.
`
`(“Petitioner”).
`
`
`
`Respectfully submitted,
`/John R. Kasha/
`Registration No. 53,100
`Attorney for Patent Owner
`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(703) 867-1886, telephone
`(301) 340-3022, facsimile
`Email: john.kasha@kashalaw.com
`
`
`
`
`
`
`
`
`
`
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