`Paper No.
`Filed: July 7, 2017
`
`UNITED STATES PATENT AND TRADEMARK
`OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UBISOFT, INC. AND SQUARE ENIX, INC.,
`Petitioners v.
`
`UNILOC USA, INC. and UNILOC LUXEMBOURG S. A.
`Patent Owner
`
`Case IPR2017-01290
`U.S. Patent 6,510,466
`
`
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`PATENT OWNER’S UNOPPOSED MOTION FOR AN EXTENSION OF
`TIME TO FILE THE PRELIMINARY RESPONSE
`PURSUANT TO 37 C.F.R. § 42.5
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`Pursuant to 37 C.F.R. § 42.5, Patent Owner submits the present Unopposed
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`Motion for Extension of Time, requesting that the Board extend the due date for the
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`Preliminary Response four (4) days—from August 5, 2017 until August 9. 2017.
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`Petitioners do not oppose Patent Owner’s Motion. The Unopposed Motion is
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`supported by a showing of good cause. Thus, Patent Owner respectfully requests that
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`the Board grant the Unopposed Motion.
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`The Board has the authority to modify the due date for the preliminary response
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`on a showing of good cause. See 37 C.F.R. § 42.5(c)(1); 37 C.F.R. § 42.5(c)(2). Here,
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`
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`IPR2017-01290
`
`Patent 6,510,466
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`the facts and circumstances surrounding this case, as discussed below, support a
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`showing of good cause for extending the due date for the preliminary response.
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`The following IPRs were all filed on April 24, 2017: IPR2017-01315,
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`IPR2017-01290, and IPR2017-01291. These IPRs challenge the same set of patents
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`concerning ongoing litigation between the Patent Owner and Petitioners. Based on
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`the slightly varied date of the PTAB notices, the patent owner preliminary response
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`dates are as follows:
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`IPR2017-01315: August 9, 2017
`IPR2017-01290: August 5, 2017
`IPR2017-01291: August 9, 2017
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`Patent owner seeks to synchronize the patent owner preliminary response dates to
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`August 9 in order to address all at the same time.
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`Patent Owner submits that the extension period of four days is reasonable, and
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`will not adversely impact the remaining schedule of the proceeding if an inter partes
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`review is instituted. See Sony Mobile Communications (USA) Inc. v. Adaptix, Inc.,
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`IPR2014-01525, Paper 10.
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`For the foregoing reasons, the present Unopposed Motion is supported by a
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`showing of good cause warranting the extension of the due date for the preliminary
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`response. Accordingly, Patent Owner respectfully requests that the Board grant the
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`Unopposed Motion.
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`Date: July 7, 2017
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`Respectfully submitted,
`
`
`/s/Brett Mangrum (Reg No. 64,783)
`
`By:
`
`Brett Mangrum, Reg. No. 64,783
`Ryan Loveless, Reg No. 51,970
`Etheridge Law Group
`2600 E. Southlake Blvd., Ste. 120-324
`Southlake, TX 76092
`
`brett@etheridgelaw.com
`469-401-2659
`
`ryan@etheridgelaw.com
`972-292-8303
`
`Sean D. Burdick Reg. No. 51,513
`Uniloc USA, Inc.
`7160 Dallas Parkway, Ste. 380
`Plano,TX 75024
`sean.burdick@unilocusa.com
`972-905-9580
`
`Attorneys for UNILOC USA, INC. and
`UNILOC LUXEMBOURG S. A.
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`3
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`CERTIFICATE OF SERVICE
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`I certify that the foregoing PATENT OWNER’S UNOPPOSED MOTION
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`FOR AN EXTENSION OF TIME TO FILE THE PRELIMINARY RESPONSE
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`PURSUANT TO 37 C.F.R. § 42.5 was served on the Petitioners’ counselors of
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`record by PRPS electronic notification, as agreed to by the parties:
`
`Eric A. Buresh, Reg. No. 50,394;
`eric.buresh@eriseip.com
`Mark C. Lang, Reg. No. 55, 356;
`mark.lang@eriseip.com
`Kathleen D. Fitterling, Reg. No. 62,950;
`kathleen.fitterling@eriseip.com
`
`4
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