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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________
`GOOGLE INC.,
`Petitioner,
`v.
`ALEX IS THE BEST, LLC
`Patent Owner
`______________________________
`Case IPR2017-02056
`U.S. Patent No. 8,134,600
`______________________________
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`PATENT OWNER REQUEST FOR ADVERSE JUDGEMENT
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`UNDER 37 C.F.R. 42.73(b)(2)
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`IPR2017-02056 – Patent Owner Request for Adverse Judgment Under 37 C.F.R. 42.73(b)(2)
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`ARGUMENT
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`In interest of streamlining the proceedings between Alex Is The Best, LLC and Google,
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`Lenovo Holding Company, Inc. et al. and focusing its resources, Patent Owner has decided to
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`cancel claims 1-5, 8-10, 12 and 13 of U.S. Patent No. 8,134,600 (“the ‘600 patent”), on which
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`IPR2017-02056 was instituted.
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`Patent Owner’s decision to cancel the claims is not an admission regarding the merits of
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`Petitioner’s position that the claims are invalid and/or that the asserted references taken alone or
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`in combination, teach or suggest all of the limitations of these claims. Patent Owner’s decision to
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`cancel the claims is intended strictly for the purpose of lifting the pending litigation stays so that
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`it may move forward with patents where no IPRs were instituted.
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`RELIEF REQUESTED
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`In view of the requested cancellation of the claims of the ‘600 patent upon which trial
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`was instituted, Patent Owner respectfully requests that the PTAB enter an adverse judgment
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`against Patent Owner in this proceeding pursuant to 37 C.F.R. 42.73(b)(2).
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`Dated: June 5, 2018
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`aim@imiplaw.com
`docket@imiplaw.com
`(888) 413-7917
`(888) 415-3481 (fax)
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`Respectfully submitted,
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`By /C. Andrew Im/
`C. Andrew Im
`Registration No.: 40,657
`IM IP LAW
`2146 Orchard Mist Street
`Las Vegas, Nevada 89135
`Counsel for Patent Owner
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`IPR2017-02056 – Patent Owner Request for Adverse Judgment Under 37 C.F.R. 42.73(b)(2)
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`CERTIFICATE OF SERVICE
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`I hereby certify that on June 5, 2018, a true and correct copy of PATENT OWNER
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`REQUEST FOR ADVERSE JUDGMENT UNDER 37 C.F.R. 42.73(b)(2) is being served
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`electronically to the Petitioners as authorized in the Petition at the correspondence email
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`addresses of record as follows:
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`joshua.larsen@btlaw.com
`jeff.barron@btlaw.com
`steven.shipe@btlaw.com
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`By:
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`/C. Andrew Im/
`Reg. No. 40,657
`Counsel for Patent Owner
`IM IP LAW PLLC
`2146 Orchard Mist Street
`Las Vegas, Nevada 89135
`aim@imiplaw.com
`docket@imiplaw.com
`(888) 413-7917
`(888) 415-3481 (fax)
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