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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`__________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`__________________________
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`UNIFIED PATENTS INC.,
`Petitioner,
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`v.
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`BRADIUM TECHNOLOGIES LLC,
`Patent Owner.
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`__________________________
`
`Case IPR2018-00952
`Patent No. 9,253,239
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`__________________________
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`UNOPPOSED MOTION TO WITHDRAW PATENT OWNER’S
`CONTINGENT MOTION TO AMEND
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`I.
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`Introduction
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`IPR2018-00952
`U.S. Patent No. 9,253,239
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`On August April 1, 2019, Patent Owner filed a Contingent Motion to Amend
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`in the present proceeding. See Paper 39; seeking to add amended claim 20 new
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`claim 21 to the case. Petitioner filed its Opposition; See Paper 42, on July 1, 2019.
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`Patent Owner subsequently filed its Reply to Opposition See Paper 44 on July 29,
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`2019, and Petitioner filed its Sur-Reply, Paper 48, on September 3, 2019.
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`On September 11, 2019, Patent Owner was granted permission to file this
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`Unopposed Motion to Withdraw via email.
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`II. Requested Relief
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`Patent Owner seeks to withdraw its Contingent Motion to Amend. Patent
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`Owner has met and conferred with opposing counsel and Petitioner does not
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`oppose this motion. Accordingly, Patent Owner requests this motion be granted
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`and that: 1) The Contingent Motion to Amend be withdrawn, and 2) no further
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`argument on the withdrawn motion be allowed at Oral Argument.
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`Good cause exists for the granting of this Motion because no party will be
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`prejudiced and because this Motion is being filed prior to oral argument in this
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`matter.
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`-1-
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`III. Request for Conference Call with the Board
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`IPR2018-00952
`U.S. Patent No. 9,253,239
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`Should the Board wish to discuss the matter further, Patent Owner
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`hereby request a conference call with the Board to discuss any concerns prior
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`to the Board issuing a decision on the Motion.
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`
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`Respectfully submitted,
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`Dated: September 11, 2019
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`/s/ Michael E. Shanahan
`Michael E. Shanahan (Reg. No.
`43,914) Bradium Technologies LLC
`75 Montebello Rd.
`Suffern, NY 10901
`Tel: (845) 368-4000
`mshanahan@generalpatent.com
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`Counsel for Patent Owner
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`-2-
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`
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`IPR2018-00952
`U.S. Patent No. 9,253,239
`
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §42.6(e), the undersigned certifies that on
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`
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`September 11, 2019, the foregoing Bradium Technology’s Unopposed Motion to
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`Withdraw Patent Owner’s Contingent Motion to Amend was served via electronic
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`mail upon the following counsel of record for the Petitioner:
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`Roshan Suresh Mansinghani (Reg. No. 62,429)
`Unified Patents Inc.
`13355 Noel Road, Suite 1100
`Dallas, TX 75240
`Tel: (214) 945-0200
`Email: roshan@unifiedpatents.com
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`Alyssa J. Holtslander (Reg. No. 64,026)
`Jonathan Stroud (Reg. No. 72,518)
`Unified Patents Inc.
`1875 Connecticut Ave. NW, Floor 10
`Washington, DC 20009
`Tel: (202) 750-3605
`Email: alyssa@unifiedpatents.com
`Email: jonathan@unifiedpatents.com
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`David L. Cavanaugh (Reg. No. 36,476)
`Daniel V. Williams (Reg. No. 45,221)
`Jonathan E. Robe (Reg. No. 76,033)
`WILMER, CUTLER, PICKERING, HALE AND DORR, LLP
`1875 Pennsylvania Avenue, NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: David.Cavanaugh@wilmerhale.com
`Email: Daniel.Williams@wilmerhale.com
`Email: Jonathan.Robe@Wilmerhale.com
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`
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`
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`-3-
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`
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`Dated: September 11, 2019
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`
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`IPR2018-00952
`U.S. Patent No. 9,253,239
`
`
`
`
`/s/ Michael E. Shanahan
`Michael E. Shanahan (Reg. No.
`43,914) Bradium Technologies LLC
`75 Montebello Rd.
`Suffern, NY 10901
`Tel: (845) 368-4000
`mshanahan@generalpatent.com
`
`Counsel for Patent Owner
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`-4-
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`