`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________________
`
`UNIFIED PATENTS INC.,
`Petitioner,
`
`v.
`
`BRADIUM TECHNOLOGIES LLC,
`Patent Owner.
`
`__________________________
`
`Case IPR2018-00952
`Patent No. 9,253,239
`
`__________________________
`
`
`UNOPPOSED MOTION TO WITHDRAW PATENT OWNER’S
`CONTINGENT MOTION TO AMEND
`
`
`
`
`
`
`
`
`
`I.
`
`Introduction
`
`IPR2018-00952
`U.S. Patent No. 9,253,239
`
`
`On August April 1, 2019, Patent Owner filed a Contingent Motion to Amend
`
`in the present proceeding. See Paper 39; seeking to add amended claim 20 new
`
`claim 21 to the case. Petitioner filed its Opposition; See Paper 42, on July 1, 2019.
`
`Patent Owner subsequently filed its Reply to Opposition See Paper 44 on July 29,
`
`2019, and Petitioner filed its Sur-Reply, Paper 48, on September 3, 2019.
`
`On September 11, 2019, Patent Owner was granted permission to file this
`
`Unopposed Motion to Withdraw via email.
`
`II. Requested Relief
`
`Patent Owner seeks to withdraw its Contingent Motion to Amend. Patent
`
`Owner has met and conferred with opposing counsel and Petitioner does not
`
`oppose this motion. Accordingly, Patent Owner requests this motion be granted
`
`and that: 1) The Contingent Motion to Amend be withdrawn, and 2) no further
`
`argument on the withdrawn motion be allowed at Oral Argument.
`
`Good cause exists for the granting of this Motion because no party will be
`
`prejudiced and because this Motion is being filed prior to oral argument in this
`
`matter.
`
`-1-
`
`
`
`III. Request for Conference Call with the Board
`
`IPR2018-00952
`U.S. Patent No. 9,253,239
`
`
`Should the Board wish to discuss the matter further, Patent Owner
`
`hereby request a conference call with the Board to discuss any concerns prior
`
`to the Board issuing a decision on the Motion.
`
`
`
`Respectfully submitted,
`
`Dated: September 11, 2019
`
`
`
`
`
`
`
`
`
`/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
`
`-2-
`
`
`
`IPR2018-00952
`U.S. Patent No. 9,253,239
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §42.6(e), the undersigned certifies that on
`
`
`
`September 11, 2019, the foregoing Bradium Technology’s Unopposed Motion to
`
`Withdraw Patent Owner’s Contingent Motion to Amend was served via electronic
`
`mail upon the following counsel of record for the Petitioner:
`
`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
`
`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
`
`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
`
`
`
`
`
`-3-
`
`
`
`Dated: September 11, 2019
`
`
`
`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
`
`-4-
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
