`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`MERRILL COMMUNICATIONS LLC d/b/a MERRILL
`CORPORATION,
`Petitioner
`
`v.
`
` E-NUMERATE SOLUTIONS, INC.,
`Patent Owner
`
`Case IPR2018-01391
`U.S. Patent 9,262,383
`
`
`
`
`
`
`
`
`
`
`__________________
`
`
`WAIVER OF PATENT OWNER’S PRELIMINARY RESPONSE
`
`Pursuant to 37 C.F.R. §42.107(b), Patent Owner, E-NUMERATE
`
`SOLUTIONS, INC. hereby elects to waive its preliminary response in this
`
`Inter Partes Review No. 2018-01391. As indicated in the Trial Practice Guide,
`
`no adverse inference should be taken by this election. See Office Patent Trial
`
`Practice Guide, Fed. Reg. Vol. 77, No. 157 (2012) at Section II.C. This
`
`
`
`1
`
`
`
`election shall not constitute a waiver or admission by Patent Owner with
`
`respect to any material set forth in the Petition.
`
`
`
`Date: November 26, 2018
`
`
`
`
`
`By: /Gregory Gonsalves/
`
`Dr. Gregory Gonsalves
`Reg. No. 43,639
`2216 Beacon Lane
`Falls Church, Virginia 22043
`(571) 419-7252
`gonsalves@gonsalveslawfirm.com
`
`
`
`2
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e), this is to certify that I caused an
`
`electronic copy of the foregoing PATENT OWNER’S WAIVER OF PRELIMINARY
`
`RESPONSE to be served on the Petitioner’s lead counsel listed below by filing in
`
`the Patent Review Processing System and by email to the following email address:
`
`Lead Counsel
`Katherine J. Rahlin
`Fredrikson & Byron, P.A.
`200 South Sixth Street, Suite 4000
`Minneapolis, MN 55402
`Phone: (612) 492-7370
`Fax: (612) 492-7077
`krahlin@fredlaw.com
`
`
`
`
`Date: November 26, 2018
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By: _/Gregory Gonsalves_____
`Dr. Gregory Gonsalves
`Reg. No. 43,639
`2216 Beacon Lane
`Falls Church, Virginia 22043
`(571) 419-7252
`gonsalves@gonsalveslawfirm.com
`
`
`
`3
`
`
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