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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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`FLEX LOGIX TECHNOLOGIES INC.,
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`Petitioner
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`V.
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`VENKAT KONDA,
`
`Patent Owner
`
`____________
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`Case IPR2020-00260
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`Patent 8,269,523 B2
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`_________
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`
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`PATENT OWNER VENKAT KONDA’S LIST OF FILED AND PROPOSED
`MOTIONS
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`
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`IPR2020-00260
`Patent 8,269,523
`
`
`
`
`Paper No. 29
`PO’s List of Filed and Proposed Motions
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`PATENT OWNER’S LIST OF FILED AND PROPOSED MOTIONS
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`Pursuant to the Office Patent Trial and Appeal Board Consolidated Trial
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`Practice Guide, November 2019, Patent Owner, Venkat Konda (the “Patent
`
`Owner” or “Venkat Konda”), submits the following list of filed and proposed
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`motions it is currently contemplating filing. This list is provided without prejudice
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`to Patent Owner’s right to seek authorization to file additional motions or to not
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`file the motions listed herein.
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`I. Request for Rehearing
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`Pursuant to 37 C.F.R. § 42.71(c), Patent Owner Venkat Konda (“Patent
`
`Owner”) respectfully requested the Patent Trial and Appeal Board (“Board”)
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`reconsider its decision granting institution for inter partes review of U.S. Patent
`
`No. 8,269,523 (“the ‘523 patent”), on August 10, 2020. (Paper 26).
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`II. Motion to Exclude Evidence
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`Pursuant to 37 C.F.R. § 42.64, 37 C.F.R. § 42.11, and 37 C.F.R. §
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`42.51(b)(iii) Patent Owner filed motion to exclude from evidence exhibits Ex.
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`1002, Ex. 1003 and all the support presented in the Petition with respect to Ex.
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`1002 and Ex. 1003 served with the Petition, on August 10, 2020 (Paper 25).
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`Page 1 of 5
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`IPR2020-00260
`Patent 8,269,523
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`
`
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`Paper No. 29
`PO’s List of Filed and Proposed Motions
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`Pursuant to 37 CFR § 42.64, Patent Owner reserves the right to file a motion
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`to exclude evidence. While such a motion is automatically authorized, Patent
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`Owner identifies such a motion to preserve its right to file the same.
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`III. Motion to Amend the Patent
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`Pursuant to 37 CFR § 42.121(a), Patent Owner contemplates filing a motion
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`to amend one or more claims of the ‘523 Patent, after conferring with the Board,
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`regarding such a motion.
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`IV. Motion for Observations on Cross-Examination
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`Pursuant to 37 CFR § 42.20(a), Patent Owner reserves the right to file a
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`motion for observations on cross-examination. Patent Owner identifies such a
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`motion to preserve its right to file the same.
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`V. Motion to Submit Supplemental Information
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`Pursuant to 37 CFR § 42.123, Patent Owner contemplates filing a motion to
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`submit Supplemental Information. Patent Owner identifies such a motion to
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`preserve its right to file the same.
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`Patent Owner reserves the right to seek authorization, as required, to file
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`additional motions not listed herein.
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`
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`Date: August 17, 2020
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`Respectfully submitted,
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`
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`Page 2 of 5
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`IPR2020-00260
`Patent 8,269,523
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`
`
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`Paper No. 29
`PO’s List of Filed and Proposed Motions
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`
`
`/Venkat Konda/
`Venkat Konda
`Pro Se Counsel
`6278 Grand Oak Way
`San Jose, CA 95135
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`
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`Page 3 of 5
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`IPR2020-00260
`Patent 8,269,523
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`
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`Paper No. 29
`PO’s List of Filed and Proposed Motions
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that on August 17, 2020, the foregoing
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`Patent Owner’s List of Proposed Motions was served electronically via e-mail in
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`their entirety on the following counsel of record for Petitioner by email to PH-
`
`FlexLogix-Konda-IPR@paulhastings.com
`
`Lead counsel:
`Naveen Modi (Reg. No. 46,224),
`Backup counsel:
`1. Joseph E. Palys (Reg. No. 46,508)
`2. Paul M. Anderson (Reg. No. 39,896)
`3. Quadeer A. Ahmed (Reg. No. 60,835).
`
`
`Service information:
`Paul Hastings LLP,
`875 15th St. N.W.,
`Washington, D.C., 20005,
`Tel.: 202.551.1700,
`Fax: 202.551.1705,
`Email: PH-FlexLogix-Konda-IPR@paulhastings.com.
`
`
`
`
`
`/Venkat Konda/
`Venkat Konda
`Pro Se Counsel
`
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`Dated: August 17, 2020
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`Certificates - Page 1 of 5
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