`
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
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`
`
`
`
`Civil Action No. 2:12cv2769 JPM-tmp
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`Hon. Jon Phipps McCalla
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`JURY DEMAND
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`
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`B.E. TECHNOLOGY, L.L.C.,
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`
`Plaintiff,
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`v.
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`FACEBOOK, INC.,
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`Defendant.
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`
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`MOTION TO STAY PENDING INTER PARTES REVIEWS OF U.S. PATENT NO.
`6,628,314
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`
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`Defendant Facebook, Inc. respectfully moves this Court to stay this case and all other
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`related cases involving the ‘314 Patent in which other defendants join this Motion, pending a
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`final written decision on all four petitions for inter partes review challenging the validity of the
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`‘314 Patent. The grounds for this Motion are fully set forth in the Defendant’s Memorandum of
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`Facts and Law in Support of Defendant’s Motion to Stay Pending Inter Partes Review of U.S.
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`Patent No. 6,628,314, and the supporting declarations and exhibits.
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`
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`
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`Respectfully submitted:
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`/s/ Orion Armon
`
`Heidi Keefe (pro hac vice)
`hkeefe@cooley.com
`Mark Weinstein (pro hac vice)
`mweinstein@cooley.com
`COOLEY LLP
`3175 Hanover Street
`Palo Alto, CA 94304-1130
`Telephone: (650) 843-5000
`Facsimile: (650) 849-7400
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`
`
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`Dated: November 27, 2013
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`Case 2:12-cv-02769-JPM-tmp Document 71 Filed 11/27/13 Page 2 of 3 PageID 484
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`
`
`
`Orion Armon (pro hac vice)
`oarmon@cooley.com
`Sara Radke (pro hac vice)
`sradke@cooley.com
`Peter Sauer (pro hac vice)
`COOLEY LLP
`380 Interlocken Crescent, Suite 900
`Broomfield, CO 80021
`Telephone: (720) 566-4000
`Facsimile: (720) 566-4099
`
`Heather J. Hubbard (TN # 23699)
`Laura P. Merritt (TN # 26482)
`WALLER LANSDEN DORTCH & DAVIS, LLP
`Nashville City Center
`511 Union St., Suite 2700
`Nashville, TN 37219-8966
`615-850-6024
`Fax: 615-244-6804
`heather.hubbard@wallerlaw.com
`laura.merritt@wallerlaw.com
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`Counsel for Defendant Facebook, Inc.
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`Case 2:12-cv-02769-JPM-tmp Document 71 Filed 11/27/13 Page 3 of 3 PageID 485
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`CERTIFICATE OF CONSULTATION
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`
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`Pursuant to Local Rule 7.2(a)(1)(B), I certify that on November 20, I spoke in person
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`with Daniel Weinberg, attorney for B.E. Technology, L.L.C. on behalf of Facebook and
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`defendants in the other related patent infringement cases brought by Plaintiff, regarding the filing
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`of motions to stay by all defendants in each of the related cases. I was advised by Mr. Weinberg
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`that Plaintiff B.E. Technology, L.L.C. opposes the relief sought by this motion.
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`/s/ Orion Armon
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`CERTIFICATE OF SERVICE
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`
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`I hereby certify that a copy of the foregoing has been served this 27th day of November,
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`2013, on the following counsel of record via the Court’s Electronic Filing System:
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`Craig Robert Kaufman
`Robert Edward Freitas
`Hsiang Hong Lin
`Qudus B. Olaniran
`FREITAS TSENG & KAUFMAN, LLP
`100 Marine Parkway, Suite 200
`Redwood Shores, CA 94065
`650-593-6300
`ckaufman@ftklaw.com
`rfreitas@ftklaw.com
`jlin@ftklaw.com
`qolaniran@ftklaw.com
`
`Richard M. Carter
`Adam J. Eckstein
`MARTIN TATE MORROW & MARSTON
`International Place, Tower II
`6410 Poplar Avenue, Suite 1000
`Memphis, TN 38119
`901-522-9000
`rcarter@martintate.com
`aeckstein@martintate.com
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`/s/
`
`Orion Armon
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