`
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`Case No. 2:16-cv-741-JRG
`(Lead)
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`JURY TRIAL REQUESTED
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`
`Case No. 2:16-cv-863-JRG
`(Consolidated)
`
`
`§
`§
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`§ §
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`§
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`§ §
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`§
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`§ §
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`§
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`UNILOC USA, INC. and
`UNILOC LUXEMBOURG, S.A.,
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`
`Plaintiffs,
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`
`v.
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`ADP, LLC,
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`Defendant.
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`v.
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`ZENDESK, INC.
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`Defendant.
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`NOTICE OF COMPLIANCE WITH THE COURT’S STANDING ORDER REGARDING
`MOTIONS UNDER 35 U.S.C. § 101
`
`Pursuant to the Court’s Standing Order Regarding Motions under 35 U.S.C. § 101 and
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`Accompanying Certifications in Cases Assigned to United States District Judge Rodney Gilstrap,
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`Defendant Zendesk, Inc. and Plaintiffs Uniloc USA, Inc. and Uniloc Luxembourg, S.A.
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`respectfully submit the attached joint letter setting forth their positions regarding whether or not
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`claim construction is necessary for the Court’s analysis under 35 U.S.C. § 101.
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`07270-00002/8574869.1
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`
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`Case 2:16-cv-00741-RWS Document 83 Filed 11/17/16 Page 2 of 3 PageID #: 907
`
`Respectfully submitted,
`
`/s/ J. Mark Mann_________
`
`J. Mark Mann
`State Bar No. 12926150
`MANN | TINDEL | THOMPSON
`300 West Main Street
`Henderson, Texas 75652
`Telephone: (903) 657-8540
`Facsimile: (903) 657-6003
`mark@themannfirm.com
`
`Kevin Johnson
`kevinjohnson@quinnemanuel.com
`Victoria Maroulis
`victoriamaroulis@quinnemanuel.com
`Ray Zado
`rayzado@quinnemanuel.com
`QUINN EMANUEL URQUHART & SULLIVAN
`LLP
`555 Twin Dolphin Dr., 5th Floor
`Redwood Shores, CA 94065
`Tel: 650-801-5000
`Fax: 650-801-5100
`
`Sam Stake
`samstake@quinnemanuel.com
`QUINN EMANUEL URQUHART & SULLIVAN
`LLP
`50 California Street, 22nd Floor
`San Francisco, CA 94111
`Tel: 415-875-6600
`Fax: 415-845-9700
`
`Attorneys for Zendesk, Inc.
`
`
`
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`
`
`Dated: November 17, 2016
`
`
`/s/ Kevin Gannon
`
`Paul J. Hayes
`Kevin Gannon
`CESARI AND MCKENNA, LLP
`88 Black Falcon Ave Suite 271
`Boston, MA 02110
`Telephone: (617) 951-2500
`Facsimile: (617) 951-3927
`Email: pjh@c-m.com
`Email: kgannon@c-m.com
`
`Craig Tadlock
`State Bar No. 00791766
`TADLOCK LAW FIRM PLLC
`2701 Dallas Parkway, Suite 360
`Plano, TX 75093
`Tel: (903) 730-6789
`Email: craig@tadlocklawfirm.com
`
`Attorneys for the Plaintiffs
`
`07270-00002/8574869.1
`
`
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`Case 2:16-cv-00741-RWS Document 83 Filed 11/17/16 Page 3 of 3 PageID #: 908
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`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that all counsel of record who are deemed to have
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`consented to electronic service are being served with a copy of this document on November 17,
`
`2016.
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`____Sam Stake______
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`07270-00002/8574869.1
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`1
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`
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