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Case: 1:16-cv-04826 Document #: 52 Filed: 11/28/16 Page 1 of 3 PageID #:1870
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`
`
`
`
`Judge Joan H. Lefkow
`Magistrate Judge Maria Valdez
`
`
`
`Civil Action No. 16-cv-4826
`
`Document electronically filed
`
`T-REX PROPERTY AB,
`
`Plaintiff,
`
`
`
`
`v.
`
`CONTEXTMEDIA, INC. AND
`CONTEXTMEDIA HEALTH, LLC,
`
`Defendants.
`
`
`
`
`
`PLAINTIFF’S MOTION FOR LEAVE TO CITE ADDITIONAL AUTHORITY
`IN OPPOSITION TO DEFENDANT’S MOTION TO STAY
`PENDING INTER PARTES REVIEW AND
`COVERED BUSINESS METHOD REVIEW OF THE PATENTS-IN-SUIT
`
`Plaintiff T-Rex Property AB (“T-Rex”), by and through their attorneys, respectfully
`
`moves this Court to consider the following additional authority regarding Defendant’s Motion to
`
`Stay Pending Inter Partes Review and Covered Business Method Review of the Patents-in-Suit
`
`(D.I. 38):
`
`Unwired Planet, LLC v. Google Inc., No. 2015-1812 (Fed. Cir. Nov. 21, 2016) (slip op.
`
`attached as Exhibit 1).
`
`This decision affects the likelihood that third party BroadSign’s Covered Business
`
`Method petition against the ’603 Patent will be granted, and therefore the likelihood of
`
`simplification of issues (see, e.g., D.I. 40, Ex. 10 at 16).
`
`
`
`
`
`

`

`Case: 1:16-cv-04826 Document #: 52 Filed: 11/28/16 Page 2 of 3 PageID #:1871
`
`
`
`Dated: November 28, 2016
`
`
`
`
`
`Respectfully submitted,
`
`
`
`/s/ William Cory Spence_
`William Cory Spence (No. 6278496)
`Brian J. Beck (No. 6310979)
`Jacob Robert Graham (No. 6309125)
`SpencePC
`405 N. Wabash Ave., Suite P2E
`Chicago, Illinois 60611
`312-404-8882
`William.Spence@spencepc.com
`Brian.Beck@spencepc.com
`Jacob.Graham@spencepc.com
`Counsel for Plaintiff
`T-Rex Property AB
`
`
`
`
`
`2
`
`

`

`Case: 1:16-cv-04826 Document #: 52 Filed: 11/28/16 Page 3 of 3 PageID #:1872
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on November 28, 2016, a copy of the foregoing was served on
`
`counsel of record by electronic means pursuant to the court’s Electronic Case Filing (ECF)
`
`
`
`
`
`
`
`
`
`
`
`/s/ William Cory Spence
`
`
`
`
`
`system.
`
`
`
`
`
`

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