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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MONSTER WORLDWIDE, INC., INDEED, INC., and
`THELADDERS.COM, INC.
`Petitioner
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`v .
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`CAREER DESTINATION DEVELOPMENT, LLC
`Patent Owner
`
`Case CBM2014-00070
`Patent 8,374,901
`
`Filed: September 18, 2014
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`PETITIONER’S LIST OF PROPOSED MOTIONS
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`
`
`Case CBM2014-00070
`Patent 8,374,901
`Pursuant to the Board’s Decision (Paper No. 12) and Scheduling Order
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`(Paper No. 13) setting an Initial Conference Call for September 23, 2014, and
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`in accordance with the Office Patent Trial Practice Guide, 77 Fed. Reg.
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`48756, 48765-66, Petitioner Monster Worldwide Inc., Indeed Inc., and
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`TheLadders.com, Inc. (collectively “Petitioner”), hereby submits its list of
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`proposed motions currently anticipated by the Petitioner. Petitioner intends
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`to seek authorization during the Initial Conference Call to file the following
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`motions:
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` A Motion to Formally Incorporate Dependent Claims 2-11 Into
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`Case CBM2014-00070 As Being Encompassed By The Board’s
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`Review of Claim 1 Under 35 U.S.C. § 112.
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`Petitioner does not currently anticipate filing additional motions,
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`however Petitioner reserves the right to seek authorization from the Board to
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`file additional motions in accordance with the Board’s Scheduling Order and
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`on any motion filed by Patent Holder.
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`Dated: September 18, 2014
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`By: /Justin F. Boyce/
`Justin F. Boyce (Reg. No. 40,920)
`Dechert LLP
`2440 W. El Camino Real, Suite 700
`Mountain View, CA 94040-1499
`Telephone: (650) 813-4853
`Facsimile:
`(650) 813-4848
`Email: justin.boyce@dechert.com
`Attorney for Petitioner
`2
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`
`
`Case CBM2014-00070
`Patent 8,374,901
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and correct copy of the foregoing
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`PETITIONER’S LIST OF PROPOSED MOTIONS was served on
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`September 18, 2014 by electronic mail on:
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`Jim Kernell
`jkernell@kcpatentlaw.com
`Erickson, Kernell, Derusseau & Kleypas, LLC
`8900 State Line Road, Suite 500
`Leawood, KS 66206
`Counsel for Patent Owner
`
`David L. Marcus
`dmarcus@bmlawkc.com
`Bartle & Marcus LLC
`1100 Main Street
`Suite 2730
`Kansas City, Missouri 6410
`Backup Counsel for Patent Owner
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`Dated: September 18, 2014
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`By: /Andrew Horner/
`Andrew Horner
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`3
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`