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Paper No. 14
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MONSTER WORLDWIDE, INC., INDEED, INC., and
`THELADDERS.COM, INC.
`Petitioner
`
`v .
`
`CAREER DESTINATION DEVELOPMENT, LLC
`Patent Owner
`
`Case CBM2014-00070
`Patent 8,374,901
`
`Filed: September 18, 2014
`
`PETITIONER’S LIST OF PROPOSED MOTIONS
`
`

`

`Case CBM2014-00070
`Patent 8,374,901
`Pursuant to the Board’s Decision (Paper No. 12) and Scheduling Order
`
`(Paper No. 13) setting an Initial Conference Call for September 23, 2014, and
`
`in accordance with the Office Patent Trial Practice Guide, 77 Fed. Reg.
`
`48756, 48765-66, Petitioner Monster Worldwide Inc., Indeed Inc., and
`
`TheLadders.com, Inc. (collectively “Petitioner”), hereby submits its list of
`
`proposed motions currently anticipated by the Petitioner. Petitioner intends
`
`to seek authorization during the Initial Conference Call to file the following
`
`motions:
`
` A Motion to Formally Incorporate Dependent Claims 2-11 Into
`
`Case CBM2014-00070 As Being Encompassed By The Board’s
`
`Review of Claim 1 Under 35 U.S.C. § 112.
`
`Petitioner does not currently anticipate filing additional motions,
`
`however Petitioner reserves the right to seek authorization from the Board to
`
`file additional motions in accordance with the Board’s Scheduling Order and
`
`on any motion filed by Patent Holder.
`
`Dated: September 18, 2014
`
`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
`
`

`

`Case CBM2014-00070
`Patent 8,374,901
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing
`
`PETITIONER’S LIST OF PROPOSED MOTIONS was served on
`
`September 18, 2014 by electronic mail on:
`
`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
`
`Dated: September 18, 2014
`
`By: /Andrew Horner/
`Andrew Horner
`
`3
`
`

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