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` Case No. IPR2016-01063
` U.S. Patent No. 8,717,166
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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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`GEOTAB INC. and TV MANAGEMENT, INC., d/b/a GPS NORTH
`AMERICA
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`Petitioners,
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`v.
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`PERDIEMCO LLC,
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`Patent Owner
`________________
`
`Case IPR2016-01063
`U.S. Patent No. 8,717,166
`________________
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`PATENT OWNER’S RESPONSE
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` Case No. IPR2016-01063
` U.S. Patent No. 8,717,166
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`Patent Owner PerdiemCo LLC (“Patent Owner”), hereby submits this
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`response to the petition filed by TV Management Inc., D/B/A GPS North
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`America (“Petitioner”)1 on May 19, 2016 requesting inter partes review of
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`claims 1-10, 13-16, and 19-25 of U.S. Patent No. 8,717,166 (“’166 Patent”).
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`Patent Owner has filed a statutory disclaimer under 37 CFR 1.321
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`disclaiming claims 1-10, 13-16, and 19-25 of the ’166 patent. A copy of the
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`statutory disclaimer that was filed is attached hereto as Exhibit 2011. In
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`view of that filing, Patent Owner requests an adverse judgment under 37
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`CFR § 42.73(b)(2) against Patent Owner for claims 1-10, 13-16, and 19-25
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`of the ’166 patent.
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`Accordingly, Patent Owner believes such adverse judgment should be
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`entered and, as there is no remaining claim in this trial, this IPR should be
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`terminated. Patent Owner’s request to file a motion for adverse judgment is
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`therefore forthcoming.
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`1 Petitioners Teletrac Inc., Navman Wireless North America, Ltd., and
`Geotab Inc. have been terminated from this proceeding. See Papers 13 and
`25.
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` Respectfully submitted,
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`By: /s/ Alan L. Whitehurst, Reg. No. 43,263
` Alan L. Whitehurst (Reg. No. 43,263)
`QUINN EMANUEL URQUHART & SULLIVAN,
`LLP
`777 6th St. NW, 11th Floor
`Washington, D.C. 20001
`Tel: (202) 538-8000
`Fax: (202) 538-9100
`Email: alanwhitehurst@quinnemanuel.com
`
`
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` Lead Attorney for Patent Owner –
` PerdiemCo LLC
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`Date: March 2, 2017
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certify that
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`PATENT OWNER’S RESPONSE, and all exhibits and other documents
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`filed together with the Motion, were served on March 2, 2017 by filing these
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`documents through the Patent Review Processing System, as well as by e-
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`
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` Respectfully submitted,
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`By: /s/ Alan L. Whitehurst, Reg. No. 43,263
` Alan L. Whitehurst (Reg. No. 43,263)
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`777 6th St. NW, 11th Floor
`Washington, D.C. 20001
`alanwhitehurst@quinnemanuel.com
`
`
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` Lead Attorney for Patent Owner –
` PerdiemCo LLC
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`mailing copies to:
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`Vivek Ganti
`vg@hkw-law.com
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`perdiemIPR@hkw-law.com
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`Hill, Kertscher, & Wharton, LLP
`3350 Riverwood Pkwy, Suite 800
`Atlanta, GA 30339
`(770) 953-0995
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`Date: March 2, 2017
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