`Patent 6,850,414
`Attorney Docket No. 160831-002USIPR
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`KINGSTON TECHNOLOGY COMPANY INC.,
`Petitioner,
`
`v.
`
`POLARIS INNOVATIONS LTD.,
`Patent Owner.
`____________
`
`Case IPR2016-01622
`Patent 6,850,414 B2
`____________
`
`PATENT OWNER POLARIS INNOVATIONS LTD.’S
`NOTICE OF PROPOSED MOTIONS
`
`
`
`
`
`
`
`
`
`
`
`
`
`Case IPR2016-01622
`Patent 6,850,414
`Attorney Docket No. 160831-002USIPR
`
`
`
`An initial conference call is scheduled for March 15, 2017, at 2:00 PM (ET).
`
`
`
`See Scheduling Order (Paper 8) at 6. Pursuant to the Office Patent Trial Practice
`
`Guide, 77 Fed. Reg. 48756, 66 (Aug. 14, 2012), Patent Owner Polaris Innovations
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`Ltd. hereby submits the following list of proposed motions.
`
`Motion to Amend the Patent (37 C.F.R. § 42.121). As authorized in the
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`Scheduling Order (Paper 8) at 5, Patent Owner plans to file a motion to amend.
`
`Consistent with the Board’s practice and 37 C.F.R. § 42.121, a conference call will
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`be made to the Board to confer regarding the proposed motion to amend and the
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`specific amendments contemplated before filing the motion.
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`Although Patent Owner does not presently expect to file additional motions,
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`it reserves the right to seek subsequent authorization for motions consistent with
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`the Board’s Rules. See Office Patent Trial Practice Guide, 77 Fed. Reg. at 48765
`
`(“Submission of a list would not preclude the filing of additional motions not
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`contained in the list.”); eBay, Inc. v. MoneyCat Ltd., CBM2014-00091 et al., Paper
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`21, at 4 (P.T.A.B. Nov. 12, 2014). To the extent the Board authorizes Petitioner to
`
`file any motions, Patent Owner requests authorization to submit an opposition.
`
`//
`
`//
`
`
`
`1
`Polaris Innovations Ltd.’s Notice of Proposed Motions
`
`
`
`Case IPR2016-01622
`Patent 6,850,414
`Attorney Docket No. 160831-002USIPR
`
`
`Respectfully submitted,
`
` /
`
` Kenneth J. Weatherwax /
`
`
`Kenneth J. Weatherwax, Reg. No. 54,528
`Lowenstein & Weatherwax LLP
`
`
`
`
`Date: March 13, 2017
`
`2
`Polaris Innovations Ltd.’s Notice of Proposed Motions
`
`
`
`Case IPR2016-01622
`Patent 6,850,414
`Attorney Docket No. 160831-002USIPR
`
`
`
`
`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that the following documents were served
`
`on the date stated below by electronic service by agreement between the parties:
`
`
`PATENT OWNER POLARIS INNOVATIONS, LTD’S
`NOTICE OF PROPOSED MOTIONS
`
`
`
`The names and address of the parties being served are as follows:
`
`IPR37307-0007IP1@fr.com (David Hoffman)
`
`IPR@sjclawpc.com (Martha Hopkins)
`
`
`Respectfully submitted,
`
` /
`
` Shawn Chi /
`
`
`
`
`
`
`
`Date: March 13, 2017
`
`
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