`Patent 6,850,414
`Attorney Docket No. 160831-002USIPR
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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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`KINGSTON TECHNOLOGY COMPANY INC.,
`Petitioner,
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`v.
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`POLARIS INNOVATIONS LTD.,
`Patent Owner.
`____________
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`Case IPR2016-01622
`Patent 6,850,414 B2
`____________
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`PATENT OWNER POLARIS INNOVATIONS LTD.’S
`NOTICE OF PROPOSED MOTIONS
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`Case IPR2016-01622
`Patent 6,850,414
`Attorney Docket No. 160831-002USIPR
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`An initial conference call is scheduled for March 15, 2017, at 2:00 PM (ET).
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`See Scheduling Order (Paper 8) at 6. Pursuant to the Office Patent Trial Practice
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`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.
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`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.
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`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
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`(“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
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`file any motions, Patent Owner requests authorization to submit an opposition.
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`//
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`//
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`1
`Polaris Innovations Ltd.’s Notice of Proposed Motions
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`Case IPR2016-01622
`Patent 6,850,414
`Attorney Docket No. 160831-002USIPR
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`Respectfully submitted,
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` /
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` Kenneth J. Weatherwax /
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`Kenneth J. Weatherwax, Reg. No. 54,528
`Lowenstein & Weatherwax LLP
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`Date: March 13, 2017
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`2
`Polaris Innovations Ltd.’s Notice of Proposed Motions
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`Case IPR2016-01622
`Patent 6,850,414
`Attorney Docket No. 160831-002USIPR
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that the following documents were served
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`on the date stated below by electronic service by agreement between the parties:
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`PATENT OWNER POLARIS INNOVATIONS, LTD’S
`NOTICE OF PROPOSED MOTIONS
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`The names and address of the parties being served are as follows:
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`IPR37307-0007IP1@fr.com (David Hoffman)
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`IPR@sjclawpc.com (Martha Hopkins)
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`Respectfully submitted,
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` /
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` Shawn Chi /
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`Date: March 13, 2017
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