`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`PRICELINE.COM LLC AND BOOKING.COM B.V.,
`Petitioner
`
`v.
`
`DDR HOLDINGS, LLC,
`Patent Owner
`
`
`
`Case IPR2019-00438
`Patent 9,639,876
`
`
`
`
`DDR’S WAIVER OF PATENT OWNER’S PRELIMINARY RESPONSE
`
`
`
`
`
`
`Page 2
`
`Case No. IPR2019-00438
`
`Patent 9,639,876
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`Given the Board’s institution of a related proceeding (IPR2018-01011)
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`brought by Shopify, Inc., and based on the representations by Petitioner
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`(Priceline.com LLC and Booking.com B.V.) that (1) Petitioner has chosen to
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`decline to raise any grounds of invalidity beyond those in the corresponding
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`Shopify IPR, (2) Petitioner agrees to an understudy role and will present no other
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`filings or oral arguments beyond Shopify’s unless Shopify withdraws, and (3) as a
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`result Patent Owner will not need to respond to any additional papers or
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`arguments, Patent Owner hereby waives its Patent Owner Preliminary Response
`
`pursuant to 37 CFR 42.107(b) and consents to Petitioner’s Motion for Joinder.
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`Nevertheless, Patent Owner maintains that the petitions do not show that the patent
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`is invalid, for the reasons given in the response to the Shopify petition, and
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`reserves the right to maintain such arguments in the consolidated proceeding.
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`Dated: April 11, 2019
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
` /Louis J. Hoffman/
`Louis J. Hoffman
`Reg. No. 38,918
`
`LOUIS J. HOFFMAN, P.C.
`7689 East Paradise Lane
`Suite 2
`Scottsdale, Arizona 85260
`(480) 948-3295
`Lead Counsel for Patent Owner
`
`
`
`Page 3
`
`Case No. IPR2019-00438
`
`Patent 9,639,876
`
`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e)(1))
`
`The undersigned hereby certifies that on April 11, 2019, a complete and
`
`correct copy of the foregoing document was served via electronic mail on the
`
`following counsel of record for Petitioner:
`
`
`
`Nathan Rees (Reg. No. 63,820)
`Allan Braxdale (Reg. No. 64,276)
`R. Ross Viguet (Reg. No. 42,203)
`Brett C. Govett (Reg. No. 45,492)
`NORTON ROSE FULBRIGHT US LLP
`2200 Ross Avenue, Suite 3600
`Dallas, Texas 75201-2784
`Email: DDR_IPR_Service@nortonrosefulbright.com
`
`
` /Louis J. Hoffman/
`Louis J. Hoffman, Reg. No. 38,918
`LOUIS J. HOFFMAN, P.C.
`7689 East Paradise Lane
`Suite 2
`Scottsdale, Arizona 85260
`Louis@valuablepatents.com
`
`
`
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