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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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`LKQ Corporation and Keystone Automotive Industries, Inc.,
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`Petitioner,
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`v.
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`GM Global Technology Operations, LLC,
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`Patent Owner.
`____________
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`Case No. IPR2020-00065
`Patent No. D813,120
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`_____________________________________________________
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`PETITIONER’S MOTION TO CORRECT CERTAIN CLERICAL OR
`TYPOGRAPHICAL ERRORS IN PETITION
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`Petitioner’s Motion to Correct Certain Clerical or
`Typographical Errors in Petition in IPR 2020-00065
`U.S. Patent No. D813,120
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`During review of its filings, Petitioner recognized that its petition contained
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`certain non-substantive clerical or typographical errors. Petitioner promptly
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`informed Patent Owner of the errors, its desire to move for correction, and the
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`substance of the corrections. Patent Owner confirmed that it would not oppose the
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`instant motion to file a corrected petition. Granting this motion will not prejudice
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`Patent Owner because Patent Owner is already aware of the substance of the
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`corrections, does not oppose the instant motion, and would have almost its full three
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`month period to submit any preliminary response, as Patent Owner was informed of
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`the error and proposed corrections on the same day the Notice of Filing was accorded
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`on November 13, 2019.
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`Petitioner respectfully requests that the following errors be corrected:
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`1. Page 15, line 16: “vehicle front bumper” should be amended to read
`“vehicle hood.”
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`2. Page 16, line 1: “vehicle front bumper” should be amended to read “vehicle
`hood.”
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`3. Page 42, line 2: “vehicle front bumpers” should be amended to read
`“vehicle hoods.”
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`4. Page 42, line 4: “vehicle front bumpers” should be amended to read
`“vehicle hoods.”
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`Petitioner thus respectfully moves pursuant to 37 C.F.R. 42.104(c) to file
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`errata to the petition that resolves the aforementioned clerical or typographical
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`2
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`Petitioner’s Motion to Correct Certain Clerical or
`Typographical Errors in Petition in IPR 2020-00065
`U.S. Patent No. D813,120
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`errors, as authorized by the Patent Trial and Appeal Board in correspondence dated
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`December 26, 2019.
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`Dated: December 30, 2019
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`Respectfully submitted,
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`/Barry F. Irwin, P.C./ _
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`Barry F. Irwin, P.C.
`Irwin IP LLC
`222 South Riverside Plaza
`Suite 2350
`Chicago, Illinois 60606
`Phone: 312.667.6080
`birwin@irwinip.com
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`3
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`Petitioner’s Motion to Correct Certain Clerical or
`Typographical Errors in Petition in IPR 2020-00065
`U.S. Patent No. D813,120
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`
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing Petitioner’s
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`Motion to Correct Certain Clerical or Typographical Errors in Petition has been
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`caused to be served on December 30, 2019, via electronic mail upon the following
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`attorneys of record for the Patent Owner at the below-listed addresses:
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`Dorothy P. Whelan
`Craig A. Deutsch
`Grace J. Kim
`FISH & RICHARDSON P.C.
`whelan@fr.com
`deutsch@fr.com
`gkim@fr.com
`IPR45343-0015IP1@fr.com
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`/Barry F. Irwin, P.C./ _
`Lead Counsel for Petitioner
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