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CASE CBM2013-00013
`Patent 8,037,158
`
`Filed on behalf of Pi-Net International, Inc.
`By: Bryan Boyle
`
`and Lawrence B. Goodwin
`
`Carr&Ferrell LLP
`
`Lawrence B. Goodwin, P.C.
`525 East 86th Street, Suite 5H
`
`120 Constitution Drive
`
`
`Menlo Park, CA 94025
`
`New York, NY 10028
`
`Tel: (650) 812-3400
`
`Tel: (212) 988-1076
`
`Fax: (650) 812-3444
`
`Fax: (646) 619-4161
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`SAP AMERICA, INC.
`Petitioner
`
`v.
`
`PI-NET INTERNATIONAL, INC.
`Patent Owner
`_____________________
`CASE CBM2013-00013
`Patent 8,037,158
`_____________________
`
`MOTION TO EXPUNGE EXHIBITS
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`1
`
`
`
`

`

`CASE CBM2013-00013
`Patent 8,037,158
`
`
`
`
`
`Pursuant to the Board’s email message of February 5, 2014, Patent Owner hereby
`
`requests that the following exhibits, which are no longer being cited or relied upon
`
`by Patent Owner, be expunged from the record in the above-identified case and
`
`from related cases IPR2013-00194 and IPR2013-00195:
`
`
`
`
`
`
`
`
`
`1. Exhibit B (Bardash Report of 11/25/13), referenced in Motions to
`
`Amend in IPR2013-00194 and IPR2013-00195 and which were attached to
`
`said motions as Exhibit B (Paper Nos. 31 and 26, respectively);
`
`2. Pi-Net Exhibit 1008 (Answering Brief from Delaware litigation)
`
`referenced in Patent Owner's Response in IPR2013-00195;
`
`3. Pi-Net Exhibit 1009 (Bardash Report of 4/1/13) referenced in
`
`Responses in IPR2013-00194 and IPR2013-00195; and
`
`4. Pi-Net Exhibits 1010, 1012, and 2017 (Easttom Report of 4/1/13)
`
`referenced in the Responses in IPR2013-00194, IPR2013-00195,
`
`and CBM2013-00013, respectively.
`
`2
`
`

`

`
`
`CASE CBM2013-00013
`Patent 8,037,158
`
`Respectfully submitted,
`
`LAWRENCE B. GOODWIN, P.C.
`
`
`
`Lawrence B. Goodwin
`Registration No. 29642
`
`CARR&FERRELL LLP
`
`Bryan Boyle
`Registration No. 52644
`Attorneys for Patent Owner
`
`
`
`
`
`
`
`
`
`Date: February 6, 2014
`525 East 86th Street, Suite 5H
`New York, NY 10028
`Tel: (212) 988-1076
`
`120 Constitution Drive
`Menlo Park, CA 94025
`650.812.3400
`
`
`
`
`
`
`
`
`
`
`
`
`3
`
`

`

`CASE CBM2013-00013
`Patent 8,037,158
`
`CERTIFICATION OF SERVICE
`
`The undersigned hereby certifies that the above-captioned “Motion to Expunge
`
`Exhibits” in CBM2013-00013 for Covered Business Method Patent Review of
`
`U.S. Patent No. 8,037,158, was served on February 6, 2014, upon the following
`
`Lori A. Gordon and Michael Q. Lee
`STERNE, KESSLER, GOLDSTEIN
`& FOX, P.L.L.C.
`3999 West Chester Pike
`Washington, DC 20005
`Attorneys for Petitioner
`
`
`
`CARR & FERRELL, LLP
`
`
`
`
`
`/Bryan Boyle/
`Bryan Boyle
`Registration No. 52644
`Attorney for Patent Owner
`
`
`
`
`
`parties via email:
`
`
`
`
`SAP America, Inc
`
`
`
`Attn: Samir Pandya
`
`
`VP and General Counsel
`
`
`1100 New York Avenue, NW
`
`
`Newtown Square, PA 19073
`Petitioner’s correspondence address
`Of record at the USPTO BOARD
`
`
`
`
`
`
`
`Date: February 6, 2014
`120 Constitution Drive
`Menlo Park, CA 94025
`650.812.3400
`bboyle@carrferrell.com
`
`
`
`
`
`
`
`
`
`
`4
`
`

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