`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`VEEAM SOFTWARE CORPORATION
`Petitioner,
`
`v.
`
`SYMANTEC CORPORATION
`Patent Owner
`________________
`
`Case IPR2013-00150
`U.S. Patent No. 7,093,086
`
`PATENT OWNER’S LIST OF PROPOSED MOTIONS
`
`In advance of the initial conference call scheduled for September 9, 2013,
`
`Patent Owner Symantec Corporation hereby provides a list of the proposed
`
`motions it presently intends to file in the above-captioned inter partes review
`
`proceeding.
`
`Patent Owner’s List of Proposed Motions
`
`1.
`
`A possible motion to amend the claims of U.S. Patent No. 7,093,086
`
`pursuant to 37 C.F.R. § 42.121(a);
`
`
`
`2.
`
`A motion to exclude evidence pursuant to 37 C.F.R. § 42.64(c) based
`
`on the grounds set forth in Patent Owner’s Objections to Petitioner’s Evidence
`
`Pursuant to 37 C.F.R. § 42.64(b)(1); and
`
`3.
`
`A motion for observations on cross-examination pursuant to 37 C.F.R.
`
`§ 42.20(a) if warranted based on testimony.
`
`In addition, Symantec hereby advises the Board of the currently pending
`
`Patent Owner’s Request for Rehearing Pursuant to 37 C.F.R. §42.71(c) for Partial
`
`Reconsideration of its Decision to Institute Trial, filed on August 21, 2013.
`
`
`
`Date: September 5, 2013
`
`Respectfully submitted,
`
`By: /Joseph J. Richetti, Reg. No. 47024/
`Joseph J. Richetti
`Reg. No. 47,024
`Lawrence G. Kurland
`Reg. No. 24,895
`BRYAN CAVE LLP
`1290 Avenue of the Americas
`New York, NY 10104
`General Tel: (212) 541-2000
`Direct Tel: (212) 541-1092
`Fax: (212) 541-4630
`Email: joe.richetti@bryancave.com
`
`Daniel A. Crowe, Reg. No. 39,644
`BRYAN CAVE LLP
`One Metropolitan Square
`211 N. Broadway, Suite 3600
`St. Louis, Missouri 63102
`Tele. (314) 259-2619
`dacrowe@bryancave.com
`
`Attorneys for Patent Owner – Symantec
`Corporation
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the foregoing PATENT OWNER’S
`
`LIST OF PROPOSED MOTIONS was served electronically via e-mail on
`
`September 5, 2013, in its entirety on the following:
`
`Lori A. Gordon
`STERNE, KESSLER, GOLDSTEIN
`& FOX P.L.L.C
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3932
`lgordon-PTAB@skgf.com
`
`Michael Q. Lee
`STERNE, KESSLER, GOLDSTEIN
`& FOX P.L.L.C
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3932
`mlee-PTAB@skgf.com
`
`Respectfully submitted,
`
`By: /Joseph J. Richetti, Reg. No. 47024/
`Joseph J. Richetti
`Lead Attorney for Patent Owner
`Reg. No. 47,024
`BRYAN CAVE LLP
`1290 Avenue of the Americas
`New York, NY 10104
`General Tel: (212) 541-2000
`Direct Tel: (212) 541-1092
`Fax: (212) 541-4630
`Email: joe.richetti@bryancave.com
`
`Attorneys for Patent Owner – Symantec
`Corporation
`
`Date: September 5, 2013
`
`2
`
`
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