`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`
`
`Under Armour, Inc.,
`Petitioner,
`
`v.
`
`adidas AG,
`Patent Owner
`
`———————
`
`Case No. IPR2015-00698
`
`Patent No. 8,092,345
`______________________________________________________________
`
`PETITIONER’S LIST OF PROPOSED MOTIONS
`
`
`
`
`
`
`
`
`
`
`Petitioner Under Armour, Inc. submits the following list of proposed
`
`motions that that it may file, as circumstances warrant, during this trial.
`
`Petitioner’s proposed motions are as follows:
`
`1. Motion to submit supplemental information under 37 C.F.R. § 42.123
`
`(if necessary).
`
`2. Motion to seal and/or for a protective order regarding confidential
`
`information pursuant to 37 C.F.R. §§ 42.14, 42.54, and 42.55 (if
`
`necessary).
`
`3. Motion to exclude evidence pursuant to 37 C.F.R. § 42.64(c) (if
`
`necessary).
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`4. Motion to expunge evidence (if necessary).
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`5. Motion for discovery or additional discovery pursuant to 37 C.F.R. §
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`42.51 (if necessary).
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`6.
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`Request for an oral hearing pursuant to 37 C.F.R. § 42.70(a).
`
`This list is provided without prejudice to Petitioner’s right to seek
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`authorization to file additional motions or to elect not to file the motions listed.1
`
`
`1 “Submission of a list [of proposed motions] would not preclude the filing of
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`additional motions not contained in the list.”
`
`
`
`
`
`1
`
`
`
`Respectfully submitted,
`
`
`
`/s/ Brian Ferguson
`Brian E. Ferguson
`Lead Counsel for Petitioner
`Registration No. 36,801
`Weil, Gotshal & Manges LLP
`1300 Eye Street NW, Suite 900
`Washington, DC 20005
`Phone: 202-682-7516
`brian.ferguson@weil.com
`
`
`2
`
`
`
`Dated: September 10, 2015
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned hereby certifies that on September 10, 2015, the foregoing
`
`PETITIONER’S LIST OF PROPOSED MOTIONS was served via electronic
`
`mail, upon the following:
`
`Mitchell G. Stockwell
`Kilpatrick Townsend & Stockton LLP
`1100 Peachtree Street NE, Suite 2800
`Atlanta, GA 30309-4528
`mstockwell@kilpatricktownsend.com
`
`Wab P. Kadaba
`Kilpatrick Townsend & Stockton LLP
`1100 Peachtree Street NE, Suite 2800
`Atlanta, GA 30309-4528
`wkadaba@kilpatricktownsend.com
`
`
`
`
`
`
`
`/s/ Brian Ferguson
`Brian E. Ferguson
`Lead Counsel for Petitioner
`Registration No. 36,801
`Weil, Gotshal & Manges LLP
`1300 Eye Street NW, Suite 900
`Washington, DC 20005
`Phone: 202-682-7516
`brian.ferguson@weil.com
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