`U.S. Patent No. RE39,618
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`Filed on behalf of Seymour Levine
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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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`THE BOEING COMPANY.
`Petitioner,
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`v.
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`SEYMOUR LEVINE
`Patent Owner
`________________
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`Case IPR2015-01341
`U.S. Patent No. RE39,618
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`PATENT OWNER’S LIST OF PROPOSED MOTIONS
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`Case IPR2015-01341
`U.S. Patent No. RE39,618
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`The Patent Trial and Appeal Board instituted an IPR trial in case number IPR2015-01341
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`on December 21, 2015 (Institution Decision, Paper 10). In advance of the initial conference call
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`scheduled for Friday, January 15, 2016, Patent Owner Seymour Levine hereby provides a list of
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`the proposed motions it may file in the above-captioned inter partes review proceeding.
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`Although motions for pro hac vice admission have been authorized in Notice of Filing Date
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`Accorded to Petition and Time for Filing Patent Owner Preliminary Response (Paper 5 at 2),
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`Patent Owner identifies its proposed motions here to preserve the right to file them and to inform
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`the Board of the motions it may file. Patent Owner reserves the right to seek permission to file
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`additional motions not listed below pursuant to the Board’s authorization.
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`PATENT OWNER’S PROPOSED MOTIONS
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`1. Motions for pro hac vice admission;
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`2. Motions for observation on cross examination;
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`3. Motion to request oral argument/hearing;
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`4. Motions for additional discovery; and
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`///
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`///
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`1
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`5. Additional motions as permitted by the Board trial rules and procedures, or as
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`Case IPR2015-01341
`U.S. Patent No. RE39,618
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`authorized by the Board.
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`Date: January 13, 2016
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` Respectfully submitted,
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`By: /Bruce R. Zisser, Reg. No. 40,884/
` Bruce R. Zisser, Reg. No. 40,884
`QUINN EMANUEL URQUHART &
`SULLIVAN LLP
`865 S. Figueroa St., 10th Floor
`Los Angeles, CA 90017
`General Tel: (213) 443-3000
`Direct Tel: (213) 443-3434
`Fax: (213) 443-3100
`Email: brucezisser@quinnemanuel.com
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`Attorneys for Patent Owner –
`Seymour Levine
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`2
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`Case IPR2015-01341
`U.S. Patent No. RE39,618
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the foregoing PATENT OWNER’S LIST OF
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`PROPOSED MOTIONS was served electronically via e-mail on January 13, 2016, in its
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`entirety on the following:
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`Ryan J. McBrayer (Reg. No. 54,299)
`Perkins Coie LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101
`RMcBrayer@perkinscoie.com
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`Chun M. Ng
`Perkins Coie LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101
`CNg@perkinscoie.com
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` Respectfully submitted,
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`By: /Bruce R. Zisser, Reg. No. 40,884/
` Bruce R. Zisser, Reg. No. 40,884
`Lead Attorney for Patent Owner
`QUINN EMANUEL URQUHART &
`SULLIVAN LLP
`865 S. Figueroa St., 10th Floor
`Los Angeles, CA 90017
`General Tel: (213) 443-3000
`Direct Tel: (213) 443-3434
`Fax: (213) 443-3100
`Email: brucezisser@quinnemanuel.com
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`Attorney for Patent Owner –
`Seymour Levine
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`3
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`Date: January 13, 2016