`______________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`THE BOEING COMPANY,
`Petitioner
`
`v.
`
`SEYMOUR LEVINE,
`Patent Owner
`_______________________
`
`Case No. IPR2015-01341
`Patent No. RE39,618
`________________
`
`
`
`PETITIONER’S LIST OF PROPOSED MOTIONS
`
`
`
`
`
`03007-0014/92044875.1
`
`
`
`Case IPR2015-01341
`Attorney Docket No. 03007.0014
`
`The Patent Trial and Appeal Board instituted an IPR trial in case number
`
`IPR2015-01341 on December 21, 2015 (Institution Decision, Paper 10). In
`
`advance of the initial conference call scheduled for Friday, January 15, 2016,
`
`Petitioner The Boeing Company hereby provides a list of the proposed motions
`
`it may file in the above-captioned inter partes review proceeding. Although
`
`motions to exclude evidence and motions for observation on cross examination
`
`have been authorized by the Board in the Scheduling Order (Paper 9 at 3–5),
`
`and motions for pro hac vice admission have been authorized in Notice of
`
`Filing Date Accorded to Petition and Time for Filing Patent Owner Preliminary
`
`Response (Paper 5 at 2), Petitioner identifies its proposed motions here to
`
`preserve the right to file them and to inform the Board of the motions it may
`
`file. Petitioner reserves the right to seek permission to file additional motions
`
`not listed below pursuant to the Board’s authorization.
`
`PETITIONER’S PROPOSED MOTIONS
`
`1. Motions for pro hac vice admission1;
`
`
`1 Petitioner filed motions for pro hac vice admission of Ted Dane and Peter
`
`Gratzinger of the law firm of Munger, Tolles & Olson LLP, along with the
`required updated Power of Attorney. See Papers 13–17. Messrs. Dane and
`Gratzinger represent The Boeing Company in concurrent litigation involving the
`same patent and technology, and they are familiar with the same as a result.
`Petitioner will attempt to confer with counsel for Patent Owner before the initial
`conference call regarding Patent Owner’s potential non-opposition to the
`admission of, and participation in the initial call by Messrs. Dane and Gratzinger.
`
`-1-
`03007-0014/92044875.1
`
`
`
`
`
`2. Motion to submit supplemental information or, in the alternative,
`
`Case IPR2015-01341
`Attorney Docket No. 03007.0014
`
`joinder;
`
`3. Motions to exclude evidence;
`
`4. Motions for observation on cross examination;
`
`5. Motion to request oral argument/hearing;
`
`6. Motions for additional discovery; and
`
`7.
`
`Additional motions as permitted by the Board trial rules and
`
`procedures, or as authorized by the Board.
`
`
`
`DATED: January 13, 2016
`
`
`
`
`
`
`
`
`
`
`
` /Ryan J. McBrayer/
`Ryan J. McBrayer (Reg. No. 54,299)
`Perkins Coie LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101
`
`Attorneys for Petitioner
`The Boeing Company
`
`
`03007-0014/92044875.1
`
`-2-
`
`
`
`
`
`Case IPR2015-01341
`Attorney Docket No. 03007.0014
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the above-captioned PETITIONER
`THE BOEING COMPANY’S LIST OF PROPOSED MOTIONS, was served in
`its entirety on January 13, 2016, upon the following parties via email, pursuant
`to the parties’ agreement concerning service:
`Bruce R. Zisser
`Amar L. Thakur
`Quinn Emanuel Urquhart & Sullivan, LLP
`865 South Figueroa Street, 10th Floor
`Los Angeles, CA 90017
`brucezisser@quinnemanuel.com
`amarthakur@quinnemanuel.com
`Attorneys for Patent Owner Seymour Levine
`
`Dated: January 13, 2016
`
`
`
`
`
` /Ryan J. McBrayer/
`Ryan J. McBrayer (Reg. No. 54,299)
`Perkins Coie LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101
`
`
`
`
`03007-0014/92044875.1
`
`-3-
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