`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`RED DIAMOND INC.,
`Petitioner
`v.
`
`SOUTHERN VISIONS, LLP,
`Patent Owner.
`
`Case PGR2019-00045
`U.S. Patent No. 10,071,852
`
`PETTIONER’S NOTICE OF DEPOSITION OF JUELENE BECK
`UNDER 37 C.F.R. § 42.53
`
`
`
`Pursuant to 37 C.F.R. § 42.53, Petitioner Red Diamond, Inc. (“Red Diamond”)
`
`hereby provides notice that it will conduct cross-examination by deposition of
`
`Juelene Beck, a witness of Patent Owner, Southern Visions, LLP (“Southern
`
`Visions”). Southern Visions offered Declarations from Ms. Beck in support of its
`
`Preliminary Response (See Exhibit 2001) and in support of its Motion to Amend (See
`
`Exhibit 2027). The deposition will begin on February 5, 2020 at 9 a.m. at the office
`
`of Carver, Darden, Koretzky, Tessier, Finn, Blossman & Areaux LLC, 1100 Poydras
`
`Street, Suite 3100, New Orleans, LA 70163, and will proceed until completed
`
`according to the duration limits specified under 37 C.F.R. § 42.53(c).
`
`In accordance with 37 C.F.R. § 42.53 (d)(1), the parties have conferred and have
`
`agreed upon this date and location for the cross-examination of Ms. Beck.
`
`Southern Visions has also confirmed that it waives any objections to holding the
`
`deposition on February 5 to the extent that objection would be based on the timing
`
`of filing or issuance of this notice.
`
`The cross-examination will be taken before a Notary Public or other officer
`
`authorized by law to administer oaths. The cross-examination will be recorded by
`
`stenographic and/or audio means. It may also be transcribed by real-time reporting
`
`software and recorded by a videographer.
`
`
`
`Date: January 27, 2020
`
`Respectfully submitted,
`
`Seyfarth Shaw LLP
`/Jamaica Potts Szeliga/
`(Reg. No. 67647)
`975 F. St. N.W.
`Washington, DC 20004
`Tel. 202-828-5364
`Fax. 202-641-9212
`Mobile. 703-655-1872
`jszeliga@seyfarth.com
`
`J. M. Robertson, LLC
` /James M. Robertson/
`(Reg. No. 36,905)
`2140 11th Avenue South – Suite 212
`Birmingham, AL 35205
`Tel. 205-212-7620
`Fax. 205-212-7621
`Mobile: 864-621-0454
`jrobertson@jmrpatents.com
`
`Attorneys for Petitioner Red Diamond,
`Inc.
`
`
`
`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on January 27,
`2020, a complete and entire copy of PETITIONER’S NOTICE OF DEPOSITION
`
`OF JUELENE BECK UNDER 37 C.F.R. § 42.53 has been served in its entirety by e-
`
`mail on the following counsel of record for Patent Owner:
`
`Raymond G. Areaux (Lead Counsel)
`areaux@carverdarden.com
`
`J. Matthew Miller III (Back-up Lead Counsel)
`miller@carverdarden.com
`
`Dated: January 27, 2020
`
`/Jamaica Potts Szeliga/
`Jamaica Potts Szeliga (Reg. No. 67,647)
`Attorney for Petitioner
`
`
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