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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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`PANASONIC SYSTEM NETWORKS CO., LTD.
`Petitioner
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`v.
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`6115187 CANADA INC.
`Patent Owner
`____________
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`Case IPR 2014-01438
`U.S. Patent No. 6,844,990
`____________
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`RESPONSE TO NOTICE OF FILING DATE ACCORDED TO PETITION
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`TIME FOR FILING PATENT OWNER PRELIMINARY RESPONSE
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`AND
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`Mail Stop PATENT BOARD, PTAB
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`RESPONSE TO NOTICE OF FILING DATE ACCORDED TO PETITION
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`TIME FOR FILING PATENT OWNER PRELIMINARY RESPONSE
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`AND
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`In response to the Notice of Filing Date Accorded to Petition and Time for
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`Filing Patent Owner Preliminary Response mailed September 11, 2014 (Paper No.
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`3), Petitioner submits concurrently herewith an amended petition addressing the
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`noted defects (“Amended Petition”) and respectfully submits the following
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`statement and comments:
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`Claim Charts
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`In the Amended Petition, as discussed with Cathy Underwood during a
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`September 15, 2014 telephone call, Petitioner has revised the Claim Charts to
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`remove reference to a POSA by deleting portions of the Claim Charts (at pages 28,
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`29, 42 and 45 of the originally filed petition). Accordingly, the defects in the Claim
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`Charts have been corrected in the manner discussed during the telephone call, and
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`no substantive changes have been made to the petition.
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`1
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`Authorization is hereby provided to charge any fee necessary for entry of
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`this paper to Deposit Account No. 19-0089.
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`Respectfully submitted,
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`/Arnold Turk/
`_______________________
`Arnold Turk
`Registration No. 33,094
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, VA 20191
`Tel: (703) 716-1191
`Fax: (703) 716-1180
`Email: ATurk@gbpatent.com
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`Attorneys for Petitioner,
`Panasonic System Networks Co., Ltd.
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`Dated: September 16, 2014
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`/Michael J. Fink/
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`_______________________
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`Michael J. Fink
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`
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`Registration No. 31,827
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
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`Reston, VA 20191
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`Tel: (703) 716-1191
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`Fax: (703) 716-1180
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`Email: MFink@gbpatent.com
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`CERTIFICATE OF SERVICE
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`I hereby certify that the attached Response to Notice of Filing Date Accorded to
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`Petition and Time for Filing Patent Owner Preliminary Response was served as of the
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`below date by Federal Express on the Patent Owner at the correspondence address
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`indicated for U.S. Patent No. 6,844,990:
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`Panitch Schwarze Belisario & Nadel LLP
`One Commerce Square
`2005 Market Street, Suite 2200
`Philadelphia PA 19103.
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`Additionally, I hereby certify that the attached Response to Notice of Filing
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`Date Accorded to Petition and Time for Filing Patent Owner Preliminary Response
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`was served as of the below date by Federal Express on the following:
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`6115187 Canada Inc.
`100, Alexis-Nihon, Suite 540
`Saint Laurent, Quebec, Canada H4m 2p1
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`and
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`Pascale Nini
`President and Chief Executive Officer
`ImmerVision
`2020 University St., Suite 2320,
`Montreal, Quebec, Canada H3A 2A5.
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`Dated: September 16, 2014
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`/Arnold Turk/
`_______________________
`Arnold Turk
`Registration No. 33,094
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`3
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