In Google Inc. v. Arendi S.A.R.L., IPR2014-00452, Paper 16 (October 27, 2014), the Board advised the patent owner on addressing dependent claims when an independent claim is amended.  The Board advised the patent owner that that it could propose substitute dependent claims that include the same limitations as the original dependent claims 2–79 but depend from proposed substitute new independent claim, and that if these claims are the same as the original claims except that they depend from a proposed substitute independent claim, the patent owner can list the proposed substitute dependent claims in a claims appendix, which would not count toward the fifteen page limit for motions to amend.