`
`From:
`
`Sent:
`To:
`Cc:
`
`Subject:
`
`Vignone, Maria <Maria.Vignone@USPTO.GOV> on behalf of Trials
`<Trials@USPTO.GOV>
`Tuesday, April 05, 2016 3:51 PM
`Emsley, Rachel; Trials
`Lori Gordon; Rob Sokohl; Jon Strang; Richard M. Bemben; Trading-Tech-CBM; tt-
`patent-cbm@tradingtechnologies.com; PTAB Account; PTAB Account
`RE: CBM2015-00179; CBM2015-00182; and CBM2015-00181: Requesting Conference
`with Board
`
`Counsel,
`
`No conference call is necessary. The Patent Owner may include such arguments in its Patent Owner
`Response. Therefore, the request to file a separate motion on this issue is dismissed as moot since the issue may be
`addressed in the PO Response.
`
`Thank you,
`
`Maria Vignone
`Paralegal Operations Manager
`Patent Trial and Appeal Board
`703‐756‐1288
`
`
`
`From: Emsley, Rachel [mailto:Rachel.Emsley@finnegan.com]
`Sent: Tuesday, April 05, 2016 1:46 PM
`To: Trials <Trials@USPTO.GOV>
`Cc: Lori Gordon (LGORDON@skgf.com) <LGORDON@skgf.com>; Rob Sokohl <RSOKOHL@skgf.com>; Jon Strang
`(JSTRANG@skgf.com) <JSTRANG@skgf.com>; rbemben@skgf.com; Trading‐Tech‐CBM <Trading‐Tech‐
`CBM@finnegan.com>; tt‐patent‐cbm@tradingtechnologies.com; PTAB@skgf.com
`Subject: CBM2015‐00179; CBM2015‐00182; and CBM2015‐00181: Requesting Conference with Board
`
`Your Honors,
`
`
`Patent Owners have requested to depose Mr. Kawashima, whose prior testimony Petitioners submitted (Ex. 1007) to
`allege that the TSE reference is prior art. See, e.g., CBM2015‐00179, Paper 9 at 21‐22. In response to Patent Owner’s
`request, Petitioners have represented to Patent Owners that they have “reached out to TSE and Mr. Kawashima . . . and
`re‐confirmed that he is unwilling to come to the United States for a deposition.” Accordingly, Patent Owners would like
`to request authorization for a motion to dismiss grounds relying on the TSE reference from the above‐referenced
`proceedings. Counsel for Petitioners has indicated that Petitioners would oppose such a motion. Counsel for both
`Petitioners and Patent Owners are available for a telephone conference on Thursday from 10 AM until 1:30 PM.
`
`
`Thank you,
`Rachel Emsley
`Counsel for Patent Owner, Trading Technologies
`
`
`Rachel L. Emsley
`Attorney at Law
`
`1
`
`IBG 1039
`IBG v. Trading Technologies
`CBM2015-00181
`
`
`
`Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
`Two Seaport Lane
`Boston, MA 02210-2001
`617.646.1624 | fax: 202.408.4400 | rachel.emsley@finnegan.com | www.finnegan.com
`
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`2