`Sent: Tuesday, March 23, 2010 11:30 AM
`To: Luke McLeroy
`Cc: Antonelli, Matthew; Ehrlich, Paul
`Subject: RE: VirnetX v. Microsoft
`
`Luke,
`1. We think the calculation should be based on when we received the complaint, which was
` Thursday, March 19. 51 days from that date pushes the deadline to Monday, May 10. Let
` me know if you disagree with that.
`2. Monday at 3:30CT will work. We will plan to review your proposal regarding discovery
` prior to the call. Additionally, we would like to discuss a potential motion to stay the
` litigation pending appeal of the first case and pending re-examination of the patents, as well
` as a potential motion regarding the sufficiency of the complaint.
`____________________
`Daniel Booth
`(713) 546-5135
`daniel.booth@weil.com
`From: Luke McLeroy [mailto:lmcleroy@McKoolSmith.com]
`Sent: Monday, March 22, 2010 3:49 PM
`To: Booth, Daniel
`Cc: Antonelli, Matthew; Ehrlich, Paul
`Subject: RE: VirnetX v. Microsoft
`Thanks for the email. By my count, Microsoft will answer by Friday, May 7, which is
` 51 days from filing. Let me know if that is incorrect.
`Next Monday is ok for me to discuss a discovery schedule. Are you available at 3:30
` pm Texas time? I will send over a proposal this week.
`Thanks, Luke
`
`From: Booth, Daniel [mailto:daniel.booth@weil.com]
`Sent: Monday, March 22, 2010 2:48 PM
`To: Luke McLeroy
`Cc: Antonelli, Matthew; Ehrlich, Paul
`Subject: VirnetX v. Microsoft
`
`Luke,
`Thank you for speaking with me this afternoon regarding the suit that VirnetX filed last week.
`We agree to accept service of the complaint on behalf of Microsoft. Additionally, you have
` agreed to a 30-day extension in the deadline for Microsoft's answer and/or preanswer motions
` (51 total days). We will file the appropriate papers for the extension.
`You also requested that we discuss VirnetX's potential request for an expedited discovery
` schedule. We suggest a call on the afternoon of Monday, March 29 to discuss any proposals
` you may have. It would be helpful to know some details or specific proposals, including any
` asserted need for expedited discovery, so that we can assess them prior to the call.
`Regards,
`_____________________________________________________
`Daniel Booth | Weil, Gotshal & Manges LLP | Associate
`
`Page 1 of 2
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`VIRNETX EXHIBIT 2014
`Microsoft v. VirnetX
`Trial IPR2014-00558
`
`
`
`700 Louisiana, Suite 1600 | Houston, Texas 77002
`(713) 546-5135 | (713) 224-9511 (fax) | daniel.booth@weil.com
`
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`Page 2 of 2
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