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`June 2, 2015
`
`VIA ECF
`
`The Honorable Paul S. Grewal
`United States Magistrate Judge
`USDC Northern District of California
`San Jose Courthouse
`280 South 1st Street
`San Jose, Ca 95113
`
`RE: Boundary Solutions Inc. v. CoreLogic, Inc., No. 5:14-cv-00761-PSG (N.D. Cal.)
`
`Dear Judge Grewal:
`
`This letter provides Plaintiff Boundary Solutions, Inc.’s (“BSI”) response to the letter of June 1,
`2015 from Sid Venkatesan.
`
`Mr. Venkatesan requests that the Court rule on two pending CoreLogic motions before staying
`the case pending inter partes review.
`
`BSI agrees that the Court should rule on the motion regarding the Prosecution Bar in the
`Protective Order if it wishes to give further guidance on that matter. Counsel for BSI has
`unequivocally already committed not to participate in the amending of claims during the IPR.
`Boundary Solutions Inc.’s Opposition to CoreLogic, Inc.’s Motion to Exclude BSI Litigation
`Counsel from Participating In Inter Partes Review and for Entry of Protective Order, dated
`March 6, 2015 (Dkt. No. 92) (“BSI’s counsel further assured that the firm … will not be
`involved in ‘strategically amending or surrendering claim scope’ in any way that can be
`influenced by CoreLogic’s confidential information”). Nothing has changed since then: BSI’s
`litigation counsel will not participate in any efforts by BSI to amend or surrender claim scope
`during the IPRs.
`
`BSI objects to the second portion of CoreLogic’s request. The Parties stipulated to a Stay of
`
`CoreLogic Exhibit 1028
`CoreLogic, Inc. v. Boundary Solutions, Inc.
`Trial IPR2015-00228
`
`Page 1 of 2
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`Proceedings Pending Inter Partes Review. They have filed a stipulation that asks the court for
`such a stay. Now, CoreLogic seeks to back out of the deal and continue the litigation in this
`court and, possibly the appeals court, by having its pending Motion for Judgment on the
`Pleadings decided. BSI was never informed of this proposed one-sided carve out from the agreed
`upon stay. Thus, BSI opposes such an asymmetric stay.
`
`BSI does not see any purpose for the convening of a case management conference at this point in
`the case. Such a conference will simply invite the parties to reargue the motions that have
`already been submitted to the Court. If the Court wishes to hold a conference, the parties should
`be directed to file a Case Management Conference Statement in advance of the conference.
`
`Sincerely,
`
`Bruce J. Wecker
`Of Counsel
`
`Page 2 of 2
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