`To:
`Cc:
`Subject:
`Date:
`
`Kala Sarvaiya
`Giunta, Rich; Steve Sereboff
`Hunt, Elisabeth
`RE: Case Nos 2015-01750, 2015-01751, 2015-01752 [A213-L15F15]
`Wednesday, September 16, 2015 7:29:18 PM
`
`Rich,
`
`We agree to abide by the terms of the protective order for the treatment of any confidential
` information disclosed during the call with the Board.
`
`Regards,
`Kala Sarvaiya
`SoCal IP Law Group LLP
`310 N. Westlake Blvd., Ste. 120
`Westlake Village, CA 91362
`Phone (805) 230-1350 x330
`Fax (805) 230-1355
`ksarvaiya@socalip.com
`www.socalip.com
`
`From: Rich Giunta [mailto:Rich.Giunta@WolfGreenfield.com]
`Sent: Wednesday, September 16, 2015 2:17 PM
`To: Steve Sereboff <SSereboff@socalip.com>
`Cc: Kala Sarvaiya <KSarvaiya@socalip.com>; Elisabeth H. Hunt
` <Elisabeth.Hunt@WolfGreenfield.com>
`Subject: RE: Case Nos 2015-01750, 2015-01751, 2015-01752
`
`Steve,
`
`Attached is the standing protective order and the standard acknowledgement from the Trial
` Practice Guide. Please review and let us know that if you will agree to abide by the terms of
` the protective order for the treatment of any confidential information disclosed during the call
` with the Board.
`
`Thanks,
`Rich
`
`From: Steve Sereboff [mailto:SSereboff@socalip.com]
`Sent: Wednesday, September 16, 2015 1:55 PM
`To: Giunta, Rich
`Cc: Kala Sarvaiya; Hunt, Elisabeth
`Subject: Re: Case Nos 2015-01750, 2015-01751, 2015-01752
`
`Rich, great idea. Please send it over. /steve/
`
`On Sep 16, 2015, at 9:13 AM, Rich Giunta <Rich.Giunta@WolfGreenfield.com> wrote:
`
`Steve,
`
`
`Page 1 of 2
`
`
`
`Would you be amenable to signing the Board’s standard protective order in
` advance of your requested call? If the Board has any questions that relate to
` confidential information it might make the call more productive if we have a
` protective order in place in advance.
`
`Please let us know.
`
`Thanks,
`Rich
`
`From: Steve Sereboff [mailto:SSereboff@socalip.com]
`Sent: Monday, September 14, 2015 4:35 PM
`To: Trials@uspto.gov
`Cc: Kala Sarvaiya; Giunta, Rich; Hunt, Elisabeth
`Subject: Case Nos 2015-01750, 2015-01751, 2015-01752
`
`We are counsel to the patent owner in the three identified IPRs. The three petitions were
` filed 8-17-2015. We would like a conference call with the Board for permission to move for
` additional discovery in these three cases on the issue of real party in interest. We have
` asked the petitioner, RPX Corp, to cooperate in providing additional discovery. After
` reviewing our proposed document requests, Petitioner refused to cooperate. Thus, patent
` owner would like to file a motion for permission to serve the document requests and to
` receive a response on an expedited basis.
`
`Counsel for patent owner and petiioner are available September 16 from 2:30-6 pm and on
` September 18 at any time.
`
`Respectfully,
`
`/Steven C. Sereboff/
`ph +1 (805) 230-1356
`mobile +1 (805) 279-0074
`SoCal IP Law Group LLP
`www.socalip.com
`310 N. Westlake Blvd., Suite 120, Westlake Village, CA 91362
`1332 Anacapa St., Suite 201, Santa Barbara, CA 93101
`ssereboff@socalip.com
`
`
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