`Direct Dial: +1.312.876.7615
`annmarie.wahls@lw.com
`
`
`
`September 22, 2014
`
`VIA EMAIL
`
`
`
`James P. Ulwick
`Kramon & Graham P.A.
`One South Street
`Suite 2600
`Baltimore, Maryland 21202
`julwick@kg-law.com
`
`
`
`330 North Wabash Avenue
`Suite 2800
`Chicago, Illinois 60611
`Tel: +1.312.876.7700 Fax: +1.312.993.9767
`www.lw.com
`
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`
`
`Re:
`
`Paice LLC v. Ford Motor Company, Case No. 14-cv-00492-WDQ
`
`I write to renew Ford’s request that Paice limit the number of claims it presently asserts
`against Ford to a reasonable number. Before this suit, Paice notified Ford that it would assert 5
`patents and over 250 patent claims against Ford. In response, Ford provided invalidity and
`noninfringement defenses to each of these claims. In addition, Paice already has a significant
`amount of information about these claims from its litigations with Toyota and Hyundai. As a
`result, Ford asked Paice to limit the claims at issue in this case to make this litigation more
`efficient, but you declined to do so.
`
`Now, Paice is complaining to the Court about the number of IPRs Ford has filed. As you
`know, Ford must file a large number of IPRs to address over 250 claims. Ford, however, would
`be happy to reduce the number of IPRs if Paice agrees to limit the number of asserted claims.
`Please reconsider whether Paice will limit the number of asserted claims and, in exchange, Ford
`will agree to reduce the number of IPRs.
`
`For example, Ford renews its request that Paice limit the number of claims presently
`asserted to 32 (no more than 10 per patent), and further reduce the number of asserted claims to
`16 (from the initial set of 32 claims and no more than 5 per patent) after it receives Ford’s
`invalidity contentions and document discovery.
`
`Thank you for your consideration of this proposal. We look forward to your response.
`
`
`Best regards,
`
`
`
`Ann Marie Wahls
`
`
`
`
`
`Page 1 of 1
`
`FORD 1204
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