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`February 13, 2017
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`One Broadway
`New York, NY 10004-1007
`+1.212.425.7200 Phone
`+1.212.425.5288 Fax
`andrewskurthkenyon.com
`
`Chris Coulson
`+1.212.908.6409 Phone
`ccoulson@kenyon.com
`
`By Email to EDay@perkinscoie.com and Counsel of Record in IPR2016-00448
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`Evan S. Day, Esq.
`Perkins Coie LLP
`11988 El Camino Real, Suite 350
`San Diego, CA 92130-2594
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`
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`Re: Microsoft Corp. v. Bradium Technologies LLC, Inter Partes Review Proceeding
`IPR2016-00448 (United States Patent 7,908,343) and IPR2016-00449 (United
`States Patent 8,924,506) Exhibit 1017
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`Counsel:
`I write on behalf of Bradium Technologies LLC and Mr. Isaac Levanon regarding Exhibit 1017,1
`“Declaration of Yonatan Lavi,” which Petitioner Microsoft publicly filed in Inter Partes Review
`Proceeding IPR2016-00448 (United States Patent 7,908,343) and, following my February 9, 2016
`letter, again filed publicly in IPR2016-00449 (United States Patent 8,924,506).
`
` I
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` renew my request that Microsoft file this exhibit under seal. In addition to confidential
`information that Mr. Lavi obtained via his employment with 3DVU entities, Exhibit 1017 also
`contains DENSO confidential information at Paragraphs 20 and 22. Microsoft has in its
`possession a copy of the DENSO license agreement, which is Exhibit 2029, which was filed under
`seal and served on Microsoft in the IPR proceedings in November 2016.
`
`Also, I have not received a response to the following questions raised in my February 9 letter:
`• Does Perkins Coie LLP represent Mr. Lavi?
`• Will Petitioner Microsoft make Mr. Lavi available for deposition in the United States at
`our New York office at One Broadway, New York, New York, 10004 on March 2, 2017,
`and will Mr. Lavi remain available on March 3 if needed?
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`Also, please confirm, as requested in my February 9 letter, that Perkins Coie LLP and Microsoft
`will retain and not destroy any and all communications, including drafts, exchanged with Mr. Lavi.
`Please also advise whether you have communicated with Mr. Lavi the request to retain all
`documents.
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`1 As you responded to my February 9, 2017 letter directed to Mr. Ng., I direct this letter to you
`for your convenience.
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`ANDREWS KURTH KENYON LLP
`Austin Beijing Dallas Dubai Houston London New York Research Triangle Park Silicon Valley The Woodlands Washington, DC
`NYC:378464.1
`
`Exhibit 2084
`Bradium Technologies LLC - patent owner
`Microsoft Corporation - petitioner
`IPR2016-00448
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`1
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`I would appreciate your response to the above at your earliest convenience.
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`Very truly yours,
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`/s/ Chris J. Coulson
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`Chris J. Coulson
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