From:
`To:
`
`Cc:
`Subject:
`Date:
`
`Day, Evan S. (SDO)
`Coulson, Chris; Bright, Meghan (SDO); Ng, Chun (SEA); Bernstein, Matthew C. (SDO); Sathe, Vinay (SDO);
`McKeever, Patrick J. (SDO); *Perkins-Service-MSFT-Bradium-IPR
`Zachary, Michael; Ulrich, Clifford
`RE: Microsoft Corp. v. Bradium Tech. // IPR2016-00448 - Correspondence
`Thursday, February 09, 2017 8:44:33 PM
`
`Counsel,
`
`We have received your correspondence today regarding Ex. 1017, and will respond to the issues raised
`in your letter in a reasonable time. However, with respect to your request that Microsoft “immediately
`request that Exhibit 1017 be sealed and that the public version of the declaration be expunged,” this
`request, as made by you, is not reasonable. Obviously we are willing to work with you and are willing to
`consider sealing the declaration if you actually identify specific confidential information contained in the
`declaration. Claiming that 10-18 year old information is confidential, without providing any reasons or
`justification, simply is not reasonable—especially given that Mr. Lavi’s declaration for the most part
`mirrors topics discussed by Mr. Levanon which he and Bradium claim is public, as well as subject matter
`that the named inventors have discussed in materials made publicly available at the PTO on several
`occasions and which Bradium itself has made publicly available in this proceeding. See, e.g. Exs. 2019,
`2020. Therefore, please identify the specific paragraphs (or portions thereof) that you claim contain
`confidential information and the bases therefore, including any agreements upon which your
`confidentiality assertions are based (with English translations if they are not in English).
`
`Moreover, you state that Mr. Lavi’s declaration reveals “confidential corporate information regarding which
`we understand Mr. Lavi is subject to confidentiality obligations based on his employment with
`GACentral.com, 3DVU, Ltd., and 3DVU, Inc.,” not Bradium. As far as we know, your office does not
`represent any entities in this IPR other than Bradium. Neither you nor your firm have entered an
`appearance on behalf of any of these entities in this IPR or any other proceeding. Also, to the best that
`our research has been able to determine, these entities are no longer operational or in good standing
`legally. The information that we have received through the Delaware litigation also gives no indication
`that the assignment of the asserted patents to Bradium conveyed any standing to enforce previous
`confidentiality agreements on behalf of other entities. Please unequivocally state whether your firm
`represents GACentral.com, 3DVU, Ltd., or 3DVU, Inc., whether you are willing to accept service on their
`behalf moving forward, and whether these entities legally still exist.
`
`Again, we are willing to consider your request and work with you if you provide the requested information.
` 
`Best regards,
`Evan
`
`Evan Day | Perkins Coie LLP
`11988 El Camino Real Suite 350
`San Diego, CA 92130-2594
`D. +1.858.720.5743
`F. +1.858.720.5799
`E. EDay@perkinscoie.com
`
`From: Coulson, Chris [mailto:CCoulson@kenyon.com]
`Sent: Thursday, February 09, 2017 2:38 PM
`To: Bright, Meghan (SDO); Ng, Chun (SEA); Bernstein, Matthew C. (SDO); Sathe, Vinay (SDO);
`McKeever, Patrick J. (SDO); Day, Evan S. (SDO); *Perkins-Service-MSFT-Bradium-IPR
`Cc: Zachary, Michael; Ulrich, Clifford
`Subject: RE: Microsoft Corp. v. Bradium Tech. // IPR2016-00448 - Correspondence
` 
`Counsel,
` 
`Please see the attached correspondence.
`
`Microsoft, Ex. 1040
`Microsoft v. Bradium, IPR2016-00449
`
`

`

`  
`
`Best regards,
` 
`Chris Coulson
`ANDREWS KURTH KENYON LLP
`Tel: 212.908.6409
` 
`From: Bright, Meghan (Perkins Coie) [mailto:MBright@perkinscoie.com]
`Sent: Monday, February 06, 2017 9:39 PM
`To: Coulson, Chris; Zachary, Michael; Ulrich, Clifford; ~~Bradium v. Microsoft
`Cc: Ng, Chun (Perkins Coie); Bernstein, Matthew C. (Perkins Coie); Sathe, Vinay (Perkins Coie);
`McKeever, Patrick J. (Perkins Coie); Day, Evan S. (Perkins Coie);
`PerkinsServiceBradiumIPR@perkinscoie.com
`Subject: Microsoft Corp. v. Bradium Tech. // IPR2016-00448 - U.S. Patent No. 7,908,343 // Service of
`Petitioner’s Reply and Related Exhibits
` 
`Re: Inter Partes Review Case No. IPR2016-00448
`Microsoft Corporation v. Bradium Technologies LLC
`U.S. Patent No. 7,908,343
`
`Counsel:
`
`Attached please find service copies of the following documents filed at the PTAB on February 6, 2017
`regarding inter partes review Case No. IPR2016-00448:
`
`
`§ Petitioner’s Reply to Patent Owner’s Response
`§ Exhibits 1014-1020, 1022-1031 (to follow via LeapFile Transfer)
`
`
`Regards,
` 
`Meghan Bright | Perkins Coie LLP
`PARALEGAL
`11988 El Camino Real Suite 350
`San Diego, CA 92130-2594
`D. +1.858.720.5746
`E. MBright@perkinscoie.com
`
` 
`
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`
`Microsoft, Ex. 1040
`Microsoft v. Bradium, IPR2016-00449
`
`