`Sent: Friday, February 24, 2017 4:46 PM
`To: Trials <Trials@USPTO.GOV>; 'nhefazi@irell.com' <nhefazi@irell.com>; justin.cohen@tklaw.com;
`hoffmann@reising.com; Frank A. Angileri <fangileri@brookskushman.com>; Thomas A. Lewry
`<tlewry@brookskushman.com>; Marc Lorelli <mlorelli@brookskushman.com>; hoffmann@reising.com;
`japowers@duanemorris.com; cjtyson@duanemorris.com
`Subject: RE: IPR2016‐01389, 01391, 01397, 01399; IPR2017‐00718, 00719, 00720, 00790
`
`IPR2017‐00718, 00719, 00720, 00790
`
`Dear Ms. Vignone,
`
`The parties have now met and conferred regarding Petitioners’ motions to join IPR2017‐00718, 00719, 00720, 00790
`(Petitioners’ IPRs) with IPR2016‐01389, 01391, 01397, 01399 (Juniper IPRs), and have agreed to the following.
`
`1. Patent Owner, Chrimar Systems, Inc., agrees to waive its right to file preliminary responses in IPR2017‐00718,
`00719, 00720 and 00790.
`
`2. Petitioners confirm that they will maintain an “understudy” role in IPR2017‐00718, 00719, 00720 and 00790 so
`long as the Juniper IPRs are maintained, and will not file additional briefs or seek additional depositions beyond
`the briefs and depositions submitted/taken by Juniper. While Petitioners do not envision any differences in
`position with Juniper nor the need to file any separate briefs, Petitioners reserve the right to request to file an
`addendum (of 5 pages or less) to Juniper briefs, should the need arise. And of course, Petitions would agree
`that Patent Owner should have a corresponding number of additional pages for its responsive briefing limited to
`the issues raised in Petitioners’ addendum, as necessary. Patent Owner reserves the right to object to any
`addendums filed by Petitioners, which in combination with any of Juniper’s briefs, would exceed the total word
`count allowed by the PTAB briefing rules.
`
`3. The parties jointly propose that any joined IPRs are to be subject to the same schedules adopted in the
`corresponding Juniper IPRs.
`
`If the Board believes that a call would be helpful, the Parties have the following availability early next week:
`February 27th (4:00 PM EST) and March 1st (1‐3 PM EST). Thank you.
`
`Regards,
`
`Christopher C. Smith (Attorney for the Patent Owner)
`Shareholder
`
`1
`
`
`
`1000 Town Center, 22nd Floor | Southfield, MI 48075
`Direct: (248) 226‐2780 | Main: (248) 358‐4400
`csmith@BrooksKushman.com | Bio
`www.BrooksKushman.com | www.BKpostgrant.com
`
`IMPORTANT/CONFIDENTIAL: This message may be privileged, confidential, or exempt from disclosure under applicable
`law. If you have received this communication in error, please notify us immediately by return e‐mail.
`
`From: Vignone, Maria [mailto:Maria.Vignone@USPTO.GOV] On Behalf Of Trials
`Sent: Wednesday, February 22, 2017 3:54 PM
`To: 'nhefazi@irell.com' <nhefazi@irell.com>; justin.cohen@tklaw.com; hoffmann@reising.com; Frank A. Angileri
`<fangileri@brookskushman.com>; Thomas A. Lewry <tlewry@brookskushman.com>; Marc Lorelli
`<mlorelli@brookskushman.com>; Christopher C. Smith <csmith@brookskushman.com>; hoffmann@reising.com;
`japowers@duanemorris.com; cjtyson@duanemorris.com
`Subject: IPR2016‐01389, 01391, 01397, 01399; IPR2017‐00718, 00719, 00720, 00790
`
`Counsel,
`
`Petitioner in IPR2017‐00718, 00719, 00720, 00790 filed motions requesting joinder with IPR2016‐01389, 01391, 01397,
`01399. Patent Owner recently filed a response indicating that it does not oppose the motions for joinder. The panel
`requests that the parties submit a joint email indicating whether Patent Owner will agree to waive its preliminary
`response in IPR2017‐00718, 00719, 00720, 00790, or, alternatively, whether Patent Owner will agree to file its
`preliminary response in those cases by March 22, 2017, or earlier. The panel also requests that the parties meet and
`confer by February 24, 2017, and provide several dates and times at the beginning of next week when they are available
`for a conference call to discuss the motions for joinder.
`
`Thank you,
`
`Maria Vignone
`Paralegal Operations Manager
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`703‐756‐1288
`
`2
`
`
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