`Sent: Friday, December 1, 2017 2:22 PM
`To: 'Trials' <Trials@USPTO.GOV>
`Cc: Jacob, Beth <BJacob@KelleyDrye.com>; Ari J. Jaffess <Ari.Jaffess@LBKMLAW.com>; Ernest Buff
`<ebuff@edbuff.com>; M. Michael Lewis <MICHAEL.LEWIS@LBKMLAW.com>; Minsk, Alan
`<MinskA@LanePowell.com>; 'Yovits, Steven' <SYovits@KelleyDrye.com>; David G. Liston
`<David.Liston@LBKMLAW.com>; 'O'Brien, Kevin M' <Kevin.O'Brien@bakermckenzie.com>; Brian Bodine
`<brianbodine@msn.com>; Scola, Adriane <ScolaA@LanePowell.com>;
`'richard.wells@bakermckenzie.com' <richard.wells@bakermckenzie.com>;
`'duodecad_WAG@bakermckenzie.com' <duodecad_WAG@bakermckenzie.com>; Scott, Mark
`<MaScott@KelleyDrye.com>
`Subject: IPR2016-01656 and -01658 | Request for Conference Cal
`
`To the Honorable Board,
`
`
`Patent Owner respectfully requests a conference call at the Board’s earliest convenience to seek leave
`for the following:
`
`
`1. To file a written opposition to Petitioner’s request made on November 29, 2017 for leave to
`move to withdraw the Petitions.
`
`2. To move to require Petitioner to respond to discovery with respect to the items that the Board
`identified at page 7 of the transcript of the conference call held on November 3, 2017, including
`“who has been directing the proceedings, who participated in preparing the petition, who has
`been funding it, how it has been funded, are the same lawyers involved, who the Petitioner's
`counsel is in this case taking direction from.”
`
`3. To renew its request (initially made May 10, 2017) for leave to file a motion to terminate the
`above-referenced proceedings in both IPR2016-01656 and -01658 as time-barred under 35
`U.S.C. Sec. 315(b), which termination would be operative with respect to all petitioners
`(including both the original petitioner and the petitioners that subsequently joined in the
`IPR2016-01658 proceeding via joinder).
`
`
`
`Respectfully submitted,
`
`
`Ronald Abramson
`Attorney for Patent Owner, WAG Acquisition, L.L.C.
`
`
`
`
`
`EXHIBIT 3001, 1
`
`
`
`
`
`Ronald Abramson
`
`
`Lewis Baach Kaufmann Middlemiss PLLC
`
`
`The Chrysler Building
`405 Lexington Avenue
`62nd Floor
`New York, New York 10174
`t 212 822-0163
`c 646 648-0388
`Bio | Email | Website | vCard
`
`This communication is confidential and may contain privileged information. If you have received this communication in error,
`please delete it and advise the sender by reply e-mail. Thank you.
`
`
`
`
`
`
`EXHIBIT 3001, 2
`
`
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