`
`From:
`Sent:
`To:
`Subject:
`
`Hi Evan,
`
`Yoni Lavi
`Monday, February 20, 2017 12:22 PM
`Day, Evan S. (SDO)
`Re: Bradium Technologies, LLC v Microsoft
`
`I was going to contact FB legal dept first, but then I considered again what makes me so anxious about it and
`realized it is not really the process of going through a deposition, but rather that I simply don't want to cause
`these people to have a personal vendetta against me. To be brief, I've moved on with my life, and would like to
`keep it that way. I hope it makes it clear now; I will participate in the legal process itself only if compelled to do
`so.
`
`I'm sorry I can't cooperate any further in this.
`I hope your case goes well, anyway.
`
`Regards,
`Yoni
`
`On Mon, Feb 20, 2017 at 7:44 PM, Day, Evan S. (Perkins Coie) <EDay@perkinscoie.com> wrote:
`
`Yoni,
`
`I would like to follow up on our conversation last week. If you have had a chance to speak with independent counsel
`about this matter, we would also be happy to talk to them directly or speak to both of you at your preference. Please let
`me know when you (and/or your counsel) are available to discuss further. Again, we really appreciate all of your help on
`this matter.
`
`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
`
`1
`
`Microsoft, Ex. 1036
`Microsoft v. Bradium, IPR2016-01897
`
`
`
`From: Day, Evan S. (SDO)
`Sent: Tuesday, February 14, 2017 3:59 PM
`To:
`Cc: Bernstein, Matthew C. (SDO)
`Subject: RE: Bradium Technologies, LLC v Microsoft
`
`Yoni,
`
`Thank you for speaking to me this evening. I understand your concerns about the possibility of being deposed in this
`matter. As I stated over the phone, Microsoft stands behind its previous agreement (per Matt’s attached letter dated
`September 13, 2016) to pay for your defense and any damages in the unlikely event that Mr. Levanon attempts to sue you
`for providing truthful testimony in a declaration or deposition. Additionally, if you require your own independent counsel to
`advise you regarding a deposition, Microsoft is willing to pay for or reimburse you for the cost of that counsel. Please let
`us know if there is anything else that we can do to help.
`
`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: Day, Evan S. (SDO)
`Sent: Thursday, February 09, 2017 8:51 PM
`To:
`Cc: Bernstein, Matthew C. (SDO)
`Subject: Bradium Technologies, LLC v Microsoft
`
`Yoni,
`
`Here’s an update on where things stand with the Bradium litigation. We filed the declaration that you provided us in the
`case (actually two of them, for different patents) in the Patent and Trademark Office this week. After we filed the
`declaration, Bradium contacted us to request to take your deposition. As you may recall from when we discussed this
`case in person, the general procedure for this type of patent office case is that if we submit a declaration (like yours), the
`
`2
`
`Microsoft, Ex. 1036
`Microsoft v. Bradium, IPR2016-01897
`
`
`
`opposing party gets an opportunity to take a deposition if they request one, or the patent office will not consider the
`declaration. For this very reason, we took Isaac Levanon’s deposition a few weeks ago.
`
`Regarding the location of the deposition, if you are willing to come to the United States (to New York or Washington, DC
`or someplace convenient for you), we would pay to fly you out and put you up in a hotel. That would be most ideal for us,
`but we can also push to have the deposition take place in Tel Aviv (and potentially on a weekend or after business hours
`to minimize the disruption to your work schedule).
`
`With that in mind, we’d like to discuss the issue with you by phone or videoconference at your earliest convenience. One
`or both of us can be available any time over the next few days, whenever it works for you.
`
`Also, I believe we discussed this earlier, but please retain any documents or correspondence relating to this case,
`including emails.
`
`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
`
`NOTICE: This communication may contain privileged or other confidential information. If you have received it in error, please advise the sender by reply email and
`immediately delete the message and any attachments without copying or disclosing the contents. Thank you.
`
`3
`
`Microsoft, Ex. 1036
`Microsoft v. Bradium, IPR2016-01897
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
