`Sent: Monday, May 14, 2018 9:49 PM
`To: Trials <Trials@USPTO.GOV>
`Cc: kayvan@noroozipc.com; william@noroozipc.com; Eliot.Williams@BakerBotts.com; michelle.eber@b
`akerbotts.com; andrew.wilson@BakerBotts.com
`Subject: IPR2017-00557 - Request for Conference Call
`
`
`Dear Your Honors,
`
`In accordance with the Board’s Order of May 7, 2018 (Paper 29) modifying the “institution decision
`to institute on all of the grounds presented in the Petition,” the Parties hereby notify the Board that
`they request a conference call with the panel.
`
`
`Petitioner’s Position - Petitioner believes that additional briefing is warranted to address the
`newly instituted grounds. Moreover, in accordance with the typical PTAB briefing process, and
`because Petitioner bears the burden, Petitioner respectfully maintains that Petitioner’s brief should
`be filed last. To the extent that the Board grants permission to file additional briefing, Petitioner
`proposes the following schedule:
`1 – Patent Owner will file a 5-page brief within 7 days of the Board’s Order granting authority for
`supplemental briefing; and
`2 – Petitioner will file a 5-page brief within 7 days of Patent Owner’s brief in #1 above.
`
`
`Patent Owner’s Position - Patent Owner does not believe Petitioner preserved the right to further
`briefing in light of SAS. Accordingly, no further briefing should be granted. Patent Owner believes
`the Board's non-institution decision and its POR address why the additional five grounds cannot
`prevail. However, to the extent further briefing is granted, Patent Owner requests that the briefing
`be limited to 5 pages per side, with no new arguments or evidence (including no new expert
`declarations). In addition, since Petitioner bears the burden, its briefing should come first, with
`Patent Owner's response coming within 7 days thereafter.
`
`
`The Parties are both available:
` Tuesday (5/15) at noon-3PM Eastern
` Monday (5/21) at 1PM-3PM Eastern and 4PM-6PM Eastern
`
`
`If those times are not available, the Parties can provide the Board with additional times that they
`are available.
`
`
`Best regards,
`Jamie
`
`
`Jamie R. Lynn
`
`
`Baker Botts L.L.P.
`jamie.lynn@bakerbotts.com
`T +1.202.639.7786
`M +1.202.285.5284
`F +1.202.585.1026
`
`
`1299 Pennsylvania Ave. NW
`Washington, DC 20004
`
`
`
`USA
`
`
`
`
`Confidentiality Notice:
`
`The information contained in this e mail a nd a ny attachments is intended only for the re cipient[s] listed above and
`m a y be privileged and confidential. Any dissemination, copying, or use of or re liance upon such information by or
`to a nyone other than the re cipient[s] listed above is prohibited. If you have re ceived this message in e rror, please
`notify the sender immediately at the email address a bove a nd destroy a ny a nd a ll copies of this message.
`
`
`
`
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