`Sent:
`To:
`Cc:
`
`Subject:
`
`Mike—
`
`Adam LaRock <ALAROCK@skgf.com>
`Thursday, January 04, 2018 1:58 PM
`Houston, Michael R.
`ARG - dymista; McParland, Jim; Meara, Joe; Dennies Varughese; Deborah Sterling; Uma
`Everett; Josh Miller; Tyler Liu
`RE: IPR2017-00807 // Dr. Carr deposition
`
`First, please confirm that you will take Dr. Carr’s deposition in San Diego on Feb. 8.
`
`Second, Dr. D’Addio is not available for deposition on Feb. 2. Instead, he is available on Jan. 25 in DC. Please confirm
`that you will take his deposition in DC on that day. Also, to accommodate your request to depose Dr. D’Addio and Dr.
`Smyth during the same week, Dr. Smyth is available for deposition on Jan. 23. Please confirm that date.
`
`Third, Mr. Jarosz is available for deposition in DC on Feb. 13. Please confirm that you will take his deposition on that day.
`
`As for your request to cross-examine Drs. Malhotra, Govindarajan, Herpin, and a representative from Avomeen, we do
`not intend to offer these individuals for cross-examination. These individuals are not Patent Owner’s declarants in this
`proceeding. The documents from these individuals were cited by Dr. Smyth and Dr. Carr, whom you will have an
`opportunity to cross-examine. Moreover, the documents from Drs. Malhotra, Govindarajan, Herpin, and Avomeen were
`publicly available before Petitioner filed its Petition, and in the case of Dr. Malhotra, were brought into this case by
`Petitioner when it filed the ’620 patent prosecution history. Indeed, Petitioner’s declarant Dr. Donovan also relies on Dr.
`Malhotra’s prosecution declaration. To the extent that Petitioner intends to raise this issue with the Board, Patent
`Owner is available for a Board call on Monday from 1:30-4:30 eastern.
`
`Best regards,
`Adam
`
`Adam LaRock
`Director
`Sterne, Kessler, Goldstein & Fox P.L.L.C.
`Email: alarock@skgf.com
`Direct: 202.772.8794 Main: 202.371.2600
`
`Administrative Assistant: Renee Moore
`Direct Dial: (202) 772.8820
`
`00001
`
`Exhibit 1173
`IPR2017-00807
`ARGENTUM
`
`
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