From:
`To:
`Cc:
`Subject:
`Date:
`
`Brian Mack
`Trials
`"intel.alacritech.ipr@weil.com"; Stephens, Garland; Hotze, Melissa; Alacritech-IPR-Team
`IPR2017-01409, -01391, -01406 - Motions to Correct
`Friday, May 11, 2018 11:59:42 AM
`
`Your Honors,
`
`Patent Owner, Alacritech Inc., respectfully requests permission to file motions to correct its
`Contingent Motions to Amend in the above captioned petitions. In particular, certain typographical
`and other errors were discovered in the exhibits to these motions as follows:
`
`
`· Case IPR2017-01409, Paper 20 – The citations for proposed substitute claim 61 in Exhibit A
`were inadvertently copied from another case and not updated to correctly identify the
`written description support. The correct citations were provided in Exhibit A of Case
`IPR2017-01410, which relates to the same patent and includes corresponding claim
`language and amendments. PO would like to copy the citations from Exhibit A in Case
`IPR2017-01410 into the corresponding limitations of Exhibit A in Case IPR2017-01410.
`· Case IPR2017-01391, Paper 21 – Exhibit C (the claim listing) includes misnumbered
`dependencies and an incorrect column heading due to clerical errors. The claim numbers
`are correct in Exhibits A and B, and petitioner has already responded to the contingent
`motion as if the errors had been corrected.
`· Case IPR2017-01406, Paper 25 – PO inadvertently omitted an “and” before “a media access
`control (MAC) layer address…” in proposed substitute claim 36. Exhibit A also has a
`typographical error in an Exhibit number. Petitioner has already responded to the
`contingent motion as if the error had been corrected.
`
`
`PO can provide redlines showing the proposed corrections upon the Board’s request.
`
`The parties have met and conferred. Petitioner, Intel Corp., does not oppose the motions to correct
`in Cases IPR2017-01391 and IPR2017-01406. Petitioner does oppose the motion to correct in Case
`IPR2017-01409.
`
`The parties are available for a conference call next week on Wednesday, May 16, from 10 – 12 AM
`CT (8 – 10 AM PT), 1:30 – 3 PM CT (11:30 AM – 1 PM PT), 4 – 6 PM CT (2 – 4 PM PT), or at the
`Board’s convenience.
`
`Best regards,
`Brian
`
`Brian E. Mack | Partner | Quinn Emanuel Urquhart & Sullivan, LLP | 50 California Street, 22nd
`Floor, San Francisco, CA 94111 | Office: +1.415.875.6423
`
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