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`From: Leary, Matthew <Matthew.Leary@wilmerhale.com>
`
`Sent: Thursday, May 24, 2018 12:33 PM
`To: Trials <Trials@ USPTO.GOV>
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`Cc: Zac <zac@ahtlawfirm.com>; Matt Antonelli <matt@ahtlawfirm.com>; larrythompson <|arry@ahtlawfirm.com>;
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`jonathan@unifiedpatents.com; Roshan Mansinghani <roshan@unifiedpatents.com>; Cavanaugh, David
`<David.Cavanaugh@wilmerhale.com>; Williams, Daniel V. <Daniel.Williams@wilmerhale.com>; Ryan Pinckney
`
`<ryan@ahtiawfirm.com>
`
`Subject: lPR2017-01430
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`Dear Honorable Board,
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`I write on behalf of petitioner in regard to IPR2017—01430.
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`In its order on supplemental briefing (Paper 16), the Board
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`said that Petitioner’s supplemental reply ”may not raise new arguments or submit new evidence.” Petitioner wishes to
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`clarify that it may present a supplemental expert declaration in support of its supplemental reply, along with
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`corroborating evidence for that declaration. Petitioner also asks that it be allowed to submit new evidence to the same
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`extent such evidence would have been allowed had all the claims been instituted originally (as the SAS ruling said they
`should have been}.
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`Petitioner requests a teleconference with the Board and Patent Owner for the purpose of discussing Petitioner’s
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`requests. Petitioner will supply a court reporter for this conference. Petitioner has conferred with Patent Owner, and
`understands that Patent Owner opposes these requests.
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`Petitioner proposes a call on Friday the 25Th before 12:30ET ifthat works for the Board. Patent Owner represented that
`due to travel, its lead c0unse| would not be available until June 2, and that he didn’t think that "back—up counsel is
`necessary to address Unified’s req uest." The patent owner has not indicated whether backup counsel is available at the
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`day and time proposed above.
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`Respectfully,
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`Matthew]. Leary | WilmerHale
`1225 Seventeenth St.
`Suite 2600
`
`Denver, CO 80202 USA
`
`+1 720 274 3153 (t)
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`+1 720 274 3133 (f)
`
`+1 857 498 1055 (c)
`matthew.lea[y@wilmerhale.com
`
`