`Sent: Thursday, November 02, 2017 3:25 PM
`To: Maebius, Steve; 'Sommer, Andrew R.'; Trials
`Cc: Mathas, Kurt A.; MNutter@winston.com; Quillin, George E.; Shaun Snader; Doug Carsten; Rich Torczon; Bobby Delafield; Veronica
`Ascarrunz
`Subject: RE: IPR Nos. 2017-01621, -01622
`
`Counsel,
`
`In IPR2017-01621 and IPR2017-01622, Petitioner is authorized to file a Reply to Patent Owner’s Preliminary Response to address Patent
`Owner’s argument relating to 35 U.S.C. § 315(b) and its assertion that Ghofrani is not prior art by another. The Reply is limited to 5
`pages and shall be filed no later than November 9, 2017. A conference call is not necessary at this time.
`
`Regards,
`
`Andrew Kellogg,
`Supervisory Paralegal
`Patent Trial and Appeal Board
`USPTO
`andrew.kellogg@uspto.gov
`Direct: 571-272-5366
`
`
`
`From: SMaebius@foley.com [mailto:SMaebius@foley.com]
`Sent: Monday, October 30, 2017 12:01 PM
`To: 'Sommer, Andrew R.' <ASommer@winston.com>; Trials <Trials@USPTO.GOV>
`Cc: Mathas, Kurt A. <KMathas@winston.com>; MNutter@winston.com; GQuillin@foley.com; ssnader@unither.com;
`dcarsten@wsgr.com; rtorczon@wsgr.com; bdelafield@wsgr.com; vascarrunz@wsgr.com
`Subject: RE: IPR Nos. 2017-01621, -01622
`
`Your Honors:
`
`For clarification, Petitioner contacted Patent Owner previously concerning its below request, and Patent Owner indicated that it
`opposes Petitioner’s request.
`
`Sincerely,
`
` Steve Maebius
` Counsel for Patent Owner
` Reg. 35,264
`
`
`From: Sommer, Andrew R. [mailto:ASommer@winston.com]
`Sent: Monday, October 30, 2017 11:33 AM
`To: Trials@USPTO.GOV
`Cc: Mathas, Kurt A.; MNutter@winston.com; Maebius, Steve; Quillin, George E.; Shaun Snader; Doug Carsten; Rich Torczon; Bobby
`Delafield; Veronica Ascarrunz
`Subject: IPR Nos. 2017-01621, -01622
`
`Your Honors:
`
`Petitioner requests authorization to file a reply limited to the following two issues raised in Patent Owner’s Preliminary Response:
`(1) the alleged untimeliness of the petitions; and (2) material inconsistencies between the declarations of Drs. Ghofrani,
`Grimminger and Reichenberger with the evidence of record that should lead to facts being construed in favor of Petitioner at this
`stage of the proceedings under 37 CFR 42.108(c).
`
`UNITED THERAPEUTICS, EX. 2031
`WATSON LABORATORIES V. UNITED THERAPEUTICS, IPR2017-01622
`Page 1 of 2
`
`
`
`
`Counsel for Petitioner and Patent Owner are available today after 3 PM and tomorrow throughout the day for a telephone
`conference should be panel wish to have one.
`
`Best regards,
`
`Andrew R. Sommer
`Counsel for Petitioner
`Reg. No. 53,932
`
`
`
`Andrew R. Sommer
`Partner
`Winston & Strawn LLP
`1700 K Street, N.W.
`Washington, DC 20006-3817
`D: +1 (202) 282-5896
`F: +1 (202) 282-5100
`Bio | VCard | Email | www.winston.com
`
`
`
`
`
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`UNITED THERAPEUTICS, EX. 2031
`WATSON LABORATORIES V. UNITED THERAPEUTICS, IPR2017-01622
`Page 2 of 2
`
`