`
`Daniel B. Ravicher <dan@ravicher.com>
`To: Dorothy Whelan <whelan@fr.com>
`Cc: Michael Kane <kane@fr.com>, Chad Shear <shear@fr.com>, "David.Cavanaugh@wilmerhale.com"
`<David.Cavanaugh@wilmerhale.com>, "emily.whelan@wilmerhale.com" <emily.whelan@wilmerhale.com>, PTAB Inbound
`<PTABlnbound@fr.com>, IPR36583-0020IP6 <IPR36583-0020IP6@fr.com>
`
`Fri, Jun 15, 2018 at 5:53 PM
`
`Please provide me days and times next week when you are available for a call with the board. Please also be advised
`that Petitioner believes Patent Owner's failure to provide material information regarding the patentability of its claims may
`be a violation of its duty candor and good faith to the board.
`
`On Fri, Jun 15, 2018, 5:46 PM Dorothy Whelan <whelan@fr.com> wrote:
`
`Counsel:
`
`Your petition has been denied . Your request is inappropriate.
`
`Regards,
`
`Dorothy P. Whelan
`
`Counsel for Patent Owner.
`
`From: Daniel B. Ravicher [mailto:dan@ravicher.com]
`Sent: Thursday, June 14, 2018 7:14 PM
`To: Dorothy Whelan <whelan@fr.com>; Michael Kane <kane@fr.com>; Chad Shear <shear@fr.com>;
`David.Cavanaugh@wilmerhale.com; emily.whelan@wilmerhale.com; PTAB Inbound
`<PTABlnbound@fr.com>; IPR36583-0020IP6 <IPR36583-0020IP6@fr.com>
`Subject: IPR2018-00123
`
`Counsel,
`
`I write to ask Patent Owner to stipulate that Sofia et al., Poster #P-259, presented at the 14th lnt'I Symposium on
`Hepatitis C Virus and Related Viruses, Glasgow, Scotland, UK, Sept. 9- 13, 2007 (Ex. 1012), was published on Patent
`Owner's predecessor's investor.pharmasset.com website on September 10, 2007, as documented by the attached
`Wayback Machine captures.
`
`If Patent Owner will not so stipulate, Petitioner intends to seek leave from the Board for additional discovery from
`Patent Owner regarding the date that the Sofia Poster was published. Should that be necessary, which I hope it is not,
`please let me know days and times next week that you are available for a call with the Board regarding such a motion.
`Thank you.
`
`IPR2018-00123
`
`Page 1 of 2
`
`I-MAK 1016
`
`
`
`Sincerely,
`
`Daniel B. Ravicher, Esq.
`
`Ravicher Law Firm PLLC
`
`2000 Ponce De Leon Blvd, Ste 600
`Coral Gables, Florida 33134
`dan@ravicher.com 786.505.1205
`
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`confidential and privileged information. Any unauthorized use or disclosure is prohibited. If
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`IPR2018-00123
`
`Page 2 of 2
`
`I-MAK 1016
`
`