`
`From:
`Sent:
`To:
`
`Cc:
`Subject:
`
`Sean Li
`Tuesday, September 18, 2018 10:01 AM
`'Hotze, Melissa'; 'intel.alacritech.ipr'; 'Constant, Justin'; 'McPherson, Patrick D.'; 'Xue,
`David T.'; 'Khachatourian, Karineh'; 'christopher.douglas@alston.com';
`'kirk.bradley@alston.com'; 'benjamin.weed.PTAB@klgates.com';
`'erik.halverson@klgates.com'
`Alacritech-IPR-Team
`Alacritech m/c regarding motion for additional discovery
`
`Counsel,
`
`During the hearing, Intel on behalf of petitioners asserted, contrary to prior statements and the Board’s order, that Dell
`(and others) is not a real party in interest in Intel’s and Cavium’s IPR petitions vis-à-vis the “readily acknowledged” and
`“of record” indemnification relationship that existed at the time of filing the May 9 – July 3, 2018 IPR petitions. See
`August 23, 2018 Order. As this information is relevant to the subsequently filed IPR2018-00226, -00234, and -00401,
`Alacritech intends to seek leave from the Board to file a motion for additional discovery requesting production of
`documents and information concerning Intel’s and Cavium’s indemnity relationships with Dell, Wistron and CenturyLink.
`
`We write to ask Intel’s, Cavium’s, Dell’s and Wistron’s availability for a conference call with the Board to discuss
`Alacritech’s requested motion for additional discovery in IPR2018-00226, -00234, and -00401.
`
`Please let us know what times you are available this week for a call with the Board.
`
`Regards,
`Ziyong (Sean) Li
`Associate,
`Quinn Emanuel Urquhart & Sullivan, LLP
`
`50 California Street, 22nd Floor
`San Francisco, CA 94111
`415-875-6373 Direct
`415.875.6600 Main Office Number
`415.875.6700 FAX
`seanli@quinnemanuel.com
`www.quinnemanuel.com
`
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`Alacritech Ex. 2405 Page 01
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