Vakili, Kamran
`From:
`Sent:
`To:
`Cc:
`
`Subject:
`
`Counsel,
`
`Baghdassarian, Mark <MBaghdassarian@KRAMERLEVIN.com>
`Thursday, March 19, 2020 1:42 PM
`Vakili, Kamran; Caplan, Jonathan S.; ~Hedvat, Shannon; ~Rovner, Phil; ~Choa, Jonathan
`Yorks, Ben; McPhie, David; Federico, Alexis; Michael J. Farnan
`(mfarnan@farnanlaw.com); Brian E. Farnan (bfarnan@farnanlaw.com)
`RE: Fraunhofer v. Sirius XM - Source Code Review
`
`It seems you have misunderstood the concerns we raised earlier this week regarding the situation at our firm
`with respect to Covid-19. Earlier in March, our firm adopted a policy based on then-available information
`regarding permitting visitors to the firm. In accordance with that policy, Mr. Price promptly sent you the e-mail
`on March 11. However, as the concerns surrounding Covid-19 have increased, our firm's policy and approach,
`similar to what we have seen from federal, state and local authorities, has evolved and changed. As we
`discussed during our call on Tuesday, our firm, similar to a number of other firms and organizations, adopted a
`work from home policy and we will not be able to host Fraunhofer's expert for the source code review at our
`offices based on our current no visitor policy. In fact, Mr. Price's e-mail specifically stated in his March 11 e-
`mail that we would provide you with “any updated policy” which I did in my e-mail from Monday. We also
`believe we clearly communicated this during our call on Tuesday.
`
`Thank you.
`-Mark
`
`Mark Baghdassarian
`Partner
`
`Kramer Levin Naftalis & Frankel LLP
`1177 Avenue of the Americas, New York, New York 10036
`T 212.715.9193 F 212.715.8362
`mbaghdassarian@kramerlevin.com
`
`Bio
`
`This communication (including any attachments) is intended solely for the recipient(s) named above and may contain information that is
`confidential, privileged or legally protected. Any unauthorized use or dissemination of this communication is strictly prohibited. If you have received
`this communication in error, please immediately notify the sender by return e-mail message and delete all copies of the original communication.
`Thank you for your cooperation.
`
`From: Vakili, Kamran [KVakili@irell.com]
`Sent: Thursday, March 19, 2020 12:43 AM
`To: Caplan, Jonathan S.; Baghdassarian, Mark; Hedvat, Shannon H.; provner@potteranderson.com; ~Choa, Jonathan
`Cc: Yorks, Ben; McPhie, David; Federico, Alexis; Michael J. Farnan (mfarnan@farnanlaw.com); Brian E. Farnan
`(bfarnan@farnanlaw.com)
`Subject: [EXTERNAL] Fraunhofer v. Sirius XM - Source Code Review
`
`Counsel,
`
`1
`
`Fraunhofer Ex 2056-p 1
`Sirius v Fraunhofer
`IPR2018-00690
`
`

`

`In response to the concerns you recently raised about Fraunhofer’s review of SXM’s source code scheduled for March
`25-27, we note that the March 11, 2020 correspondence from Jeffrey Price in connection with related IPR2018-00690
`(concerning asserted patent 6,314,289) explained that Kramer Levin’s official policy for office visitors requires responses
`to the following screening questions:
`
`•
`•
`
`•
`
`•
`
`If you, or anyone in your household has been diagnosed with the COVID-19 virus.
`If you, or anyone in your household has come into known contact with anyone who has the COVID-19 virus, or
`who is suspected of having the COVID-19;
`If you, or anyone in your household has traveled to a Level 2 or higher country as determined by the CDC
`including, China, North Korea, South Korea, Iran, Italy, Pakistan, Mongolia, or Japan in the past 21 days; and/or
`If you, or anyone in your household are experiencing any flu-like symptoms, including fever, cough, or shortness
`of breath.
`
`Having discussed these questions with our expert, Dr. Dhananjay (who is local in NYC), we can confirm that none of the
`above apply to him. Accordingly, we trust that he should be able to visit your office for the code review on March 25-27
`as planned. Please confirm as soon as possible so we can let Dr. Dhananjay know for planning purposes.
`
`Regards,
`Kamran
`
`Kamran Vakili, Ph.D
`Irell & Manella LLP | kvakili@irell.com | www.irell.com
`840 Newport Center Drive, Suite 400, Newport Beach, CA 92660
`Direct: (949) 760-5151
`
`This message and its contents are intended only for the person or entity to which it is addressed. It may contain
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`
`PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside
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`replying to this message and then delete it from your system. Thank you.
`
`2
`
`Fraunhofer Ex 2056-p 2
`Sirius v Fraunhofer
`IPR2018-00690
`
`