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From: Brett Mangrum brett@etheridgelaw.com
`Subject: RE: IPR2018-00884: Dr. Easttom Deposition
`Date: February 7, 2019 at 2:07 PM
`To: Paul Hart paul.hart@eriseip.com, Danny Butts danny@etheridgelaw.com, Ryan Loveless ryan@etheridgelaw.com, Jeff Huang
`jeff@etheridgelaw.com, Jim Etheridge jim@etheridgelaw.com
`Cc: Adam Seitz adam.seitz@eriseip.com
`
`Counsel,
`
`Uniloc cites to Dr. Eas3om’s declara7on solely for the proposi7on that “a POSITA would
`understand that the en7ty intercep7ng a message would not be one of the intended recipients of
`that message. EX2001 ¶¶ 8-9. In other words, a POSITA would understand that the device that is
`intercep7ng a message would be a third party to the intended recipients of that message.”
`
`Under these circumstances, Uniloc believes a cross examina7on of Dr. Eas3om is a waste of the
`par7es’ 7me and resources. If you s7ll disagree, Uniloc would not oppose a mo7on to strike Dr.
`Eas3om’s declara7on.
`
`Regards,
`Bre3
`
`From: Paul Hart <paul.hart@eriseip.com>
`Sent: Tuesday, February 5, 2019 3:07 PM
`To: Danny Bu3s <danny@etheridgelaw.com>; Ryan Loveless <ryan@etheridgelaw.com>; Bre3
`Mangrum <bre3@etheridgelaw.com>; Jeff Huang <jeff@etheridgelaw.com>; Jim Etheridge
`<jim@etheridgelaw.com>
`Cc: Adam Seitz <adam.seitz@eriseip.com>
`Subject: IPR2018-00884: Dr. Eas3om Deposi7on
`
`Counsel,
`
`We would like to schedule Dr. Eas3om’s deposi7on in IPR2018-00884. The week of March 18
`works well on our end. Please let us know if Dr. Eas3om is available any day that week.
`
`Thanks very much.
`
`Best,
`
`PaulPaul Hart | Shareholder
`Erise IP, P.A.
`Suite 200
`Greenwood Village, CO 80111
`(main) 913-777-5600
`(direct) 720-689-5441
`paul.hart@eriseip.com
`(fax) 913-777-5601
`www.eriseip.com
`
`5600 Greenwood Plaza Blvd.
`
`IPR2018-00884
`Apple Inc. EX1012 Page 1
`
`

`

`
`
`Confidentiality Statement
`This email message and any attached files are confidential and are intended solely for the use of the addressee(s) named above. This communication may contain
`material protected by attorney-client, work product, or other privileges. If you are not the intended recipient or person responsible for delivering this
`confidential communication to the intended recipient, you have received this communication in error, and any review, use, dissemination, forwarding, printing, copying,
`or other distribution of this email message and any attached files is strictly prohibited. Erise IP, P.A. reserves the right to monitor any communication that is created,
`received, or sent on its network. If you have received this confidential communication in error, please notify the sender immediately by reply email message and
`permanently delete the original message.
`
`IPR2018-00884
`Apple Inc. EX1012 Page 2
`
`

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