From: Paul Hart paul.hart@eriseip.com
`Subject: Re: IPR2018-00884: Dr. Easttom Deposition
`Date: February 28, 2019 at 8:43 AM
`To: Brett Mangrum brett@etheridgelaw.com
`Cc: Danny Butts danny@etheridgelaw.com, Ryan Loveless ryan@etheridgelaw.com, Jeff Huang jeff@etheridgelaw.com,
`Jim Etheridge jim@etheridgelaw.com, Adam Seitz adam.seitz@eriseip.com
`
`Brett,
`Given the Court’s ruling (attached) that striking Easttom’s declaration is premature prior to the expiration of our discovery period, we
`wanted to follow up with you all on next steps. To the extent that you are maintaining your prior position, please confirm that (1) you
`will not provide Dr. Easttom for cross examination and (2) you will not oppose a motion to strike his declaration and any references or
`citations thereto following the close of our discovery period. Otherwise, please provide dates of availability for Dr. Easttom so
`Petitioner can take his deposition in advance of our Reply.
`Best,
`
`PaulP"#$ H"'( | S+"',+-$.,'
`E'01, IP, P.A.
`Suite 200
`Greenwood Village, CO 80111
`(main) 913-777-5600
`(direct) 720-689-5441
`(fax) 913-777-5601
`paul.hart@eriseip.com
`www.eriseip.com
`
`5600 Greenwood Plaza Blvd.
`
`Order denying
`motion…ec.pdf
`
`On Feb 21, 2019, at 9:44 AM, Paul Hart <paul.hart@eriseip.com> wrote:
`Brett,
`Here’s what we intend to send the Board by COB this afternoon:
`>>>
`In IPR2018‐00884, Petitioner Apple respectfully requests permission to file an Unopposed Motion to Strike under 37 CFR 42.5(a)
`and 42.20(a). Specifically, the Petitioner seeks to strike the Easttom Declaration (Exhibit 2001) and all references or citations to the
`declaration in any filing as an alternative to making the declarant available for cross‐examination. Petitioner and Patent Owner have
`conferred, and Patent Owner indicates that they do not oppose the motion.
`If needed, Petitioner and Patent Owner are available for a Board call on Monday or Tuesday next week (2/25 or 2/26) between
`11:00am and 3pm EDT.
`
`>>>P"#$ H"'( | S+"',+-$.,'
`E'01, IP, P.A.
`Suite 200
`Greenwood Village, CO 80111
`(main) 913-777-5600
`(direct) 720-689-5441
`(fax) 913-777-5601
`paul.hart@eriseip.com
`www.eriseip.com
`
`5600 Greenwood Plaza Blvd.
`
`IPR2018-00884
`Apple Inc. EX1014 Page 1
`
`

`

`On Feb 21, 2019, at 7:00 AM, Brett Mangrum <brett@etheridgelaw.com> wrote:
`
`Paul,
`
`Please provide us a dra8 copy of the email you intend to send to the Board. While we do not
`believe a call with the Board is necessary, we can make ourselves available either Monday or
`Tuesday of next week from 10am to 2pm (CST).
`
`Regards,
`BreM
`
`From: Paul Hart <paul.hart@eriseip.com>
`Sent: Wednesday, February 20, 2019 11:52 AM
`To: BreM Mangrum <breM@etheridgelaw.com>
`Cc: Danny BuMs <danny@etheridgelaw.com>; Ryan Loveless <ryan@etheridgelaw.com>; Jeff
`Huang <jeff@etheridgelaw.com>; Jim Etheridge <jim@etheridgelaw.com>; Adam Seitz
`<adam.seitz@eriseip.com>
`Subject: Re: IPR2018-00884: Dr. EasMom Deposiaon
`
`Counsel,
`
`We’ve had a chance to confer with our client, and we agree that an unopposed moaon to
`strike Dr. EasMom’s declaraaon and any references or citaaons thereto is an acceptable
`alternaave to cross examinaaon. We’ll reach out to the Board to request permission for the
`filing. To the extent they would like to convene a conference call to discuss, what’s your
`availability next week? We can generally make ourselves available at any ame next week.
`
`Best,
`Paul
`
` Paul 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.
`
`
`
`
`
`
`On Feb 7, 2019, at 2:07 PM, BreM Mangrum <breM@etheridgelaw.com> wrote:
`
`IPR2018-00884
`Apple Inc. EX1014 Page 2
`
`

`

`On Feb 7, 2019, at 2:07 PM, BreM Mangrum <breM@etheridgelaw.com> wrote:
`
`Counsel,
`
`Uniloc cites to Dr. EasMom’s declaraaon solely for the proposiaon that “a POSITA
`would understand that the enaty intercepang 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 intercepang a message would
`be a third party to the intended recipients of that message.”
`
`Under these circumstances, Uniloc believes a cross examinaaon of Dr. EasMom is
`a waste of the paraes’ ame and resources. If you sall disagree, Uniloc would not
`oppose a moaon to strike Dr. EasMom’s declaraaon.
`
`Regards,
`BreM
`
`From: Paul Hart <paul.hart@eriseip.com>
`Sent: Tuesday, February 5, 2019 3:07 PM
`To: Danny BuMs <danny@etheridgelaw.com>; Ryan Loveless
`<ryan@etheridgelaw.com>; BreM Mangrum <breM@etheridgelaw.com>; Jeff
`Huang <jeff@etheridgelaw.com>; Jim Etheridge <jim@etheridgelaw.com>
`Cc: Adam Seitz <adam.seitz@eriseip.com>
`Subject: IPR2018-00884: Dr. EasMom Deposiaon
`
`Counsel,
`
`We would like to schedule Dr. EasMom’s deposiaon in IPR2018-00884. The week
`of March 18 works well on our end. Please let us know if Dr. EasMom is available
`any day that week.
`
`Thanks very much.
`
`Best,
`Paul
`
`
`
`
`
`
` Paul 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. EX1014 Page 3
`
`

`

`
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`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
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`
`IPR2018-00884
`Apple Inc. EX1014 Page 4
`
`