From: Brett Mangrum brett@etheridgelaw.com
`Subject: RE: IPR2018-00884: Dr. Easttom Deposition
`Date: March 28, 2019 at 12:41 PM
`To: Adam Seitz adam.seitz@eriseip.com, Ryan Loveless ryan@etheridgelaw.com
`Cc: Paul Hart paul.hart@eriseip.com, Danny Butts danny@etheridgelaw.com, Jeff Huang jeff@etheridgelaw.com, Jim Etheridge
`jim@etheridgelaw.com, Travis Richins travis@etheridgelaw.com
`
`Adam,
`
`With your wri0en s4pula4on acknowledging that the scope of the deposi4on will be strictly limited to the two paragraphs
`from his declara4on that Patent Owner cited in his response, Dr. Eas0om will be made available for deposi4on tomorrow
`(March 28) in the Dallas area (exact loca4on to be determined). Please let us know within the next couple of hours if you
`plan to move forward tomorrow.
`
`Thanks,
`Bre0
`
`From: Adam Seitz <adam.seitz@eriseip.com>
`Sent: Thursday, March 28, 2019 11:04 AM
`To: Ryan Loveless <ryan@etheridgelaw.com>; Bre0 Mangrum <bre0@etheridgelaw.com>
`Cc: Paul Hart <paul.hart@eriseip.com>; Danny Bu0s <danny@etheridgelaw.com>; Jeff Huang <jeff@etheridgelaw.com>; Jim
`Etheridge <jim@etheridgelaw.com>; Travis Richins <travis@etheridgelaw.com>
`Subject: Re: IPR2018-00884: Dr. Eas0om Deposi4on
`
`Bre0,
`
`Looping back on our discussion about Dr. Eas0om’s deposi4on. I appreciate you taking the call and discussing these issues
`with me. I believe you were going to consider whether you would agree to strike his declara4on and your reliance upon it to
`avoid a deposi4on as originally agreed between the par4es. I was going to consider whether we could agree to any claim
`construc4on to otherwise avoid his deposi4on. We have gone back and reviewed the ID, Eas0om’s declara4on, and Uniloc's
`responsive brief and we simply can’t agree on this issue. The ques4on of how “intercep4ng a message” should be construed
`is a fundamental dispute between the par4es, was discussed in the ID, and is the very point for which you cite to Eas0om in
`the Patent Owner Response. Unless the par4es can revert to our original agreement, then we want to proceed with a
`deposi4on of Mr. Eas0om. I understand you are concerned about breadth, and to reiterate, the focus of our deposi4on will
`be on the cited por4ons of his declara4on and his basis for those statements/opinions.
`
`Please let us know by COB today where you stand on this. If you are not going to give us dates, then please provide 4mes
`when you are available over the next few days for a conference call with the Board
`
`Thanks,
`
`Adam
`
`On Mar 14, 2019, at 10:26 AM, Ryan Loveless <ryan@etheridgelaw.com> wrote:
`
`For our call at 2:30 CST tomorrow, please use the following dial-in:
`
`Dial in number: 214-238-4431
`PIN: 04117
`
`Ryan Loveless | Etheridge Law Group
`2600 East Southlake Blvd | Suite 120-324 |Southlake, TX 76092
`ryan@etheridgelaw.com | T 972 292 8303 | F 817 887 5950
`
`From: Adam Seitz <adam.seitz@eriseip.com>
`Sent: Thursday, March 14, 2019 7:12 AM
`To: Bre0 Mangrum <bre0@etheridgelaw.com>
`Cc: Paul Hart <paul.hart@eriseip.com>; Danny Bu0s <danny@etheridgelaw.com>; Ryan Loveless
`<ryan@etheridgelaw.com>; Jeff Huang <jeff@etheridgelaw.com>; Jim Etheridge <jim@etheridgelaw.com>;
`Travis Richins <travis@etheridgelaw.com>
`Subject: Re: IPR2018-00884: Dr. Eas0om Deposi4on
`
`
`IPR2018-00884
`Apple Inc. EX1021 Page 1
`
`

`

`
`Bre0,
`
`That works. Let’s do 2:30. I’m currently traveling. Do you mind circula4ng a dial-in?
`
`Adam
`
`On Mar 13, 2019, at 11:27 AM, Bre0 Mangrum <bre0@etheridgelaw.com> wrote:
`
`Adam,
`
`We can be available for a conference call between the par4es on Friday between 2pm and 3pm
`(CST). Let us know of that works.
`
`Thanks,
`Bre0
`
`From: Adam Seitz <adam.seitz@eriseip.com>
`Sent: Tuesday, March 12, 2019 4:59 PM
`To: Bre0 Mangrum <bre0@etheridgelaw.com>
`Cc: Paul Hart <paul.hart@eriseip.com>; Danny Bu0s <danny@etheridgelaw.com>; Ryan Loveless
`<ryan@etheridgelaw.com>; Jeff Huang <jeff@etheridgelaw.com>; Jim Etheridge
`<jim@etheridgelaw.com>; Travis Richins <travis@etheridgelaw.com>
`Subject: Re: IPR2018-00884: Dr. Eas0om Deposi4on
`
`Bre0,
`
`Jumping in the middle here. Perhaps we are talking over each other or perhaps we are
`misunderstanding your thoughts. Why don’t we jump on the phone and see if we can figure this
`out. Do you have 4me this week where we could talk?
`
`Adam
`
`On Mar 12, 2019, at 2:31 PM, Bre0 Mangrum <bre0@etheridgelaw.com> wrote:
`
`Paul,
`
`We seem to be talking past one another. Our posi4on is straighporward: pursuant to
`the rules, any deposi4on of Dr. Eas0om should be strictly limited to the sole
`proposi4on for which the only two paragraphs of his declara4on is cited. You have
`refused to agree to this. Instead, your communica4ons confirm you intend to exceed
`that scope. On your last communica4on, for example, you confirmed your inten4on
`to ask ques4ons regarding an unspecified claim construc4on posi4on not addressed
`in the two paragraphs of Dr. Eas0om’s declara4on cited in Patent Owner’s
`response. Because Pe44oner has not agreed to properly limit the scope of the
`deposi4on to the sole argument in the Response for which the declara4on is cited,
`despite repeated invita4ons for Pe44oner to do so, the par4es clearly remain at a
`real impasse. Uniloc will inform the Board of these facts in its opposi4on to a mo4on
`to strike, should you decide to refile your mo4on.
`
`Regards,
`Bre0
`
`From: Paul Hart <paul.hart@eriseip.com>
`Sent: Monday, March 11, 2019 1:41 PM
`To: Bre0 Mangrum <bre0@etheridgelaw.com>
`Cc: Danny Bu0s <danny@etheridgelaw.com>; Ryan Loveless
`<ryan@etheridgelaw.com>; Jeff Huang <jeff@etheridgelaw.com>; Jim Etheridge
`<jim@etheridgelaw.com>; Adam Seitz <adam.seitz@eriseip.com>; Travis Richins
`<travis@etheridgelaw.com>
`
`IPR2018-00884
`Apple Inc. EX1021 Page 2
`
`

`

`<travis@etheridgelaw.com>
`Subject: Re: IPR2018-00884: Dr. Eas0om Deposi4on
`
`Bre0,
`
`Throughout this weeks-long back and forth Pe44oner has never stated or suggested
`that it seeks cross examina4on that exceeds the scope permi0ed by the rules. Your
`a0empt to manufacture such an issue simply finds no support in the par4es
`communica4ons.
`
` I
`
` will state our posi4on once again, to ensure there is no confusion. Pe44oner
`disagrees with Mr. Eas0om’s claim construc4on posi4on and Patent Owner’s reliance
`on the same. Unless Patent Owner agrees to strike Mr. Eas0om’s declara4on and all
`reliance on that declara4on, Pe44oner demands a deposi4on of Mr. Eas0om. It is
`our right to cross examine Mr. Eas0om and we will not consider wri0en ques4ons
`(and the poten4al for gamesmanship those introduce) an adequate subs4tute for
`live cross examina4on.
`
`As we’ve now requested mul4ple 4mes, either (i) provide dates for Mr. Eas0om’s
`deposi4on or (ii) confirm that (1) you are refusing to make Mr. Eas0om available for
`cross examina4on and that (2) you will not oppose a mo4on to strike his declara4on
`and any references or cita4ons thereto following the close of our discovery period.
`
`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 Mar 8, 2019, at 3:56 PM, Bre0 Mangrum
`<bre0@etheridgelaw.com> wrote:
`
`Paul,
`
`To more produc4vely advance this discussion, it would be helpful if you
`addressed our prior ques4ons, including whether Pe44oner disputes
`the sole proposi4on for which the expert declara4on is cited. You also
`neglected to address our proposed compromise. Nevertheless, we
`understand from your last, including your comment that Uniloc’s
`admi0edly narrow reliance on the declara4on is “irrelevant,” that you
`seek a deposi4on for the impermissible purpose of asking ques4ons
`directed to arguments outside the scope of the Patent Owner
`Response. You are reminded that 37 CFR 42.23 states a Pe44oner’s
`reply may only respond to arguments raised in a patent owner
`response. You apparent posi4on in scope is in conflict with this rule.
`You have provided no authority in support of your posi4on, though we
`invited you to do so.
`
`In the absence of the clarifica4on we specifically requested, we can only
`
`IPR2018-00884
`Apple Inc. EX1021 Page 3
`
`

`

`In the absence of the clarifica4on we specifically requested, we can only
`conclude that your purpose in seeking a deposi4on is to ask ques4ons
`outside what the rules allow. We need the clarifica4on we requested in
`order to properly address your ques4ons. Under the present
`circumstances, we cannot agree to not oppose a new mo4on to strike.
`
`Regards,
`Bre0
`
`From: Paul Hart <paul.hart@eriseip.com>
`Sent: Thursday, March 7, 2019 1:46 PM
`To: Bre0 Mangrum <bre0@etheridgelaw.com>
`Cc: Danny Bu0s <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. Eas0om Deposi4on
`
`Bre0,
`
`You’ve submi0ed an expert declara4on in this case and have relied on
`that declara4on in your Patent Owner Response. Under the rules, we’re
`en4tled to cross examine your expert in a deposi4on. The narrowness
`of your expert’s opinions on which you rely is irrelevant. We’re en4tled
`a deposi4on and, if you won’t agree to strike his declara4on and your
`reliance on that declara4on, we want to proceed with his deposi4on.
`
`To the extent you are unwilling to provide dates of availability for Dr.
`Eas0om, the only op4on is his tes4mony must be stricken. As we stated
`previously, either (i) provide dates for Dr. Eas0om’s deposi4on or (ii)
`confirm that (1) you are refusing to make Dr. Eas0om available for cross
`examina4on and that (2) you will not oppose a mo4on to strike his
`declara4on and any references or cita4ons thereto following the
`close of our discovery period.
`
`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 Mar 7, 2019, at 8:21 AM, Bre0 Mangrum
`<bre0@etheridgelaw.com> wrote:
`
`Paul:
`
`As we stated in prior communica4on, the Patent Owner
`
`IPR2018-00884
`Apple Inc. EX1021 Page 4
`
`

`

`As we stated in prior communica4on, the Patent Owner
`Response ONLY cites Dr. Eas0om’s declara4on (EX2001 ¶¶
`8-9) for the sole proposi4on that “a POSITA would
`understand that the en4ty intercep4ng a message would
`not be one of the intended recipients of that
`message.” Our posi4on is that it would be a waste of the
`par4es resources to schedule a deposi4on that, under the
`rules, must be restricted to that sole proposi4on. Indeed,
`Pe44oner has not indicated whether that straighporward
`proposi4on is even disputed. Please do so. Given your
`insistence in scheduling a deposi4on, we can only assume
`that you intend to expand the scope of the deposi4on
`beyond what the rules allow. Please clarify your posi4on
`as to the scope and the authority in support of your
`posi4on. Alterna4vely, and in the interest of compromise,
`we would not be opposed to you submitng a limited
`number of interrogatory ques4ons directed to the single
`proposi4on for which the declara4on is cited.
`
`Regards,
`Bre0
`
`
`From: Paul Hart <paul.hart@eriseip.com>
`Sent: Wednesday, March 6, 2019 2:58 PM
`To: Bre0 Mangrum <bre0@etheridgelaw.com>
`Cc: Danny Bu0s <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. Eas0om Deposi4on
`
`Bre0,
`
`Putng this back to the top of your inbox. Please let us
`know Uniloc’s posi4on.
`
`To the extent we do not hear from you on this issue, your
`silence will be interpreted as confirma4on that (1) you will
`not provide Dr. Eas0om for cross examina4on and (2) you
`will not oppose a mo4on to strike his declara4on and any
`references or cita4ons thereto following the close of our
`discovery period.
`
`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. EX1021 Page 5
`
`

`

`On Feb 28, 2019, at 9:43 AM, Paul Hart
`<paul.hart@eriseip.com> wrote:
`
`Bre0,
`
`Given the Court’s ruling (a0ached) that
`striking Eas0om’s declara4on is premature
`prior to the expira4on of our discovery
`period, we wanted to follow up with you all
`on next steps. To the extent that you are
`maintaining your prior posi4on, please
`confirm that (1) you will not provide Dr.
`Eas0om for cross examina4on and (2) you
`will not oppose a mo4on to strike his
`declara4on and any references or cita4ons
`thereto following the close of our discovery
`period. Otherwise, please provide dates of
`availability for Dr. Eas0om so Pe44oner can
`take his deposi4on in advance of our Reply.
`
`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.
`
`
`
`<Order denying mo4on to strike Eas0om's
`Dec.pdf>
`
`
`On Feb 21, 2019, at 9:44 AM,
`Paul Hart
`<paul.hart@eriseip.com> wrote:
`
`Bre0,
`
`Here’s what we intend to send
`the Board by COB this
`auernoon:
`
`>>>
`In IPR2018-00884, Pe44oner
`Apple respecpully requests
`
`IPR2018-00884
`Apple Inc. EX1021 Page 6
`
`

`

`Apple respecpully requests
`permission to file an Unopposed
`Mo4on to Strike under 37
`CFR 42.5(a) and 42.20(a).
`Specifically, the Pe44oner seeks
`to strike the Eas0om
`Declara4on (Exhibit 2001) and
`all references or cita4ons to the
`declara4on in any filing as an
`alterna4ve to making the
`declarant available for cross-
`examina4on. Pe44oner and
`Patent Owner have conferred,
`and Patent Owner indicates that
`they do not oppose the mo4on.
`
`If needed, Pe44oner 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.
`>>>
`
` 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 21, 2019,
`at 7:00 AM, Bre0
`Mangrum
`<bre0@etheridgel
`aw.com> wrote:
`
`Paul,
`
`Please provide us a
`drau 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
`
`IPR2018-00884
`Apple Inc. EX1021 Page 7
`
`

`

`week from 10am
`to 2pm (CST).
`
`Regards,
`Bre0
`
`From: Paul Hart
`<paul.hart@eriseip
`.com>
`Sent: Wednesday,
`February 20, 2019
`11:52 AM
`To: Bre0 Mangrum
`<bre0@etheridgel
`aw.com>
`Cc: Danny Bu0s
`<danny@etheridge
`law.com>; Ryan
`Loveless
`<ryan@etheridgela
`w.com>; Jeff
`Huang
`<jeff@etheridgela
`w.com>; Jim
`Etheridge
`<jim@etheridgela
`w.com>; Adam
`Seitz
`<adam.seitz@erise
`ip.com>
`Subject: Re:
`IPR2018-00884: Dr.
`Eas0om
`Deposi4on
`
`Counsel,
`
`We’ve had a
`chance to confer
`with our client,
`and we agree that
`an unopposed
`mo4on to strike Dr.
`Eas0om’s
`declara4on and
`any references or
`cita4ons thereto is
`an acceptable
`alterna4ve to cross
`examina4on. 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 4me next
`
`IPR2018-00884
`Apple Inc. EX1021 Page 8
`
`

`

`at any 4me next
`week.
`
`Best,
`Paul
`
` PaulHart | Shareholder
`Erise IP, P.A.
`Suite 200
`Greenwood Village, CO
`80111
`(main) 913-777-5600
`(direct) 720-689-5441
`paul.hart@eriseip.co
`(fax) 913-777-5601
`mwww.eriseip.com
`
`5600 Greenwood Plaza Blvd.
`
`
`
`
`
`
`On
`Feb 7,
`2019,
`at
`2:07
`PM,
`Bre0
`Mang
`rum
`<bre0
`@eth
`eridg
`elaw.c
`om>
`wrote
`
`: C
`
`ouns
`el,
`
`Unilo
`c cites
`to
`Dr. Ea
`s0om
`’s decl
`ara4o
`
`ns
`
`olely
`for
`the
`propo
`si4on
`that
`
`IPR2018-00884
`Apple Inc. EX1021 Page 9
`
`

`

`that
`“a
`POSIT
`
`Aw
`
`ould
`under
`stand
`that
`the
`en4ty
`interc
`ep4n
`g a
`mess
`age
`would
`not
`be
`one
`of the
`inten
`ded
`recipi
`ents
`of
`that
`mess
`age.
`EX200
`1 ¶¶
`8-9.
`In
`other
`words
`, a
`POSIT
`
`Aw
`
`ould
`under
`stand
`that
`the
`devic
`e that
`is
`interc
`ep4n
`g a
`mess
`age
`would
`be a
`third
`party
`to the
`inten
`ded
`recipi
`ents
`of
`that
`mess
`age.”
`
`IPR2018-00884
`Apple Inc. EX1021 Page 10
`
`

`

`age.”
`
`Unde
`
`rt
`
`hese
`circu
`mstan
`ces,
`Unilo
`
`cb
`
`eliev
`es a
`cross
`exami
`na4o
`n of
`Dr. Ea
`s0om
` is a
`waste
`of the
`par4e
`s’
`4me
`and
`resou
`rces.
`If you
`s4ll
`disagr
`ee,
`Unilo
`
`cw
`
`ould
`not
`oppos
`e a
`mo4o
`n to
`strike
`Dr. Ea
`s0om
`’s decl
`ara4o
`n.
`
`Regar
`ds,
`Bre0
`
`From:
` Paul
`Hart
`<paul.
`hart
`@eris
`eip.co
`m>
`Sent:
`Tuesd
`ay,
`Febru
`ary 5,
`
`IPR2018-00884
`Apple Inc. EX1021 Page 11
`
`

`

`ary 5,
`2019
`3:07
`PM
`To: D
`anny
`Bu0s
`<dan
`ny@e
`therid
`gelaw
`.com>
`; Ryan
`Lovel
`ess
`<ryan
`@eth
`eridg
`elaw.c
`om>;
`Bre0
`Mang
`rum
`<bre0
`@eth
`eridg
`elaw.c
`om>;
`Jeff
`Huan
`
`g<
`
`jeff
`@eth
`eridg
`elaw.c
`om>;
`Jim
`Etheri
`dge
`<jim
`@eth
`eridg
`elaw.c
`om>
`Cc: A
`dam
`Seitz
`<ada
`m.seit
`z@eri
`seip.c
`om>
`Subje
`ct: IP
`R201
`8-
`0088
`4: Dr.
`Eas0o
`
`mD
`
`epo
`si4on
`
`
`IPR2018-00884
`Apple Inc. EX1021 Page 12
`
`

`

`
`Couns
`el,
`
`We
`would
`like to
`sched
`ule
`Dr.
`Eas0o
`m’s
`depos
`i4on
`in
`IPR20
`18-
`0088
`4. The
`week
`of
`Marc
`h 18
`works
`well
`on
`our
`end.
`Pleas
`e let
`us
`know
`if Dr.
`Eas0o
`m is
`availa
`ble
`any
`day
`that
`week.
`
`
`Thank
`s very
`much.
`
`Best,
`Paul
`
` PaulHart |
`Share
`holde
`rErise
`IP, P.A.
`Suite200Greenw
`oodVillage,
`CO
`
`5600
`Greenwo
`od Plaza
`Blvd.
`
`IPR2018-00884
`Apple Inc. EX1021 Page 13
`
`

`

`CO80111
`(main)
`913-777-5600
`(direct)
`720-689-5441
`(fax)913-777-5601paul.h
`art@e
`riseip.
`comwww.
`erisei
`p.com
`
`
`
`
`
`Confidenti
`ality
`Statement
`This email
`message
`and any
`attached
`files are
`confidenti
`al and are
`intended
`solely
`for the use
`of the
`addressee
`(s) named
`above. Thi
`ommunic
`ation may
`contain
`material pr
`otected by
`attorney-
`client,
`work
`product, o
`r other
`privileges.
`If you are
`not
`the intend
`ed
`recipient
`or person
`responsibl
`e for
`delivering
`this
`confidenti
`al commu
`nication to
`the
`intended
`recipient,
`you have
`received
`this
`communic
`ation
`in error,
`and any
`review,
`use,
`dissemina
`tion, forwa
`rding,
`printing,
`copying,
`or
`other distri
`bution of
`this email
`message
`and
`any attach
`ed files is
`strictly
`prohibited.
`Erise
`IP, P.A.
`reserves
`the right to
`monitor
`any comm
`unication
`that is
`created,
`received,
`or sent on
`its
`network. If
`you have
`received t
`his
`confidenti
`al
`
`sc
`
`IPR2018-00884
`Apple Inc. EX1021 Page 14
`
`

`

`al
`communic
`ation in
`error, plea
`se notify
`the sender
`immediate
`ly by reply
`email
`message
`and
`permanen
`tly delete
`the
`original
`message.
`
`
`
`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.
`
`
`
`
`
`
`
`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.
`
`
`
`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.
`
`
`
`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.
`
`
`
`
`
`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.
`
`
`
`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. EX1021 Page 15
`
`

`

`
`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. EX1021 Page 16
`
`

`

`|PR2018—00884
`
`Apple Inc. EX1021 Page 17
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`IPR2018-00884
`Apple Inc. EX1021 Page 17
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`|PR2018—00884
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`Apple Inc. EX1021 Page 18
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`Apple Inc. EX1021 Page 18
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`|PR2018—00884
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`IPR2018-00884
`Apple Inc. EX1021 Page 19
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`|PR2018—00884
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`Apple Inc. EX1021 Page 20
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`IPR2018-00884
`Apple Inc. EX1021 Page 20
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`|PR2018—00884
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`IPR2018-00884
`Apple Inc. EX1021 Page 21
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`Apple Inc. EX1021 Page 22
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`IPR2018-00884
`Apple Inc. EX1021 Page 23
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`Apple Inc. EX1021 Page 24
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`IPR2018-00884
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`|PR2018—00884
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`Apple Inc. EX1021 Page 27
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`IPR2018-00884
`Apple Inc. EX1021 Page 27
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`