From: Brett Mangrum brett@etheridgelaw.com
`Subject: RE: IPR2018-00884: Dr. Easttom Deposition
`Date: March 28, 2019 at 2:28 PM
`To: Adam Seitz adam.seitz@eriseip.com
`Cc: Ryan Loveless ryan@etheridgelaw.com, 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,
`
`Your response deadline is April 2. We do not understand how you could feign surprise that we offered Dr. Eas>om for a deposi?on on
`one of the two remaining week days that remain prior to your due date.
`
`Moreover, the compressed schedule that remains is a problem of your own making. During our last conference call, which occurred
`nearly two weeks ago (on March 15), you acknowledged that you needed to go back to your client on issues we discussed, including
`whether and how you wanted to proceed. You commi>ed to us that you would update us within days of that call. You did not. Instead,
`you chose to delay upda?ng us on your posi?on un?l just this morning. Had you updated us sooner, as you had previously commi>ed to
`do, we likely would have had more op?ons to consider.
`
`Please clarify as soon as possible as to whether you refuse to depose Dr. Eas>om tomorrow.
`
`Thanks,
`Bre>
`
`From: Adam Seitz <adam.seitz@eriseip.com>
`Sent: Thursday, March 28, 2019 2:43 PM
`To: Bre> Mangrum <bre>@etheridgelaw.com>
`Cc: Ryan Loveless <ryan@etheridgelaw.com>; Paul Hart <paul.hart@eriseip.com>; Danny Bu>s <danny@etheridgelaw.com>; Jeff Huang
`<jeff@etheridgelaw.com>; Jim Etheridge <jim@etheridgelaw.com>; Travis Richins <travis@etheridgelaw.com>
`Subject: Re: IPR2018-00884: Dr. Eas>om Deposi?on
`
`Thanks, Bre>, for agreeing to make him available for deposi?on. We absolutely intend to move forward with his deposi?on. That being
`said, proposing tomorrow—less than 1-day's no?ce—is unreasonable and unworkable. Please let us know when Dr. Eas>om is available
`next week, we can make any day or ?me work.
`
`Also, to clarify, we are agreeing to limit our deposi?on to the two paragraphs and the basis for his opinion. We are en?tled to ask him
`how and why he reached those opinions contained in those two paragraphs.
`
`Thanks,
`
`Adam
`
`On Mar 28, 2019, at 1:41 PM, Bre> Mangrum <bre>@etheridgelaw.com> wrote:
`
`Adam,
`
`With your wri>en s?pula?on acknowledging that the scope of the deposi?on will be strictly limited to the two paragraphs
`from his declara?on that Patent Owner cited in his response, Dr. Eas>om will be made available for deposi?on tomorrow
`(March 28) in the Dallas area (exact loca?on to be determined). Please let us know within the next couple of hours if you
`plan to move forward tomorrow.
`
`Thanks,
`Bre>
`
`From: Adam Seitz <adam.seitz@eriseip.com>
`Sent: Thursday, March 28, 2019 11:04 AM
`To: Ryan Loveless <ryan@etheridgelaw.com>; Bre> Mangrum <bre>@etheridgelaw.com>
`Cc: Paul Hart <paul.hart@eriseip.com>; Danny Bu>s <danny@etheridgelaw.com>; Jeff Huang <jeff@etheridgelaw.com>; Jim
`Etheridge <jim@etheridgelaw.com>; Travis Richins <travis@etheridgelaw.com>
`Subject: Re: IPR2018-00884: Dr. Eas>om Deposi?on
`
`Bre>,
`
`Looping back on our discussion about Dr. Eas>om’s deposi?on. 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 declara?on and your reliance upon it to
`avoid a deposi?on as originally agreed between the par?es. I was going to consider whether we could agree to any claim
`construc?on to otherwise avoid his deposi?on. We have gone back and reviewed the ID, Eas>om’s declara?on, and Uniloc's
`responsive brief and we simply can’t agree on this issue. The ques?on of how “intercep?ng a message” should be construed
`
`IPR2018-00884
`Apple Inc. EX1022 Page 1
`
`

`

`responsive brief and we simply can’t agree on this issue. The ques?on of how “intercep?ng a message” should be construed
`is a fundamental dispute between the par?es, was discussed in the ID, and is the very point for which you cite to Eas>om in
`the Patent Owner Response. Unless the par?es can revert to our original agreement, then we want to proceed with a
`deposi?on of Mr. Eas>om. I understand you are concerned about breadth, and to reiterate, the focus of our deposi?on will
`be on the cited por?ons of his declara?on 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 ?mes
`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: Bre> Mangrum <bre>@etheridgelaw.com>
`Cc: Paul Hart <paul.hart@eriseip.com>; Danny Bu>s <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. Eas>om Deposi?on
`
`Bre>,
`
`That works. Let’s do 2:30. I’m currently traveling. Do you mind circula?ng a dial-in?
`
`Adam
`
`On Mar 13, 2019, at 11:27 AM, Bre> Mangrum <bre>@etheridgelaw.com> wrote:
`
`Adam,
`
`We can be available for a conference call between the par?es on Friday between 2pm and 3pm
`(CST). Let us know of that works.
`
`Thanks,
`Bre>
`
`From: Adam Seitz <adam.seitz@eriseip.com>
`Sent: Tuesday, March 12, 2019 4:59 PM
`To: Bre> Mangrum <bre>@etheridgelaw.com>
`Cc: Paul Hart <paul.hart@eriseip.com>; Danny Bu>s <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. Eas>om Deposi?on
`
`Bre>,
`
`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 ?me this week where we could talk?
`
`Adam
`
`IPR2018-00884
`Apple Inc. EX1022 Page 2
`
`

`

`On Mar 12, 2019, at 2:31 PM, Bre> Mangrum <bre>@etheridgelaw.com> wrote:
`
`Paul,
`
`We seem to be talking past one another. Our posi?on is straighrorward: pursuant to
`the rules, any deposi?on of Dr. Eas>om should be strictly limited to the sole
`proposi?on for which the only two paragraphs of his declara?on is cited. You have
`refused to agree to this. Instead, your communica?ons confirm you intend to exceed
`that scope. On your last communica?on, for example, you confirmed your inten?on
`to ask ques?ons regarding an unspecified claim construc?on posi?on not addressed
`in the two paragraphs of Dr. Eas>om’s declara?on cited in Patent Owner’s
`response. Because Pe??oner has not agreed to properly limit the scope of the
`deposi?on to the sole argument in the Response for which the declara?on is cited,
`despite repeated invita?ons for Pe??oner to do so, the par?es clearly remain at a
`real impasse. Uniloc will inform the Board of these facts in its opposi?on to a mo?on
`to strike, should you decide to refile your mo?on.
`
`Regards,
`Bre>
`
`From: Paul Hart <paul.hart@eriseip.com>
`Sent: Monday, March 11, 2019 1:41 PM
`To: Bre> Mangrum <bre>@etheridgelaw.com>
`Cc: Danny Bu>s <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>
`Subject: Re: IPR2018-00884: Dr. Eas>om Deposi?on
`
`Bre>,
`
`Throughout this weeks-long back and forth Pe??oner has never stated or suggested
`that it seeks cross examina?on that exceeds the scope permi>ed by the rules. Your
`a>empt to manufacture such an issue simply finds no support in the par?es
`communica?ons.
`
` I
`
` will state our posi?on once again, to ensure there is no confusion. Pe??oner
`disagrees with Mr. Eas>om’s claim construc?on posi?on and Patent Owner’s reliance
`on the same. Unless Patent Owner agrees to strike Mr. Eas>om’s declara?on and all
`reliance on that declara?on, Pe??oner demands a deposi?on of Mr. Eas>om. It is
`our right to cross examine Mr. Eas>om and we will not consider wri>en ques?ons
`(and the poten?al for gamesmanship those introduce) an adequate subs?tute for
`live cross examina?on.
`
`As we’ve now requested mul?ple ?mes, either (i) provide dates for Mr. Eas>om’s
`deposi?on or (ii) confirm that (1) you are refusing to make Mr. Eas>om available for
`cross examina?on and that (2) you will not oppose a mo?on to strike his declara?on
`and any references or cita?ons 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. EX1022 Page 3
`
`

`

`On Mar 8, 2019, at 3:56 PM, Bre> Mangrum
`<bre>@etheridgelaw.com> wrote:
`
`Paul,
`
`To more produc?vely advance this discussion, it would be helpful if you
`addressed our prior ques?ons, including whether Pe??oner disputes
`the sole proposi?on for which the expert declara?on is cited. You also
`neglected to address our proposed compromise. Nevertheless, we
`understand from your last, including your comment that Uniloc’s
`admi>edly narrow reliance on the declara?on is “irrelevant,” that you
`seek a deposi?on for the impermissible purpose of asking ques?ons
`directed to arguments outside the scope of the Patent Owner
`Response. You are reminded that 37 CFR 42.23 states a Pe??oner’s
`reply may only respond to arguments raised in a patent owner
`response. You apparent posi?on in scope is in conflict with this rule.
`You have provided no authority in support of your posi?on, though we
`invited you to do so.
`
`In the absence of the clarifica?on we specifically requested, we can only
`conclude that your purpose in seeking a deposi?on is to ask ques?ons
`outside what the rules allow. We need the clarifica?on we requested in
`order to properly address your ques?ons. Under the present
`circumstances, we cannot agree to not oppose a new mo?on to strike.
`
`Regards,
`Bre>
`
`From: Paul Hart <paul.hart@eriseip.com>
`Sent: Thursday, March 7, 2019 1:46 PM
`To: Bre> Mangrum <bre>@etheridgelaw.com>
`Cc: Danny Bu>s <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. Eas>om Deposi?on
`
`Bre>,
`
`You’ve submi>ed an expert declara?on in this case and have relied on
`that declara?on in your Patent Owner Response. Under the rules, we’re
`en?tled to cross examine your expert in a deposi?on. The narrowness
`of your expert’s opinions on which you rely is irrelevant. We’re en?tled
`a deposi?on and, if you won’t agree to strike his declara?on and your
`reliance on that declara?on, we want to proceed with his deposi?on.
`
`To the extent you are unwilling to provide dates of availability for Dr.
`Eas>om, the only op?on is his tes?mony must be stricken. As we stated
`previously, either (i) provide dates for Dr. Eas>om’s deposi?on or (ii)
`confirm that (1) you are refusing to make Dr. Eas>om available for cross
`examina?on and that (2) you will not oppose a mo?on to strike his
`declara?on and any references or cita?ons 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. EX1022 Page 4
`
`

`

`
`
`
`
`
`On Mar 7, 2019, at 8:21 AM, Bre> Mangrum
`<bre>@etheridgelaw.com> wrote:
`
`Paul:
`
`As we stated in prior communica?on, the Patent Owner
`Response ONLY cites Dr. Eas>om’s declara?on (EX2001 ¶¶
`8-9) for the sole proposi?on that “a POSITA would
`understand that the en?ty intercep?ng a message would
`not be one of the intended recipients of that
`message.” Our posi?on is that it would be a waste of the
`par?es resources to schedule a deposi?on that, under the
`rules, must be restricted to that sole proposi?on. Indeed,
`Pe??oner has not indicated whether that straighrorward
`proposi?on is even disputed. Please do so. Given your
`insistence in scheduling a deposi?on, we can only assume
`that you intend to expand the scope of the deposi?on
`beyond what the rules allow. Please clarify your posi?on
`as to the scope and the authority in support of your
`posi?on. Alterna?vely, and in the interest of compromise,
`we would not be opposed to you submiung a limited
`number of interrogatory ques?ons directed to the single
`proposi?on for which the declara?on is cited.
`
`Regards,
`Bre>
`
`
`From: Paul Hart <paul.hart@eriseip.com>
`Sent: Wednesday, March 6, 2019 2:58 PM
`To: Bre> Mangrum <bre>@etheridgelaw.com>
`Cc: Danny Bu>s <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. Eas>om Deposi?on
`
`Bre>,
`
`Puung this back to the top of your inbox. Please let us
`know Uniloc’s posi?on.
`
`To the extent we do not hear from you on this issue, your
`silence will be interpreted as confirma?on that (1) you will
`not provide Dr. Eas>om for cross examina?on and (2) you
`will not oppose a mo?on to strike his declara?on and any
`references or cita?ons thereto following the close of our
`discovery period.
`
`Best,
`Paul
`
` Paul Hart | Shareholder
`Erise IP, P.A.
`Suite 200
`Greenwood Village, CO 80111
`
`5600 Greenwood Plaza Blvd.
`
`IPR2018-00884
`Apple Inc. EX1022 Page 5
`
`

`

`Greenwood Village, CO 80111
`(main) 913-777-5600
`(direct) 720-689-5441
`paul.hart@eriseip.com
`(fax) 913-777-5601
`www.eriseip.com
`
`
`
`
`
`
`On Feb 28, 2019, at 9:43 AM, Paul Hart
`<paul.hart@eriseip.com> wrote:
`
`Bre>,
`
`Given the Court’s ruling (a>ached) that
`striking Eas>om’s declara?on is premature
`prior to the expira?on of our discovery
`period, we wanted to follow up with you all
`on next steps. To the extent that you are
`maintaining your prior posi?on, please
`confirm that (1) you will not provide Dr.
`Eas>om for cross examina?on and (2) you
`will not oppose a mo?on to strike his
`declara?on and any references or cita?ons
`thereto following the close of our discovery
`period. Otherwise, please provide dates of
`availability for Dr. Eas>om so Pe??oner can
`take his deposi?on 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 mo?on to strike Eas>om's
`Dec.pdf>
`
`
`On Feb 21, 2019, at 9:44 AM,
`Paul Hart
`<paul.hart@eriseip.com> wrote:
`
`Bre>,
`
`Here’s what we intend to send
`
`IPR2018-00884
`Apple Inc. EX1022 Page 6
`
`

`

`Here’s what we intend to send
`the Board by COB this
`avernoon:
`
`>>>
`In IPR2018-00884, Pe??oner
`Apple respecrully requests
`permission to file an Unopposed
`Mo?on to Strike under 37
`CFR 42.5(a) and 42.20(a).
`Specifically, the Pe??oner seeks
`to strike the Eas>om
`Declara?on (Exhibit 2001) and
`all references or cita?ons to the
`declara?on in any filing as an
`alterna?ve to making the
`declarant available for cross-
`examina?on. Pe??oner and
`Patent Owner have conferred,
`and Patent Owner indicates that
`they do not oppose the mo?on.
`
`If needed, Pe??oner 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, Bre>
`Mangrum
`<bre>@etheridgel
`aw.com> wrote:
`
`Paul,
`
`Please provide us a
`drav 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
`
`IPR2018-00884
`Apple Inc. EX1022 Page 7
`
`

`

`either Monday or
`Tuesday of next
`week from 10am
`to 2pm (CST).
`
`Regards,
`Bre>
`
`From: Paul Hart
`<paul.hart@eriseip
`.com>
`Sent: Wednesday,
`February 20, 2019
`11:52 AM
`To: Bre> Mangrum
`<bre>@etheridgel
`aw.com>
`Cc: Danny Bu>s
`<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.
`Eas>om
`Deposi?on
`
`Counsel,
`
`We’ve had a
`chance to confer
`with our client,
`and we agree that
`an unopposed
`mo?on to strike Dr.
`Eas>om’s
`declara?on and
`any references or
`cita?ons thereto is
`an acceptable
`alterna?ve to cross
`examina?on. 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 ?me next
`week.
`
`Best,
`Paul
`
`
`IPR2018-00884
`Apple Inc. EX1022 Page 8
`
`

`

`5600 Greenwood Plaza Blvd.
`
` 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
`
`
`
`
`
`
`On
`Feb 7,
`2019,
`at
`2:07
`PM,
`Bre>
`Mang
`rum
`<bre>
`@eth
`eridg
`elaw.c
`om>
`wrote
`
`: C
`
`ouns
`el,
`
`Unilo
`c cites
`to
`Dr. Ea
`s>om
`’s decl
`ara?o
`
`ns
`
`olely
`for
`the
`propo
`si?on
`that
`“a
`POSIT
`
`Aw
`
`ould
`under
`stand
`that
`the
`en?ty
`interc
`
`IPR2018-00884
`Apple Inc. EX1022 Page 9
`
`

`

`interc
`ep?n
`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
`ep?n
`g a
`mess
`age
`would
`be a
`third
`party
`to the
`inten
`ded
`recipi
`ents
`of
`that
`mess
`age.”
`
`Unde
`
`rt
`
`hese
`circu
`mstan
`ces,
`Unilo
`
`cb
`
`eliev
`es a
`cross
`exami
`na?o
`n of
`Dr. Ea
`
`IPR2018-00884
`Apple Inc. EX1022 Page 10
`
`

`

`Dr. Ea
`s>om
` is a
`waste
`of the
`par?e
`s’
`?me
`and
`resou
`rces.
`If you
`s?ll
`disagr
`ee,
`Unilo
`
`cw
`
`ould
`not
`oppos
`e a
`mo?o
`n to
`strike
`Dr. Ea
`s>om
`’s decl
`ara?o
`n.
`
`Regar
`ds,
`Bre>
`
`From:
` Paul
`Hart
`<paul.
`hart
`@eris
`eip.co
`m>
`Sent:
`Tuesd
`ay,
`Febru
`ary 5,
`2019
`3:07
`PM
`To: D
`anny
`Bu>s
`<dan
`ny@e
`therid
`gelaw
`.com>
`; Ryan
`Lovel
`ess
`<ryan
`@eth
`eridg
`elaw.c
`om>;
`Bre>
`Mang
`rum
`
`IPR2018-00884
`Apple Inc. EX1022 Page 11
`
`

`

`<bre>
`@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.
`Eas>o
`
`mD
`
`epo
`si?on
`
`Couns
`el,
`
`We
`would
`like to
`sched
`ule
`Dr.
`Eas>o
`m’s
`depos
`i?on
`in
`IPR20
`18-
`0088
`4. The
`week
`of
`Marc
`h 18
`works
`well
`on
`our
`end.
`Pleas
`e let
`
`IPR2018-00884
`Apple Inc. EX1022 Page 12
`
`

`

`e let
`us
`know
`if Dr.
`Eas>o
`m is
`availa
`ble
`any
`day
`that
`week.
`
`
`Thank
`s very
`much.
`
`Best,
`Paul
`
`5600
`Greenwo
`od Plaza
`Blvd.
`
` PaulHart |
`Share
`holde
`rErise
`IP, P.A.
`Suite200Greenw
`oodVillage,
`CO80111
`(main)
`913-777-5600
`(direct)
`720-689-5441
`(fax)913-777-5601paul.h
`art@e
`riseip.
`comwww.
`erisei
`p.com
`
`
`
`
`
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`
`IPR2018-00884
`Apple Inc. EX1022 Page 13
`
`

`

`ed
`recipient
`or person
`responsibl
`e for
`delivering
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`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
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`communication in error, please
`notify the sender immediately
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`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
`
`IPR2018-00884
`Apple Inc. EX1022 Page 14
`
`

`

`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
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