From:
`To:
`Cc:
`
`Subject:
`Date:
`
`Dan Smith
`Trials
`puneet.kohli@bakerbotts.com; brian.oaks@bakerbotts.com; Sara Fish; Tim Riffe; Thad Kodish; celeste.jones@bakerbotts.com; Thomas Rozylowicz; Diana Bradley; Karl Renner;
`ptab@fr.com; AXF-PTAB; Qualcomm_037IPR@BakerBotts.com; IPR39521-0050IP1
`IPR2018-01279
`Friday, September 27, 2019 12:12:31 AM
`
`Re: IPR2018-01279
`
`Your Honors,
`
`Due to a family emergency, Petitioner’s expert is unavailable and Petitioner respectfully requests a call with the Board to discuss postponing the
`oral hearing for the above-referenced proceeding, which is currently scheduled for October 30. The parties are generally available for a call with
`the Board next Monday (9/30), Tuesday (10/1), or Wednesday (10/2).
`
`To provide the Board with more details regarding the emergency, last week the wife of Petitioner’s expert, Dr. Narayan Mandayam, was involved
`in a serious car accident (described in this article). She sustained severe injuries in the accident necessitating multiple surgeries. Dr. Mandayam
`indicates that his wife is slowly recovering, but that he will be required to focus all of his time and energy over the next several weeks caring for
`her. Thus, he is unavailable, until at least the last week of October.
`
`As a result of this unavailability, Patent Owner was unable to depose Dr. Mandayam on 9/25 as scheduled. Patent Owner’s Surreply and Reply in
`Support of the Motion to Amend are currently due on 10/2, but obviously Patent Owner cannot prepare these filings without deposing Petitioner’s
`expert on his supplemental declaration filed in support of Petitioner’s Reply and Opposition to the Motion to Amend.
`
`Petitioner thus requests a call with the Board to discuss postponing the October 30 oral hearing either to compensate for Dr. Mandayam’s
`unforeseen period of unavailability, or, alternatively, to allow Petitioner to engage a new expert to step in for Dr. Mandayam and adopt his
`supplemental declaration.
`
`The parties have conferred, and Patent Owner does not oppose postponing the oral hearing.
`
`Respectfully,
`
`Dan Smith
`Counsel for Petitioner
`______________________________________
`Dan Smith :: Principal :: Fish & Richardson P.C.
`214 292 4071 direct :: 214 693 0516 cell
`
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`
`IPR2018-01279 Ex. 3002
`page 1 of 1
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