`Christopher Evans; Joseph Micallef; Greenhut, Jason P.
`Alfonso G Chan; Alicia Cary-Howell; Shukri Abdi; Rhonda Polvado; Caroline Johnson
`RE: SRC Labs LLC & St. Regis Mohawk Tribe v. Microsoft Corp., Case No. 18-cv-321-JLR (W.D. Wash.)
`Tuesday, October 9, 2018 11:34:53 AM
`
`From:
`To:
`Cc:
`Subject:
`Date:
`
`Chris,
`
`As we proposed previously, Microsoft would be willing to enter into a mutual stay of the IPRs pending the Federal Circuit’s resolution of the
`rehearing petition directed to the tribal immunity issue if SRC and SRMT are willing to stay all district court proceedings on the patents that are the
`subject of those IPR. If your client cannot agree to that, Microsoft will oppose any motion to stay the PTAB proceedings, although we take no
`position on your request to the Board to file such a motion.
`
`We also previously explained that for any potential PHV motion by you or Michael Shore, Microsoft will not oppose for those proceedings involving
`patents for which there is no possibility of amending claims should the IPR be instituted. For those IPR proceedings involving patents where future
`claim amendment could be possible after institution, e.g., the 324 and 800 Patent proceedings, Microsoft also will not oppose at this time.
`However, if those IPRs are instituted and proceed past your motion practice on immunity, Microsoft reserves its right to seek a supplemental
`protective order with a prosecution bar in the district court. Of course, such a protective order would be unnecessary if you agree that SRMT will
`not seek to amend those patents during the IPR proceedings.
`
`SCOTT M. BORDER
`
`SIDLEY AUSTIN LLP
`+1 202 736 8818
`sborder@sidley.com
`
`From: Christopher Evans <cevans@ShoreChan.com>
`Sent: Thursday, October 4, 2018 4:18 PM
`To: Micallef, Joseph <jmicallef@sidley.com>; Border, Scott <sborder@sidley.com>; Greenhut, Jason P. <jgreenhut@sidley.com>
`Cc: Alfonso G Chan <achan@ShoreChan.com>; Cary-Howell, Alicia (NON-SIDLEY @SHORECHAN.COM) <acary-howell@shorechan.com>;
`Shukri Abdi <sabdi@ShoreChan.com>; Polvado, Rhonda (NON-SIDLEY @SHORECHAN.COM) <rpolvado@shorechan.com>; Johnson,
`Caroline (NON-SIDLEY @SHORECHAN.COM) <cjohnson@shorechan.com>
`Subject: FW: SRC Labs LLC & St. Regis Mohawk Tribe v. Microsoft Corp., Case No. 18-cv-321-JLR (W.D. Wash.)
`
`Scott, Joseph, and Jason,
`
`The Saint Regis Mohawk Tribe is going to seek permission from the Board to file the attached motion to stay the IPRs in light of the pending
`Federal Circuit appeal on whether sovereign immunity applies to IPRs. Please let me know if you will oppose our request to file the motion
`and whether you will oppose the motion itself.
`
`Also, I am also going to request permission to file a Motion for Pro Hac Vice Admission for myself. Please let me know if Microsoft will
`oppose this motion as well.
`
`Sincerely,
`
`Chris Evans
`
`Christopher L. Evans
`Shore Chan DePumpo LLP
`901 Main Street, Suite 3300
`Dallas, Texas 75202
`214-593-9118 (Direct)
`214-593-9110 (Firm)
`214-593-9111 (Fax)
`
`NOTICE OF CONFIDENTIALITY:
`The information contained in and transmitted with this e-mail may be subject to the Attorney-Client and Attorney Work Product privileges, and is Confidential. It is intended only
`for the individuals or entities designated as recipients above. You are hereby notified that any dissemination, distribution, copying, use or reliance upon the information contained
`in and transmitted with this e-mail by or to anyone other than the addressee designated above by the sender is unauthorized and strictly prohibited. If you have received this e-mail
`in error, please notify the sender by reply immediately. Any e-mail erroneously transmitted to you should be immediately destroyed.
`
`From: Cederoth, Richard A. <rcederoth@sidley.com>
`Sent: Friday, September 21, 2018 12:38 PM
`To: Christopher Evans <cevans@ShoreChan.com>; Michael Shore <mshore@ShoreChan.com>
`Subject: RE: SRC Labs LLC & St. Regis Mohawk Tribe v. Microsoft Corp., Case No. 18-cv-321-JLR (W.D. Wash.)
`
`Patent Owner Saint Regis Mohawk Tribe
`Ex. 2023, p. 1
`
`
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