`
`May 13, 2019
`
`VIA EMAIL
`
`Tarek N. Fahmi
`Ascenda Law Group, PC
`333 W San Carlos St., Suite 200
`San Jose, CA 95110-2730
`
`Victoria Q. Smith
`VSmith@perkinscoie.com
`D. +1.650.838.4313
`F. +1.650.838.4513
`
`Re: Ralph Lauren Corporation v. Lexos Media IP, LLC, Case Nos. IPR2018-01755,
`IPR2018-01749
`
`Dear Tarek:
`
`We write regarding the Patent Trial and Appeal Board’s Institution Decisions in
`IPR2018-01755 and IPR2018-01749 to apprise Patent Owner of what Petitioner believes are
`misapprehensions of Petitioner’s positions so that Patent Owner may address those positions in
`its Response.
`
`In both Decisions, the Board found that Petitioner had not shown reasonable likelihood of
`success that it will prevail with respect to grounds asserting obviousness over U.S. Patent No.
`6,437,800 (“Malamud”) of claims 1 and 53 of U.S. Patent No. 6,118,449, claims 70 and 72 of
`U.S. Patent No. 5,995,102, and the dependent claims that depend from these independent claims.
`
`In reaching its conclusion on whether Petitioner showed a reasonable likelihood of
`success on grounds asserting obviousness over Malamud, the Board appears to have
`misapprehended Petitioner’s argument related to the limitation wherein said specified content
`information further comprises information to be displayed on said display of said user’s terminal
`and its variants. Petitioner has consistently argued that information to be displayed is disclosed
`by the object in Malamud (see, e.g., ’449 Petition at 36; ’102 Petition at 41), but the Board has
`apparently misunderstood Petitioner’s statements as arguing that information to be displayed is
`disclosed by the name of the object in Malamud (see ’449 Decision at 18; ’102 Decision at 17).
`At trial, Petitioner intends to maintain and rely on its argument that information to be displayed
`is disclosed by the object in Malamud. We are bringing this issue to Patent Owner’s attention
`now so that Patent Owner may address the argument as it deems appropriate in discovery and its
`Response briefs.
`
`
`
`Page 1 of 2
`
`Ralph Lauren Corp. Ex. 1018
`Ralph Lauren Corp. v. Lexos Media IP, LLC
`IPR2018-01749, IPR2018-01755
`
`
`
`May 13, 2019
`Page 2
`
`
`Sincerely,
`
`
`Victoria Q. Smith
`
`
`
`
`Page 2 of 2
`
`Ralph Lauren Corp. Ex. 1018
`Ralph Lauren Corp. v. Lexos Media IP, LLC
`IPR2018-01749, IPR2018-01755
`
`
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