`To:
`Cc:
`Subject:
`Date:
`Attachments:
`
`John Edmonds
`Trials
`TVPPTABDocket; Pearce Jr., T. Vann; PTO-Edmonds; Jesse Villegas
`RE: IPR2019-00131: Request for Authorization to File Reply to Patent Owner"s Preliminary Response
`Thursday, February 14, 2019 2:43:06 PM
`image005.png
`
`Dear Board,
`
`Respondent opposes Petitioner’s request and does not deem a call necessary, but – should the Board
`desire a call - within the below parameters, our availability is as follows:
`
`
`after 2 PM Eastern tomorrow (Friday, February 15);
`next Wednesday afternoon after 2 pm Eeastern (February 20); or
`any time on Friday of next week (February 22).
`
`
`Respectfully,
`
`John Edmonds
`
`COLLINS EDMONDS
`
`COLLINS EDMONDS SCHLATHER & TOWER, PLLC
`1616 S. Voss Road, Suite 125
`Houston, Texas 77057
`713.364.5291
`1851 East First Street, Suite 900
`Santa Ana, California 92705
`714.702.5367
`jedmonds@ip-lit.com
`
`From: Pearce Jr., T. Vann <vpearce@orrick.com>
`Sent: Thursday, February 14, 2019 12:32 PM
`To: Trials@USPTO.gov
`Cc: TVPPTABDocket <TVPPTABDocket@orrick.com>; PTO-Edmonds <pto-edmonds@ip-lit.com>; Eric
`Carr <ecarr@ip-lit.com>
`Subject: IPR2019-00131: Request for Authorization to File Reply to Patent Owner's Preliminary
`Response
`
`Dear Board,
`
`Petitioners request a conference call with the Board seeking authorization to file a
`reply brief to the Patent Owner’s Preliminary Response (“POPR”) in IPR2019-00131.
`The reply would be limited to addressing the lack of standing argument in the POPR.
`Specifically, the reply would address Patent Owner’s argument, citing case law
`involving cancelled claims or claims ruled invalid following all appeals, that Petitioners
`“fail to show sufficient grounds or standing for institution” because of a district court
`ruling of invalidity under Section 101 that Patent Owner is appealing to the Federal
`Circuit (POPR, page 42).
`
`The parties have met and conferred. Patent Owner stated that it opposes Petitioners’
`
`
`
`request and that Patent Owner is available for a conference call after 2 PM Eastern
`tomorrow (Friday, February 15). Petitioners are available during that time as well;
`Petitioners also are available next Wednesday afternoon (February 20) or any time
`Thursday or Friday of next week (February 21-22).
`
`Respectfully submitted,
`Vann Pearce
`Lead Counsel for Petitioners
`
`
`T. Vann Pearce, Jr.
`Partner, Intellectual Property
`
`Orrick
`Washington, DC
`T +1-202-339-8696
`vpearce@orrick.com
`
`
`
`
`
`
`NOTICE TO RECIPIENT | This e-mail is meant for only the intended recipient of the transmission, and may be a
`communication privileged by law. If you received this e-mail in error, any review, use, dissemination, distribution, or copying
`of this e-mail is strictly prohibited. Please notify us immediately of the error by return e-mail and please delete this message
`from your system. Thank you in advance for your cooperation.
`
`For more information about Orrick, please visit http://www.orrick.com.
`
`In the course of our business relationship, we may collect, store and transfer information about you. Please see our privacy
`policy at https://www.orrick.com/Privacy-Policy to learn about how we use this information.
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
