`To:
`Cc:
`Subject:
`Date:
`
`Rocci, Steven
`Doug.Muehlhauser
`Guest-TekCA; Nomadix.Guest-Tek
`RE: Nomadix v Guest-Tek Conference of Counsel Regarding Motion Practice
`Monday, November 4, 2019 1:23:36 PM
`
`Doug:
`
`I’ve summarized our conference of counsel today, by annotating each of the agenda items below.
`
`Steve
`
`From: Rocci, Steven
`Sent: Monday, November 4, 2019 9:10 AM
`To: 'Doug.Muehlhauser' <Doug.Muehlhauser@knobbe.com>
`Cc: Guest-TekCA <Guest-TekCA@bakerlaw.com>; Nomadix.Guest-Tek <Nomadix.Guest-
`Tek@knobbe.com>
`Subject: Nomadix v Guest-Tek Conference of Counsel Regarding Motion Practice
`
`Doug,
`
`Please use the following dial in for our 11:30 AM Pacific/2:30 PM Eastern call:
`
`800-768-2983
`Code 564-8364
`
`
`As I understand it, we will be discussing:
`
`Nomadix’s contemplated motion(s) for summary judgment on Guest-Tek’s invalidity and misuse
`defenses, and on Nomadix’s breach of contract claim based on Guest-Tek’s alleged ongoing
`violations of the no-challenge clause; Guest-Tek opposes these motions. It is Nomadix’s position that
`these arise from the same operative facts and are therefore only one motion.
`
`Guest-Tek’s contemplated motion(s) for summary judgment on one or more of: Guest-Tek’s defense
`of Lack of Standing; Guest-Tek’s counterclaims for No Patent Coverage by one or more of the
`asserted Bandwidth Management, Redirection, Property Management System, and/or
`Authentication patents, and for breach of the MOU; Nomadix’s damages claims; Nomadix opposes
`these motions, and asserts that they are more than one motion. With respect to the standing issue,
`it is Nomadix’s position that the assignment on record at the Patent Office is inoperative, and that
`the patents were never owned by anyone other than Nomadix. Nomadix will direct us to the
`document from the NY action that, in Nomadix’s view, demonstrates that Nomadix has been and is
`presently the owner of the patents.
`
`Extension of the present page limits for the above MSJ’s; Nomadix opposes a page extension.
`
`
`NOMADIX 2010
`Guest Tek v. Nomadix
`IPR2019-01191
`
`
`
`Guest-Tek’s contemplated Rule 12(c) motion to dismiss the 2:19-cv-04980 case; Nomadix
`opposes both the Rule 12(c) motion and a motion to consolidate; and,
`
`Nomadix’s contemplated motion regarding Judge Mumm’s Report and Recommendation.
`Nomadix inquired whether Guest-Tek will agree that Judge Mumm’s report, recommending
`that Nomadix’s second supplemental responses to Guest-Tek’s interrogatory nos. 2 and 3,
`is/should be limited to non-OVI systems and does not strike Nomadix’s second supplemental
`responses directed to OVI systems. Nomadix stated that it may not move on/object to the
`report if Guest-Tek will so agree. We advised you that we will promptly get back to you on
`this.
`
`We advised you that Guest-Tek contemplates moving for summary judgment that claims 1 and 11 of
`the 917 patent are invalid as being anticipated by Trudeau. Nomadix opposes this motion
`
`Steve
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`NOMADIX 2010
`Guest Tek v. Nomadix
`IPR2019-01191
`
`
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