From: Ha, Yung-Hoon (Sam) <Yung-Hoon.Ha@wilmerhale.com>
`Sent: Thursday, April 9, 2020 10:23 AM
`To: Trials <Trials@USPTO.GOV>
`Cc: Bridget Smith <smith@lowensteinweatherwax.com>; Kenneth Weatherwax
`<weatherwax@lowensteinweatherwax.com>; Nathan Lowenstein
`<lowenstein@lowensteinweatherwax.com>; Flavio Rose <rose@lowensteinweatherwax.com>; Edward
`Hsieh <hsieh@lowensteinweatherwax.com>; Parham Hendifar
`<hendifar@lowensteinweatherwax.com>; Patrick Maloney <maloney@lowensteinweatherwax.com>;
`Jason Linger <linger@lowensteinweatherwax.com>; VLSI <VLSI_IPRs@lowensteinweatherwax.com>;
`Cho, Tim <Tim.Cho@wilmerhale.com>; Walden, S. Calvin <Calvin.Walden@wilmerhale.com>
`Subject: IPR2019-01198, -01199, and -1200 // Request to correct an inadvertently included date in
`Petitioner's Reply to POPR
`
`Dear Honorable Board,
`
`
`We have discovered that Petitioner’s Reply to POPR in IPR2019-01198, -01199, and -1200, submitted on
`December 11, 2019, inadvertently included an incorrect date. Petitioner would like to correct the
`record on page 3 of the Reply in each of the above-referenced cases as follows, where strikethrough
`indicate removal and underline indicate added text:
`
`
`
`
`“Focusing on the United States cases, VLSI initially filed suit against Intel in the Northern District
`of California on October 2, 2017, asserting 8 patents. See VLSI Technology LLC v. Intel
`Corporation, No. 5:17-cv-05671 (N.D. Cal.). After extensive discovery and case narrowing, and
`after successful institution of the IPR petitions filed by Intel, VLSI agreed, on June 28, 2018
`March 1, 2019, to a stipulation to stay that case in California. On June 28, 2018, However, on
`that same day, VLSI filed suit in Delaware, asserting 8 additional patents. See VLSI v. Intel, No.
`1:18-cv-00966 (D. Del.). Thereafter Also, on March 1, 2019, VLSI filed yet another suit in
`Delaware, asserting six additional patents. See VLSI v. Intel, 1:19-cv-00426 (D. Del.).
`
`
`In each of the above-referenced cases, correcting the date does not alter or affect any of the arguments
`Intel made in its Reply to the POPR. Nonetheless, Petitioner wanted to bring the issue to the Board’s
`attention to ensure a factually accurate record, and Petitioner requests authorization to file an amended
`Reply to the POPR.
`
`Petitioner has conferred with the Patent Owner and Patent Owner does not oppose.
`
`Yung-Hoon (Sam) Ha Ph.D. | WilmerHale
`7 World Trade Center
`250 Greenwich Street
`New York, NY 10007 USA
`+1 212 295 6404 (t)
`+1 212 230 8888 (f)
`yung-hoon.ha@wilmerhale.com
`
`Please consider the environment before printing this email.
`
`This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be
`privileged. If you are not the intended recipient, please notify us immediately—by replying to this message or by sending an email to
`postmaster@wilmerhale.com—and destroy all copies of this message and any attachments. Thank you.
`
`For more information about WilmerHale, please visit us at http://www.wilmerhale.com.
`
`
`
`
`Ex. 3003
`
`