From: Cho, Tim <Tim.Cho@wilmerhale.com>
`Sent: Tuesday, January 21, 2020 5:11 PM
`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>; Ha, Yung-Hoon (Sam) <Yung-
`Hoon.Ha@wilmerhale.com>; Konstantakopoulos, Theodoros
`<Theodoros.Konstantakopoulos@wilmerhale.com>; Walden, S. Calvin
`<Calvin.Walden@wilmerhale.com>; Cho, Tim <Tim.Cho@wilmerhale.com>
`Subject: Re: Case Nos. IPR2019-01198, IPR2019-01199, and IPR2019-01200 // Request to file
`supplemental information
`
`Re: IPR2019-01198, IPR2019-01199, and IPR2019-01200
`
`Dear Honorable Board,
`
`Petitioner respectfully requests authorization to submit the following as exhibits in this
`proceeding under the Board’s authority in 37 CFR 42.5:
`
`
` “Plaintiff VLSI Technology LLC’s Identification of Eighteen Asserted Claims Pursuant to
`the Court’s April 22, 2019 Memorandum Order (D.I. 136)” The proposed exhibit shows
`that Plaintiff is no longer asserting the challenged claims of IPR proceedings IPR2019-
`01197 and IPR2019-01200 in the concurrent district court litigation.
`
` “Defendant Intel Corporation’s Identification of Thirty Prior Art Combinations” The
`proposed exhibit shows that on January 17, 2020, Intel further narrowed prior art
`combinations being pursued in the concurrent district court litigation as required by the
`district court, and is relevant to IPR2019-01198, -01199, and -1200. For example, Oda
`(relied upon in IPR2019-01198 and 01200) is no longer being pursued in the concurrent
`district court litigation.
`
` “Stipulation Regarding Case Schedule and Discovery Disputes” The proposed exhibit
`shows that Petitioner and Patent Owner have stipulated to an extended case schedule
`in the concurrent district court litigation.
`
` “District Court’s Order dated January 13, 2020” The proposed exhibit shows that the
`district court has adopted the stipulated extended case schedule, has cancelled the trial
`that had been scheduled for 11/2/2020, and ordered that the trial “will be rescheduled
`after the dispositive motions have been decided.”
`
`
`Petitioner believes these proposed exhibits are relevant to the 314(a) issues raised by the
`Patent Owner. Patent Owner does not oppose this request.
`
` 1 Exhibit 3001
`
`
`

`

`Respectfully,
`Tim Cho
`
`Taeg Sang (Tim) Cho | WilmerHale
`7 World Trade Center
`250 Greenwich Street
`New York, NY 10007 USA
`+1 212 295 6490 (t)
`+1 212 230 8888 (f)
`tim.cho@wilmerhale.com
`
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`
`
` 2 Exhibit 3001
`
`
`