From:
`To:
`Cc:
`Subject:
`Date:
`
`Bregman, Dion M.
`Trials
`"Stephen Murray"; John D. Simmons; Dennis Butler; Keith Jones; LGE-ImmerVision-IPRs
`IPR2020-00179 and -00195 / Request to Submit Supplemental Information
`Thursday, June 11, 2020 7:29:02 PM
`
`Dear Board,
`
`Petitioner writes to request permission to file a motion to submit supplemental information
`pursuant to 37 C.F.R. § 42.123(a) in the captioned cases. The supplemental information consists of:
`1) Code V Designer’s Manual: System of Optical Design Programs, 2nd ed., Optical Research
`Associates (1978) (Ex. 1014);
`2) Excerpts of the Code V Reference Manual, Version 7.60, Optical Research Associates (Feb.
`1994) (Ex. 1015);
`3) “A Technical Overview of CODE V Version 7” by Bruce R. Irving of Optical Research
`Associates, Proceedings Volume 0766 of the Society of Photo-Optical Instrumentation
`Engineers (SPIE), Recent Trends in Optical Systems Design and Computer Lens Design
`Workshop (1987) (Ex. 1016); and
`4) A supplemental declaration from Petitioner’s expert (Ex. 1017) that authenticates the above
`three additional pieces of evidence and notes that they corroborate his opinion in his
`original declaration that the Code V lens design software would render the same results in
`2001 as it did at the time of his declaration.
`
`
`Petitioner has conferred with counsel for Patent Owner, who has indicated that they do not oppose
`Petitioner’s motion to submit the above-referenced exhibits.
`
`If authorized, Petitioner seeks guidance as to whether the above listed exhibits should be filed with
`the unopposed motion or whether the exhibits should only be filed if and when the motion is
`granted.
`
`If the Board wishes to convene a call to discuss Petitioner’s request, the parties are available next
`week as follows:
`1. Monday (6/15) – 11:30am-1:30pm or after 4:30pm ET
`2. Tuesday (6/16) – 11:30am-12:30pm or 3:00pm ET
`
`
`Thank you.
`
`Respectfully submitted,
`
`-Dion Bregman
`
`Dion M. Bregman
`Morgan, Lewis & Bockius LLP
`1400 Page Mill Road | Palo Alto, CA 94304
`Direct: +1.650.843.7519 | Main: +1.650.843.4000 | Fax: +1.650.843.4001
`dion.bregman@morganlewis.com | www.morganlewis.com
`Assistant: Kari B. Aguiar | +1.650.843.7877 | kari.aguiar@morganlewis.com
`
`
`

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