Venkat Konda
`Anderson, Paul M.; Modi, Naveen; Jairam, Arvind; Hsieh, Courtney A.
`Venkat Konda
`[EXT] Re: Availability of Dr. Chaudhary for Deposition
`Friday, December 18, 2020 6:07:03 PM
`
`From:
`To:
`Cc:
`Subject:
`Date:
`
`Mr. Anderson:
`
`In reply to your email, I propose the following for the taking of Dr. Chaudhary's deposition:
`
`1. The deposition will be scheduled for December 30, 2020 at 9:00 AM EST continuing as per the rules. Please serve a formal notice of deposition to that effect
`setting forth the logistics for the taking of the deposition (presumably by Zoom, Blue Jeans or other videoconferencing system which Petitioner will provide).
`2. Petitioner's cross-examination, Patent Owner's redirect examination (if any), and Petitioner's re-cross-examination (if any) will of course be limited to Dr.
`Chaudhary's declaration according to 37 C.F.R. 42.53(d)(5)(ii).
`3. I will be retaining a registered patent attorney to make a special appearance on behalf of Patent Owner at the deposition.
`
`Please let me know if you agree to the above so that the matter can be resolved without the necessity of involving the Board.
`
`Very Truly Yours,
`Venkat Konda Ph.D
`
`From: Anderson, Paul M. <paulanderson@paulhastings.com>
`Date: Fri, Dec 18, 2020 at 1:18 PM
`Subject: RE: Availability of Dr. Chaudhary for Deposition
`To: Venkat Konda <venkat@kondatech.com>
`Cc: Modi, Naveen <naveenmodi@paulhastings.com>, Jairam, Arvind <arvindjairam@paulhastings.com>, Hsieh, Courtney A.
`<courtneyhsieh@paulhastings.com>, Anderson, Paul M. <paulanderson@paulhastings.com>
`
`Dr. Konda,
`
`
`
`Thank you for getting back to us. It seems like we should just seek the Board’s guidance on these issues. Below is an email we
`plan to send to the Board later today. Please insert your position and availability for a call.
`
`
`
`***************
`
`Petitioner Flex Logix seeks the Board’s guidance on the following issues that have arisen in the above-mentioned proceedings:
`
`
`
`First, as the Board is aware, Patent Owner has submitted a declaration from Dr. Vipin Chaudhary, PH.D. (Ex. 2005) in these
`proceedings. Petitioner has been conferring with Patent Owner on three issues with respect to deposing Dr. Chaudhary and seeks
`the Board’s guidance:
`
`
`
`1. Petitioner has been trying to meet and confer to arrive at a deposition time that is appropriate. Patent Owner proposed only
`December 30th within a three week period with a 2 PM ET start time. Patent Owner has provided no justification for the late start
`time. Based on the interaction with Patent Owner during the meet and confer to establish a deposition time, it has become clear
`that Patent Owner’s conduct during the deposition is likely to require intervention by the Board, and, as such, having the deposition
`take place outside of normal business hours is unduly burdensome on both Petitioner and the Board.
`
`
`
`2. Patent Owner is not committing to producing Dr. Chaudhry for the entire time period that is provided by the rules. See 37
`C.F.R. 42.53(c)(2) (“Unless stipulated by the parties or ordered by the Board, cross-examination, redirect examination, and re-cross
`examination for uncompelled direct testimony shall be subject to the follow time limits: Seven hours for cross-examination, four
`hours for redirect examination, and two hours for re-cross examination.”) Petitioner certainly plans to be efficient with its
`examination, but cannot at this time say how long the deposition will last and has asked Patent Owner to commit to providing Dr.
`Chaudhary for the time period provided by the rules. Patent Owner has refused to do so.
`
`
`
`3. Patent Owner believes that he can defend Dr. Chaudhary at the deposition. Patent Owner is not an attorney and is not
`registered to practice before the USPTO. As such, Petitioner does not believe that Patent Owner is qualified to defend the
`deposition and allowing him to do so would be inefficient, disruptive to the cross-examination, and prejudicial to Petitioner.
`
`
`
`Second, Petitioner seeks the Board’s guidance with respect to Patent Owner’s behavior. Even after being instructed by the Board
`to exhibit proper decorum, Patent Owner continues to use insulting, personal language that is inappropriate and unnecessary. See
`IPR2020-00260, Paper 11 at 6 (noting that “Patent Owner does not exhibit proper decorum in his email communications with
`Petitioner” and encouraging “Patent Owner to review the Board’s rules and Consolidated Practice Guide, and request[ing] Patent
`Owner refrain from such behavior in the future”). Petitioner seeks leave to submit an example of Patent Owner’s improper behavior
`and regrettably seeks the Board’s guidance on this issue.
`
`
`
`FLEX LOGIX EXHIBIT 1057
`Flex Logix Technologies v. Venkat Konda
`IPR2020-00260
`
`Page 1 of 7
`
`

`

`To the extent the Board deems a call is necessary, Petitioner is available for a call at the Board’s convenience. Patent Owner is
`available [Insert availability]
`
`
`
`Patent Owner’s Positon: [Insert]
`
`
`
`
`
`From: Venkat Konda <venkat@kondatech.com>
`Sent: Friday, December 18, 2020 1:44 AM
`To: Anderson, Paul M. <paulanderson@paulhastings.com>
`Cc: Modi, Naveen <naveenmodi@paulhastings.com>; Jairam, Arvind <arvindjairam@paulhastings.com>; Hsieh, Courtney A.
`<courtneyhsieh@paulhastings.com>; Venkat Konda <venkat@kondatech.com>
`Subject: [EXT] Re: Availability of Dr. Chaudhary for Deposition
`
`
`Mr. Anderson:
`
`1. With respect to the deposition time, it appears to me you are lying big time! Nowhere in this thread, I said Dr Chaudhary and I are available at 9
`AM on December 30, 2020 let alone at 9 AM EST. I challenge you to prove otherwise, if not shut up!
`2. Dr. Chaudhary and I are available at 11 AM PST on December 30, 2020. (read this email thread again)
`3. As I said before, we will abide by the rules.
`4. I repeatedly mentioned Dr. Chadhury's deposition is limited to the scope and content of Dr. Chaudhary's declaration.
`5. I suspect the deposition will be taken on a video conference call. Once you confirm, I will answer follow on questions.
`6. I am representing Dr. Chaudhary at the deposition as a Pro Se Counsel on the IPRs.
`
`Very Truly Yours,
`
`Venkat Konda Ph.D.
`
`
`
`
`
`On Thu, Dec 17, 2020 at 6:33 AM Anderson, Paul M. <paulanderson@paulhastings.com> wrote:
`
`Dr. Konda,
`
`
`
`Thank you for your email.
`
`
`
`With respect to the deposition time, it appears that you agree that you need to make Dr. Chaudhry available for the entire time
`period provided by the rules. Please confirm that we can start his deposition at 9 AM ET on December 30th. Please also let us
`know where in Cleveland the deposition will take place so we can issue a deposition notice.
`
`
`
`As for costs, Rule 42.53 (g) states that “[e]xcept as the Board may order or the parties may agree in writing, the proponent of the
`direct testimony shall bear all costs associated with the testimony, including the reasonable costs associated with making the
`witness available for the cross-examination." The proponent of the direct testimony here is Patent Owner, not Petitioner. In any
`event, the rules provide for costs associated with the court reporter, etc., not the costs you are referring to in your email.
`
`
`
`Finally, we do object to you representing Dr. Chaudhary at his deposition. It seems like you will retain counsel for him to the
`extent you want, but please confirm that you will not be representing him at the deposition.
`
`
`
`If you disagree with any of the above, please let us know and we can seek the Board’s guidance as appropriate.
`
`
`
`Regards,
`
`
`
`Paul
`
`
`
`
`
`From: Venkat Konda <venkat@kondatech.com>
`Sent: Thursday, December 17, 2020 1:16 AM
`To: Anderson, Paul M. <paulanderson@paulhastings.com>
`Cc: Modi, Naveen <naveenmodi@paulhastings.com>; Jairam, Arvind <arvindjairam@paulhastings.com>; Hsieh, Courtney A.
`<courtneyhsieh@paulhastings.com>; Venkat Konda <venkat@kondatech.com>
`Subject: [EXT] Re: Availability of Dr. Chaudhary for Deposition
`
`
`Mr. Anderson:
`
`Page 2 of 7
`
`

`

`1. Firstly, it is Dr. Chaudhary and I are accommodating within the schedule you proposed i.e. December 30, 2020. It is not the other way around
`as you stated.
`2. Secondly, you neither got it nor would not want to get it. I never requested you as you wrote "our (your) intended areas of cross-examination".
`3. Thirdly, I warned you several times in this thread, that Dr. Chaudhary's deposition is limited to the scope and content of Dr. Chaudhary's
`declaration i.e. ¶¶ 27-38 in Exhibit 2025. Anything outside of that will be appropriately objected. After that it is your stupidity of how many
`hours you want to repeatedly ask the same y=1 question for the IPR eligibility of '523 patent.
`4. Fourthly, Dr. Chaudhary will be represented by the Pro Se counsel Dr. Konda.
`5. Fifthly, If you object and prove that Dr. Konda is not qualified as Counsel to represent, we will hire an attorney to represent at the deposition.
`6. Sixthly, 37 CFR § 42.53 (g) states:
`
`1. Costs. Except as the Board may order or the parties may agree in writing, the proponent of the direct testimony shall bear all costs
`associated with the testimony, including the reasonable costs associated with making the witness available for the cross-examination."
`
`7. Accordingly i.e. pursuant to 37 CFR § 42.53 (g), all the costs for Dr. Chaudhary's deposition are on you and your client.
`8. Whether it is Dr. Konda or Dr. Konda & a registered attorney representing Dr. Chaudhary's deposition, one or two people need to travel and
`stay in Cleveland for Dr. Chaudhary's deposition.
`9. Due to Covid-19 and stay-in-place orders, the people (as stated above) travelling and staying in cleveland need to quarantine for appropriate
`duration both ways of travel to Cleveland. You need to bear all these costs pursuant to 37 CFR § 42.53 (g).
`
`Figure out all the above details and make the funds available ASAP upfront, for Dr. Konda to hire a registered attorney soon if needed and make the
`travel/lodging arrangements soon as there is not a lot of time till December 30, 2020. Finally I have sent enough emails on this matter and so you
`need to decide fast of what you want to do on this matter.
`
`
`
`Very Truly Yours,
`
`Venkat Konda Ph.D.
`
`
`
`On Wed, Dec 16, 2020 at 12:49 PM Anderson, Paul M. <paulanderson@paulhastings.com> wrote:
`
`Dr. Konda,
`
`
`
`We are trying to be accommodating of Dr. Chaudhary’s schedule and are willing to hold the deposition on the only day you
`indicate Dr. Chaudhary is available over a three week span. As we previously informed you, the maximum number of hours on
`the record for the deposition is set forth in the rule. The total time that will be required for the deposition depends on many
`factors, some of which relate to how Dr. Chaudhary responds to the questions presented and some of which relate to the
`particular aspects of Dr. Chaudhary’s declaration that Petitioner chooses to cross-examine him on. Needless to say, we are
`under no obligation to inform you in advance of our intended areas of cross-examination.
`
`
`
`Will Dr. Chaudhary be represented by counsel at the deposition? Your emails suggest that you intend to attend the deposition
`as well. Based on our understanding, you are not an attorney and you do not have a registration number for practicing before
`the USPTO, and, as such, you are not qualified to defend Dr. Chaudhary at his deposition.
`
`
`
`Regards,
`
`
`
`Paul
`
`
`
`From: Venkat Konda <venkat@kondatech.com>
`Sent: Wednesday, December 16, 2020 1:16 AM
`To: Anderson, Paul M. <paulanderson@paulhastings.com>
`Cc: Modi, Naveen <naveenmodi@paulhastings.com>; Jairam, Arvind <arvindjairam@paulhastings.com>; Hsieh, Courtney A.
`<courtneyhsieh@paulhastings.com>; Venkat Konda <venkat@kondatech.com>
`Subject: [EXT] Re: Availability of Dr. Chaudhary for Deposition
`
`
`Mr. Anderson:
`
`
`
`First, I am thrilled to know you will take ONLY one deposition that applies to BOTH IPR2020-00260 and -00261. It is so generous of you, Sir.
`
`
`
`However you are not still getting it! Let me break this into separate questions:
`
`1. You seem to have trouble understanding "with respect to Dr. Chaudhary's declaration and its scope in IPRs 2020-00260 and -00261"
`
`1. To understand scope of a declaration refer to § 37 C.F.R. 42.53(d)(5)
`
`2. "How many hours are you planning to take Dr. Chaudhary's deposition" means what is the maximum number of hours?
`
`1. Engineers do this sort of planning all the time. So the direct question to you is given the scope and content of Dr. Chaudhary's
`declaration, how many maximum hours of deposition is going to be according to the rules you are referring to?
`
`1. Of course, Dr. Chaudhary and I need to allocate that maximum number of hours in our schedules, after you respond with
`a direct answer.
`2. BTW, December 30, 2020 is the only day that works for both Dr. Chaudhary and me.
`
`Page 3 of 7
`
`

`

`2. Also I hope you have already read Dr. Chaudhary's deposition. If not please read it first to understand the scope and content of of it
`and then answer my questions.
`
`
`
`Finally of course I agree to follow the rules.
`
`
`
`Very Truly Yours,
`
`Venkat Konda Ph.D.
`
`
`
`On Tue, Dec 15, 2020 at 4:31 PM Anderson, Paul M. <paulanderson@paulhastings.com> wrote:
`
`Dr. Konda,
`
`
`
`At this point I don’t know how long the deposition will take, but the witness needs to be made available for the entirety of the
`time period provided by the rules. There are many factors that will influence the time required for the deposition, and some of
`those involve decisions with respect to the specific questions that will be asked of the witness.
`
`
`
`Regards,
`
`
`
`Paul
`
`
`
`From: Venkat Konda <venkat@kondatech.com>
`Sent: Tuesday, December 15, 2020 6:23 PM
`To: Anderson, Paul M. <paulanderson@paulhastings.com>
`Cc: Modi, Naveen <naveenmodi@paulhastings.com>; Jairam, Arvind <arvindjairam@paulhastings.com>; Hsieh, Courtney A.
`<courtneyhsieh@paulhastings.com>; Venkat Konda <venkat@kondatech.com>
`Subject: [EXT] Re: Availability of Dr. Chaudhary for Deposition
`
`
`Mr. Anderson:
`
`
`
`You did not answer my question. Again here is the question:
`
`1. With respect to Dr. Chaudhary's declaration and its scope in IPRs 2020-00260 and -00261, how many hours are you planning to take Dr.
`Chaudhary's deposition?
`
`
`
`Very Truly Yours,
`
`Venkat Konda Ph.D.
`
`
`
`On Tue, Dec 15, 2020 at 4:00 PM Anderson, Paul M. <paulanderson@paulhastings.com> wrote:
`
`Dr. Konda,
`
`
`
`We are willing to have one deposition that will apply to both IPR2020-00260 and -00261. However, the witness needs to
`be made available for the entirety of the time period provided by the rules.
`
`
`
`Regards,
`
`
`
`Paul
`
`
`
`From: Venkat Konda <venkat@kondatech.com>
`Sent: Tuesday, December 15, 2020 5:07 PM
`To: Anderson, Paul M. <paulanderson@paulhastings.com>
`Cc: Modi, Naveen <naveenmodi@paulhastings.com>; Jairam, Arvind <arvindjairam@paulhastings.com>; Hsieh, Courtney
`A. <courtneyhsieh@paulhastings.com>; Venkat Konda <venkat@kondatech.com>
`Subject: [EXT] Re: Availability of Dr. Chaudhary for Deposition
`
`
`Mr. Anderson:
`
`
`
`Page 4 of 7
`
`

`

`Of course I know § 37 C.F.R. 42.53. With respect to Dr. Chaudhary's declaration and its scope in IPRs 2020-00260 and -00261, how many
`hours are you planning to take Dr. Chaudhary's deposition?
`
`
`
`Very Truly Yours,
`
`Venkat Konda Ph.D.
`
`
`
`On Tue, Dec 15, 2020 at 8:13 AM Anderson, Paul M. <paulanderson@paulhastings.com> wrote:
`
`Dr. Konda,
`
`
`
`Depositions can be lengthy and therefore starting earlier helps to ensure that the deposition can be completed within a
`single day.
`
`
`
`See 37 C.F.R. 42.53(c)(2) (“Unless stipulated by the parties or ordered by the Board, cross-examination, redirect
`examination, and re-cross examination for uncompelled direct testimony shall be subject to the follow time limits: Seven
`hours for cross-examination, four hours for redirect examination, and two hours for re-cross examination.”)
`
`
`
`Regards,
`
`
`
`Paul
`
`
`
`From: Venkat Konda <venkat@kondatech.com>
`Sent: Tuesday, December 15, 2020 2:24 AM
`To: Anderson, Paul M. <paulanderson@paulhastings.com>
`Cc: Modi, Naveen <naveenmodi@paulhastings.com>; Jairam, Arvind <arvindjairam@paulhastings.com>; Hsieh,
`Courtney A. <courtneyhsieh@paulhastings.com>; Venkat Konda <venkat@kondatech.com>
`Subject: [EXT] Re: Availability of Dr. Chaudhary for Deposition
`
`
`Mr. Anderson:
`
`
`
`What is the purpose to start earlier in the day for Dr. Chaudhary's deposition?
`
`
`
`Very Truly Yours,
`
`Venkat Konda Ph.D.
`
`
`
`On Mon, Dec 14, 2020 at 6:08 PM Anderson, Paul M. <paulanderson@paulhastings.com> wrote:
`
`Dr. Konda,
`
`
`
`December 30th will work for the deposition, but a 2pm EST is very late in the day to start a deposition. Is Dr.
`Chaudhary available to start earlier in the day on the 30th? If not, can you please propose a different date where we
`can start earlier?
`
`
`
`Regards,
`
`
`
`Paul
`
`
`
`From: Venkat Konda <venkat@kondatech.com>
`Sent: Saturday, December 12, 2020 10:28 PM
`To: Anderson, Paul M. <paulanderson@paulhastings.com>
`Cc: Modi, Naveen <naveenmodi@paulhastings.com>; Jairam, Arvind <arvindjairam@paulhastings.com>; Hsieh,
`Courtney A. <courtneyhsieh@paulhastings.com>; Venkat Konda <venkat@kondatech.com>
`Subject: [EXT] Re: Availability of Dr. Chaudhary for Deposition
`
`
`Mr. Anderson:
`
`
`
`Page 5 of 7
`
`

`

`Dr. Chaudhary from Cleveland, OH and I from San Jose are available on December 30, 2020 @ 11 AM PST (2 PM EST) for Dr.
`Chaudhary's deposition in IPRs 2020-00260 and -00261.
`
`
`
`Very Truly Yours,
`
`Venkat Konda Ph.D.
`
`
`
`On Fri, Dec 11, 2020 at 1:09 PM Anderson, Paul M. <paulanderson@paulhastings.com> wrote:
`
`Dr. Konda,
`
`
`
`Please let us know Dr. Chaudhary’s availability for a deposition in IPRs 2020-00260 and -00261 during the weeks of December 21,
`28, and January 4. I understand that part of this window of time corresponds to holidays, which is part of the basis for such a large
`window of time.
`
`
`
`Regards,
`
`
`
`Paul Anderson
`
`
`
`<image001.png>
`
`Paul Anderson | Other Attorney
`Paul Hastings LLP | 600 Travis Street, Fifty-Eighth Floor, Houston, TX 77002 | Direct: +1.713.860.7353 | Main:
`+1.713.860.7300 | Fax: +1.713.353.3473 | paulanderson@paulhastings.com | www.paulhastings.com
`
`
`
`
`
`
`
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