6/11/2020
`
`konda technologies Inc . Mail - Re: PGR2019-00037, -00042 - Transcript by your Court Reporter on May 27, 2020 Conference call with the Board
`
`Venkat Konda <venkat@kondatech.com>
`
`Re: PGR2019-00037, -00042 - Transcript by your Court Reporter on May 27, 2020
`Conference call with the Board
`
`Anderson, Paul M. <paulanderson@paulhastings.com>
`To: Venkat Konda <venkat@kondatech.com>
`Cc: "Modi, Naveen" <naveenmodi@paulhastings.com>, FlexLogix Konda PGR <PH-FlexLogix-Konda-
`PGR@paulhastings.com>
`
`Thu, Jun 11, 2020 at 7:17 AM
`
`Dr. Konda,
`
`We have not yet received the transcript from the court reporter and therefore have not yet submitted it. If you would like to
`pay for expedited service in the future, please let us know. You are also welcome to pay for and provide a court reporter
`for future Board calls if you feel having not having a transcript In an expedited manner is somehow prejudicial to you.
`
`We will submit the transcript of the call in a timely manner once it has been received.
`
`Regards,
`
`Paul Anderson
`
`On Jun 10, 2020, at 8:45 PM, Venkat Konda <venkat@kondatech.com> wrote:
`
`Mr. Modi, Mr. Anderson:
`
`You did not file the transcript by your Court Reporter of May 27, 2020 Conference call with the Board as an exhibit per the
`Patent Trial and Appeal Board Consolidated Trial Practice Guide November 2019 at Page 10 as follows:
`"If a court reporter is present for the conference call, the party that retained the court reporter should notify the panel at
`the beginning of the call that a reporter is on the line, and shall file the transcript of the call as an exhibit to the proceeding
`within one week of receiving the transcript."
`
`Patent Owner is severely prejudiced by your delay for more than two weeks, Or are you not willing to submit it?
`Please let me know by 11 AM EDT tomorrow (June 11, 2020).
`
`Sincerely,
`Venkat Konda
`Pro se Patent Owner
`Email: venkat@kondatech.com<mailto:venkat@kondatech.com>
`Cell # 408-472-3273
`
`On Tue, May 26, 2020 at 11:16 AM Venkat Konda <venkat@kondatech.com<mailto:venkat@kondatech.com>> wrote:
`During the conference call on December 3, 2019 regarding requirement for Patent Owner to confer with the Board before
`filing a motion to amend, Board directed the parties to the Board’s order in Lectrosonics, Inc. v. Zaxcom, Inc., Case
`IPR2018-01129, Paper 15 (PTAB Feb. 25, 2019) (precedential). See. e.g., Paper 15 in PGR2019-00037. Lectrosonics,
`Inc. Paper 15 provides guidelines in Section 8. Duty of Candor in pages 9-10. Accordingly, the Patent Owner on May 20,
`2020 filed motion to exclude pursuant to 37 C.F.R. § 42.64, 37 C.F.R. § 42.11 and 37 C.F.R. § 42.51(b)(iii).
`
`In the motions to exclude filed on May 20, 2020, Patent Owner objected that Dr. Baker is not a person of ordinary skill in
`the art based on his own admission in his declarations that he has no experience even in the networks (which is what the
`petitions defined as a POSITA). For example See PGR219-00037 Exhibit 1002 ¶3 and Paper 1, at 6. He expressly stated
`that he is a person skilled in the field of "integrated circuits and memory devices," not a person skilled in the applicable
`field of networks according to your definition of POSITA in the petitions.
`
`Patent Owner respectfully requests the Board to consider the motions to exclude filed by Patent Owner on May 20, 2020.
`
`Very respectfully,
`Venkat Konda
`Pro Se Patent Owner
`
`https://mail.google.com/mail/u/1?ik=bb0abc28e6&view=pt&search=all&permmsgid=msg-f%3A1669212471708576576&simpl=msg-f%3A1669212471708576576&… 1/3
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`Page 1 of 3 IPR2020-00260
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`6/11/2020
`
`konda technologies Inc . Mail - Re: PGR2019-00037, -00042 - Transcript by your Court Reporter on May 27, 2020 Conference call with the Board
`
`On Tue, May 26, 2020 at 6:19 AM Modi, Naveen <naveenmodi@paulhastings.com<mailto:naveenmodi@
`paulhastings.com>> wrote:
`As the Board is aware, Patent Owner filed a revised motion to amend in the above-mentioned proceedings. Petitioner
`understands that the Board will be entering a revised schedule in light of the revised motion. Petitioner would appreciate
`the Board providing an indication as to when such a schedule will be entered.
`
`In addition, Petitioner requests leave to file a motion to expunge the motions to exclude and associated exhibits that
`Patent Owner filed in these proceedings on May 20, 2020. Specifically, Patent Owner filed motions to exclude in each
`proceeding, seeking to exclude the testimony of Petitioner’s expert, Dr. Baker. See, e.g., Paper 27 in PGR2019-00037.
`Petitioner believes that the motions are improper as Patent Owner never objected to Dr. Baker’s testimony within the
`timeframe allowed by the Board’s rules. See 37 C.F.R. § 42.64.
`
`Petitioner conferred with Patent Owner, who is pro se, and asked if he was willing to withdraw the motions. Patent Owner
`indicated he was unwilling to withdraw the motions. As such, Petitioner seeks leave to file a motion to expunge in each
`proceeding.
`
`Should the Board wish to have a call regarding the issues mentioned above, Petitioner can seek Patent Owner’s
`availability and provide that to the Board.
`
`Respectfully,
`Naveen Modi
`Counsel for Petitioner
`
`__________________________________________________________________________________________
`
`[Paul Hastings LLP]<http://www.paulhastings.com/>
`
`Naveen Modi | Partner and Global Vice Chair of Intellectual Property, Litigation Department
`Paul Hastings LLP | 875 15th Street, N.W., Washington, DC 20005 | Direct: +1.202.551.1990 | Main: +1.202.551.1700 |
`Fax: +1.202.551.0490 | naveenmodi@paulhastings.com<mailto:naveenmodi@paulhastings.com> |
`www.paulhastings.com<http://www.paulhastings.com/>
`
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`Page 2 of 3 IPR2020-00260
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`VENKAT KONDA EXHIBIT 2019
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`

`

`konda technologies Inc . Mail - Re: PGR2019-00037, -00042 - Transcript by your Court Reporter on May 27, 2020 Conference call with the Board
`6/11/2020
`This message is sent by a law firm and may contain information that is privileged or confidential. If you received
`this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments.
`If you reply to this message, Paul Hastings may collect personal information including your name, business name
`and other contact details, and IP address. For more information about Paul Hastings’ information collection, privacy
`and security principles please click HERE. If you have any questions, please contact Privacy@paulhastings.com.
`
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`Page 3 of 3 IPR2020-00260
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`VENKAT KONDA EXHIBIT 2019
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