Joe Edell
`Trials
`Allan Bullwinkel; Michael Heim; McKeown, Scott; Rowland, Mark D.; Radsch, Andrew; Batchelder, James R.;
`Adam Allgood
`IPR2020-00335-00338 & IPR2020-00485-00486
`Monday, July 6, 2020 10:21:26 AM
`
`From:
`To:
`Cc:
`
`Subject:
`Date:
`
`Trials:
`
`In view of Patent Owner’s reliance on Dr. Kevin Almeroth in its Patent Owner’s Preliminary
`Responses in IPR2020-00335, -00336, -00337, -00338, -00339, -00485, and -00486, Petitioner
`Juniper Networks seeks authorization from the assigned panel to file a 15-page page motion to
`disqualify Dr. Almeroth from the ongoing IPRs. Juniper previously retained Dr. Almeroth and supplied
`him with confidential and privileged information relevant to these IPRs. Juniper has filed a motion to
`disqualify Dr. Almeroth in the district court case, which remains pending (Dkt. No. 55 in Packet
`Intelligence LLC v. Juniper Networks, Inc., Case No. 3:19-cv-04741-WHO (N.D. Cal.)). Juniper is
`amenable to filing the motion to disqualify Dr. Almeroth at this point in the IPR proceedings or
`waiting until after a decision is made regarding institution, whichever the assigned panel prefers.
`Juniper also anticipates that it will need to file confidential information along with its motion and
`seeks authorization to file a Protective Order allowing confidential information to be designated as
`Attorneys’ Eyes Only.
`
`Juniper has conferred with Patent Owner’s counsel. During that conference, Juniper proposed that
`the parties agree to be bound by the district court’s ruling on this issue. Patent Owner did not agree
`to this proposal. Patent Owner also did not agree to Juniper’s requests for authorization to file the
`motion to disqualify or to enter a protective order.
`
`A conference call is requested to resolve these issues. The parties have conferred and are available
`July 13 (11am-3pm ET), and can confer on additional times next week if the Board prefers.
`
`Best regards,
`Joe Edell
`Counsel for Petitioner Juniper Networks, Inc.
`
`Joseph Edell | Fisch Sigler LLP | Attorney
`+1.202.362.3524 (o)
`+1.301.806.7562 (m)
`
`5301 Wisconsin Avenue NW, Fourth Floor
`Washington, DC 20015 USA
`Biography | Firm Victories | LinkedIn
`
`IPR2020-00335, -00336, -00337,-00485
`Ex. 3003
`
`