`To:
`Cc:
`Subject:
`Date:
`
`Trials
`Dougal, Brent; Ullagaddi, Monica; Moore, Bryan
`Trials
`FW: IPR2020-00905 and IPR2020-00906 - request to expunge mistaken filings
`Wednesday, August 26, 2020 4:11:42 PM
`
`Please see below
`
`Thanks
`Andrew
`
`From: Neil Rubin <nrubin@raklaw.com>
`Sent: Wednesday, August 26, 2020 6:50 AM
`To: Trials <Trials@USPTO.GOV>
`Cc: Michael Parsons IPR <michael.parsons.ipr@haynesboone.com>; Andy Ehmke IPR
`<andy.ehmke.ipr@haynesboone.com>; Jordan Maucotel IPR
`<jordan.maucotel.ipr@haynesboone.com>; corephotonics@raklaw.com
`Subject: IPR2020-00905 and IPR2020-00906 - request to expunge mistaken filings
`
`Dear Honorable Board,
`
` I
`
` represent patent owner Corephotonics in IPR2020-00905 and IPR2020-00906.
`
`
`Due to clerical error, incorrect versions of patent owner Corephotonics’ preliminary responses
`were filed on August 13, 2020 in each of these two IPRs. The incorrect documents were filed
`as Paper 7 in each IPR. The error was identified immediately, and correct versions of each
`preliminary response were filed timely and appear as Paper 8 in each IPR.
`
`To avoid confusion, Corephotonics wishes to have the incorrect filings expunged in each case.
`We have asked counsel for Apple whether Apple opposes expunging these documents, and
`they have indicated that Apple will not take a position one way or another on this issue.
`
`We request the Board’s guidance on the procedure for expunging these documents (Paper 7 in
`each of IPR2020-00905 and IPR2020-00906). To the extent that a formal motion to expunge
`is required, we request leave to file such a motion.
`
`Best regards,
`
`
`Neil A. Rubin
`
`RUSS AUGUST & KABAT | 12424 Wilshire Boulevard, 12th Floor | Los Angeles, CA 90025
`Main +1 310 826 7474 | Direct +1 310 979 8252 | nrubin@raklaw.com | www.raklaw.com
`
`
`
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