`From:
`Trey Powers <TPOWERS@sternekessler.com>
`Sent:
`Friday, June 11, 2021 4:10 PM
`To:
`Stavinoha, Clarke; Mark Walters; Jason Fitzsimmons; Steve Merrill; bamert@lowegrahamjones.com;
`PTAB Account
`Wille, David; Walters, Chad; jperkins@perkinsip.com; PTAB Account; PTAB Account
`RE: IPR2020-01139, -01142 - Petitioner's Opposition to Patent Owner's Motion for Entry of Modified
`Protective Order
`
`Cc:
`Subject:
`
`[EXTERNAL EMAIL]
`
`Clarke,
`
`
`To our knowledge, you never inquired into the status of Yita’s in‐house counsel or plans to obtain in‐house counsel in
`any previous discussions. In any event, whether Yita currently has in‐house counsel or not is irrelevant to MacNeil’s
`attempts to exclude “Parties” from MacNeil’s proposed modified protective order. We note again that MacNeil moved
`to enter its modified protective order without meaningful discussion with Yita. And Yita is well‐within its right to oppose
`a protective order that would prevent any Yita in‐house counsel, now or in the future, from accessing MacNeil
`information alleged to be material to patentability.
`
`
`Regards,
`Trey
`
`
`
`R. Wilson “Trey” Powers III, Ph.D.
`Director
`Sterne, Kessler, Goldstein & Fox P.L.L.C.
`Email: tpowers@sternekessler.com
`Direct: 202.772.8876
`
`Administrative Assistant: Cheryl Wagner
`Direct: 202.772.8961 Main: 202.371.2600
`
`
`From: Stavinoha, Clarke <clarke.stavinoha@BakerBotts.com>
`Sent: Wednesday, June 9, 2021 11:26 AM
`To: Mark Walters <walters@lowegrahamjones.com>; Trey Powers <TPOWERS@sternekessler.com>; Jason Fitzsimmons
`<JFITZSIMMONS@sternekessler.com>; Steve Merrill <SMERRILL@sternekessler.com>; bamert@lowegrahamjones.com;
`PTAB Account <PTAB@sternekessler.com>
`Cc: Wille, David <david.wille@bakerbotts.com>; Walters, Chad <chad.walters@bakerbotts.com>;
`jperkins@perkinsip.com; PTAB Account <PTAB@sternekessler.com>; PTAB Account <PTAB@sternekessler.com>
`Subject: IPR2020‐01139, ‐01142 ‐ Petitioner's Opposition to Patent Owner's Motion for Entry of Modified Protective
`Order
`
`
`EXTERNAL EMAIL: Use caution before clicking links or attachments.
`
`
`
`Mark,
`
`
`Your opposition papers refer to in‐house counsel for Yita. You have never mentioned any in‐house counsel for Yita
`previously during our discussions of the protective order. Nor do you identify any in‐house counsel in your papers. Who
`is the in‐house counsel?
`
`
`Thanks,
`
`1
`
`MacNeil Exhibit 2139
`Yita v. MacNeil IP, IPR2020-01139
`Page 1
`
`
`
`Clarke
`
`
`Clarke Stavinoha
`Senior Associate
`
`
`Baker Botts L.L.P.
`clarke.stavinoha@bakerbotts.com
`T +1.214.953.6484
`F +1.214.661.4484
`M +1.214.793.0114
`
`
`2001 Ross Avenue
`Suite 900
`Dallas, Texas 75201
`
`
`
`
`Confidentiality Notice:
`
`The information contained in this email and any attachments is intended only for the recipient[s] listed above and may be privileged
`and confidential. Any dissemination, copying, or use of or reliance upon such information by or to anyone other than the recipient[s]
`listed above is prohibited. If you have received this message in error, please notify the sender immediately at the email address
`above and destroy any and all copies of this message.
`
`2
`
`MacNeil Exhibit 2139
`Yita v. MacNeil IP, IPR2020-01139
`Page 2
`
`
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