From:
`To:
`Cc:
`Subject:
`Date:
`
`Kerry.Taylor
`Trials
`John P White; Murnane, John D.; Oliver, Justin J.; ggershik@cooperdunham.com; BoxIllumina
`IPR2020-01065, -01125, and -01177 - Request for Reply Briefing
`Friday, October 30, 2020 7:12:12 PM
`
`Dear Members of the Board,
`
`Petitioner Illumina requests authorization from the Board to file a Reply brief in each of IPR2020-
`01065, -01125, and -01177 (Illumina v. Columbia). Petitioner requests a 5-page Reply on the same
`topics for which the Board authorized Reply briefing in the closely related matter of IPR2020-00988.
`Those topics concern discretionary denial under 314(a) and 325(d), as well as claim construction of
`the term “chemical linker.” Also, Illumina requests authorization to submit non-testimonial exhibits
`in the same manner that the Board authorized in IPR2020-00988.
`
`Good cause exists for Petitioner to address Patent Owner’s arguments concerning 314(a) and the
`state of the parallel district court litigation, as well as Patent Owner’s theories under 325(d) and its
`characterizations of Sanger sequencing and Hiatt. Good cause also exists for Petitioner to address
`the statements raised in Patent Owner’s Preliminary Responses concerning whether the term
`"chemical linker" requires construction in view of the District Court’s Markman Order.
`
`The parties have conferred. Patent Owner opposes Petitioner’s request.
`
`Counsel for Patent Owner is included on this email. The parties are available for a teleconference
`with the Board, if necessary, on:
`Tuesday 11/3 from 10:00 AM-1:00 PM and 2:00-6:00 PM Eastern Time;
`Wednesday 11/4 from 10:00 AM-12:00 PM and 3:00-6:00 PM Eastern Time;
`Thursday 11/5 from 10:00-11:00 AM and 2:30-6:00 PM Eastern Time; and
`Friday 11/6 from 10:00 AM-6:00 PM Eastern Time.
`
`Regards,
`
`Kerry Taylor
`Partner
`Kerry.Taylor@knobbe.com
`(858) 707-4000 Main
`Knobbe Martens
`12790 El Camino Real
`San Diego, CA 92130
`www.knobbe.com/kerry-taylor
`
`IPR2020-01065, -01125, -01177
`Ex. 3001
`
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