`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Hartmann, H. Michael
`Monday, April 27, 2020 6:07 PM
`jennifer.tempesta@bakerbotts.com
`Paul.Ragusa@BakerBotts.com; Wittmann, Robert T.; Mueller, Wesley
`RE: VARTA v. PEAG LLC (E.D.Tex. No. 2:20-71) and VARTA v. Audio Partnership LLC
`(N.D.Ill. No. 1:20-1568)
`
`Thank you for your call and the note, Jennifer. As I indicated, I will raise these matters with the client at the earliest
`possible time, and hope to have further word in a few days.
`
`Mike
`
`H. Michael Hartmann, Sr. | Leydig, Voit & Mayer, Ltd.
`Attorney at Law | Intellectual Property
`Two Prudential Plaza | Suite 4900 | Chicago, IL 60601-6731 USA
`Liebigstrasse 51 | Frankfurt am Main 60323 | Germany
`Chicago: + 1 312 616 5635 | Frankfurt: +49 69 713 7798 0 | cell: +1 630 399 9000
`Chicago | Alexandria, VA | Boulder, CO | Frankfurt am Main | San Francisco Bay Area
`
`This communication is private and confidential, and may contain material that is privileged and/or exempt from disclosure under applicable law. If you have received this
`communication in error, please notify me immediately and delete the original and all copies of this communication. Thank you.
`
`From: jennifer.tempesta@bakerbotts.com <jennifer.tempesta@bakerbotts.com>
`Sent: Monday, April 27, 2020 2:37 PM
`To: Hartmann, H. Michael <mhartmann@leydig.com>
`Cc: Paul.Ragusa@BakerBotts.com
`Subject: VARTA v. PEAG LLC (E.D.Tex. No. 2:20‐71) and VARTA v. Audio Partnership LLC (N.D.Ill. No. 1:20‐1568)
`
`Michael,
`
`Thank you for taking the time to discuss the above‐referenced matters earlier today. As discussed, we represent
`defendants PEAG LLC d/b/a JLab Audio and Audio Partnership LLC d/b/a Cambridge Audio in these matters. As I
`indicated on the call, we propose that the parties in the Audio Partnership case in Illinois file an unopposed or joint
`motion to transfer to the E.D. Tex. and seek consolidation of the Audio Partnership action with the PEAG action in
`Texas. We view this as the most efficient approach since the accused products in these actions are the same. Please let
`us have your position on this proposal. If VARTA agrees, we will prepare a draft filing for your review.
`
`In line with the goal of having the PEAG and Audio Partnership cases on the same schedule, we relatedly seek your
`approval to file an unopposed application for extension of time to answer in the PEAG case for a period of 30 days while
`we work to get the Audio Partnership case transferred and consolidated. PEAG’s response to the complaint is currently
`due to be filed on April 29.
`
`Please let us have your views on the above at your earliest convenience, and let me know if a further call would be
`helpful to discuss any of the above.
`
`Regards,
`Jennifer
`
`1
`
`VARTA Ex. 2001 Page 1 of 2
`PEAG/Audio Partnership v. VARTA
`IPR2020-01212
`
`
`
`Jennifer Tempesta
`Partner
`Baker Botts L.L.P.
`jennifer.tempesta@bakerbotts.com
`T +1.212.408.2571
`M +1.347.860.2752
`
`30 Rockefeller Plaza
`New York, NY 10112
`USA
`
`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
`
`VARTA Ex. 2001 Page 2 of 2
`
`
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