`Subject: Re: Solas v. Apple/Motorola, 6:20-cv-00840/00842 (WDTX)
`Date: December 7, 2020 at 1:29 PM
`To: Philip Wang pwang@raklaw.com
`Cc: solas@raklaw.com, Padmanabhan, Nandan nandan.padmanabhan@dlapiper.com, Guaragna, John john.guaragna@dlapiper.com
`, Beale, Kristin kristin.beale@dlapiper.com, Gibson, Erin erin.gibson@dlapiper.com, Lineberry, Alice alice.lineberry@dlapiper.com
`
`Philip,
`I am told the Motorola agreement is complete. By when do you plan on filing the dismissal? We would rather you just file
`that than us ask for another extension to answer.
`For the older Solas case, if you want to ask for a stay of all dates, that would be fine with us.
`Mike
`
`From: Philip Wang <pwang@raklaw.com>
`Sent: Monday, December 7, 2020 12:46:10 PM
`To: Jay, Michael <Michael.Jay@us.dlapiper.com>
`Cc: solas@raklaw.com <solas@raklaw.com>; Padmanabhan, Nandan
`<nandan.padmanabhan@us.dlapiper.com>; Guaragna, John
`<John.Guaragna@us.dlapiper.com>; Beale, Kristin <Kristin.Beale@us.dlapiper.com>;
`Gibson, Erin <Erin.Gibson@us.dlapiper.com>; Lineberry, Alice
`<alice.lineberry@us.dlapiper.com>
`Subject: Re: Solas v. Apple/Motorola, 6:20-cv-00840/00842 (WDTX)
`[EXTERNAL]
`Mike,
`That’s okay with us. We also understand that in the more advanced Solas v. Apple case, we’ll agree to a mutual extension
`of any discovery responses due before resolution.
`Philip
`Philip Wang
`Russ August & Kabat
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, CA 90025
`310 826-7474
`pwang@raklaw.com
`
`On Dec 7, 2020, at 10:53 AM, Jay, Michael <michael.jay@dlapiper.com> wrote:
`Philip,
`Given the pending settlement, we intend to ask for an additional three weeks—to
`December 30—to respond to the Complaints in the Apple and Motorola actions. Let me
`know if Solas agrees. Thanks.
`Mike
`Michael Jay
`Partner
`
`T +1 310 595 3140
`F +1 310 595 3315
`M +1 310 487 9250
`
`LG DISPLAY V. SOLAS
`IPR2020-01238
`Exhibit 2012
`Page 1
`
`
`
`M +1 310 487 9250
`michael.jay@us.dlapiper.com
`
`DLA Piper LLP (US)
`dlapiper.com
`
`From: Jay, Michael
`Sent: Tuesday, November 17, 2020 1:07 PM
`To: Philip Wang <pwang@raklaw.com>
`Cc: solas@raklaw.com; Padmanabhan, Nandan
`<nandan.padmanabhan@us.dlapiper.com>; Guaragna, John
`<John.Guaragna@us.dlapiper.com>; Beale, Kristin <Kristin.Beale@us.dlapiper.com>;
`Gibson, Erin <Erin.Gibson@us.dlapiper.com>
`Subject: Solas v. Apple/Motorola, 6:20-cv-00840/00842 (WDTX)
`
`Philip,
`
`Given the present circumstances, we would like an additional three weeks—until
`December 16— for Apple and Motorola to respond to the Complaints in the recently-
`filed WDTX actions. Please let me know if Solas will agree. Thanks.
`
`Mike
`
`Michael Jay
`Partner
`
`T +1 310 595 3140
`F +1 310 595 3315
`M +1 310 487 9250
`michael.jay@us.dlapiper.com
`
`DLA Piper LLP (US)
`dlapiper.com
`
`
`The information contained in this email may be confidential and/or legally privileged. It has been sent for the sole use of the
`intended recipient(s). If the reader of this message is not an intended recipient, you are hereby notified that any unauthorized
`review, use, disclosure, dissemination, distribution, or copying of this communication, or any of its contents, is strictly
`prohibited. If you have received this communication in error, please reply to the sender and destroy all copies of the message.
`To contact us directly, send to postmaster@dlapiper.com. Thank you.
`
`The information contained in this email may be confidential and/or legally privileged. It has been sent for the sole use of the
`intended recipient(s). If the reader of this message is not an intended recipient, you are hereby notified that any unauthorized
`review, use, disclosure, dissemination, distribution, or copying of this communication, or any of its contents, is strictly prohibited.
`If you have received this communication in error, please reply to the sender and destroy all copies of the message. To contact us
`directly, send to postmaster@dlapiper.com. Thank you.
`
`LG DISPLAY V. SOLAS
`IPR2020-01238
`Exhibit 2012
`Page 2
`
`
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