From:
`To:
`Cc:
`
`Subject:
`Date:
`
`Cecil Key
`Nash, Brian C.; Jay Kesan; Trials
`Finkel, Evan; Hindman, Matthew W.; Gartman, Cody A.; Intel-SRC; Ari Rafilson (arafilson@shorechan.com);
`Henning Schmidt
`RE: Intel v. FG SRC, IPR2020-01449: Patent Owner"s Request to Schedule a Conference Call
`Thursday, May 20, 2021 3:40:17 PM
`
`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before
`responding, clicking on links, or opening attachments.
`
`Your Honors:
`
`Patent Owner objects to the argumentative nature of Petitioner’s email in response to a simple
`request for guidance on the current procedures. Patent Owner will, however, be prepared to
`address the substance of the issues Petitioner seeks to raise during the May 24, 2021 telephone
`conference should the Board so desire.
`
`Cecil E. Key
`DGKeyIp Group
`1750 Tysons Blvd., Suite 1500
`Tysons Corner, Virginia 22102
`Phone: 703-289-5118
`Fax: 703-388-0648
`Cell: 703-472-5976
`Email: ckey@dimuro.com
`
`
`
`From: Nash, Brian C. <brian.nash@pillsburylaw.com>
`Sent: Thursday, May 20, 2021 12:12 PM
`To: Jay Kesan <jay@jaykesan.com>; Trials <Trials@USPTO.GOV>
`Cc: Finkel, Evan <evan.finkel@pillsburylaw.com>; Hindman, Matthew W.
`<matthew.hindman@pillsburylaw.com>; Gartman, Cody A. <cody.gartman@pillsburylaw.com>;
`Intel-SRC <Intel-SRC@Pillsburylaw.com>; Cecil Key <CKey@dimuro.com>; Ari Rafilson
`(arafilson@shorechan.com) <arafilson@shorechan.com>; Henning Schmidt
`<hschmidt@dimuro.com>
`Subject: RE: Intel v. FG SRC, IPR2020-01449: Patent Owner's Request to Schedule a Conference Call
`
`Dear Board,
`
`To clarify Petitioner’s position, Petitioner has repeatedly asked Patent Owner to identify what exactly
`it is requesting from the Board, but Patent Owner would not do so beyond suggesting that it might
`want to take depositions if the Motion to Supplement is granted. Patent Owner’s stated “request”
`below is similarly noncommittal. Petitioner is not opposed to a conference with the Board, but
`Petitioner is not able to take a position on PO’s request without knowing what is being requested.
`
`

`

`Patent Owner has had ample opportunity to take depositions and to prepare its Response and
`Motion to Amend within the time frame provided by the Scheduling Order (i.e., by May 26), and the
`parties have been aware of the timing on the Motion to Supplement for over a month.
`
`Best regards,
`
`Brian Nash
`Counsel for Petitioner Intel Corporation
`
`
`Brian C. Nash | Partner
`Pillsbury Winthrop Shaw Pittman LLP
`401 Congress Avenue, Suite 1700 | Austin, TX 78701-3797
`t +1.512.580.9629
`brian.nash@pillsburylaw.com | website bio
`
`
`From: jay jaykesan.com <jay@jaykesan.com>
`Sent: Tuesday, May 18, 2021 10:15 PM
`To: Trials <Trials@USPTO.GOV>
`Cc: Nash, Brian C. <brian.nash@pillsburylaw.com>; Finkel, Evan <evan.finkel@pillsburylaw.com>;
`Hindman, Matthew W. <matthew.hindman@pillsburylaw.com>; Gartman, Cody A.
`<cody.gartman@pillsburylaw.com>; Intel-SRC <Intel-SRC@Pillsburylaw.com>; Cecil Key
`<CKey@dimuro.com>; Ari Rafilson (arafilson@shorechan.com) <arafilson@shorechan.com>;
`Henning Schmidt <hschmidt@dimuro.com>
`Subject: Intel v. FG SRC, IPR2020-01449: Patent Owner's Request to Schedule a Conference Call
`
`Your Honors:
` Patent Owner requests a conference call with the Board as soon as possible to obtain the
`Board’s guidance regarding the current schedule in light of the Board’s pending decision on
`Petitioner’s Motion to Submit Supplemental Information.
`In accordance with the Board’s Order governing the Conduct of the Proceeding (Paper No.
`18), briefing by both parties on Petitioner’s Motion to Submit Supplemental Information is complete
`as of May 12, 2021.
`Currently, Patent Owner’s Response and Motion to Amend are due on May 26, 2021, and
`whether Patent Owner will seek additional depositions at this stage depends on the Board’s ruling
`on Petitioner’s Motion to Submit Supplemental Information.
`As such, Patent Owner respectfully seeks guidance from the Board on when a ruling on
`Petitioner’s Motion might be expected. In addition, Patent Owner may seek an extension of the due
`date for its Patent Owner Response and Motion to Amend based on the guidance that we receive
`from the Board.
`Petitioner has indicated that it may or may not oppose this request. Accordingly, in light of
`the upcoming May 26, 2021 deadline, Patent Owner respectfully requests a conference call at the
`Board’s earliest convenience to address this request.
`Best regards.
`
`

`

`--Jay Kesan.
`Counsel for Patent Owner, FG SRC.
`
`Jay P. Kesan
`DGKeyIp Group
`1750 Tysons Blvd., Suite 1500
`Tysons Corner, Virginia 22102
`Phone: 703-289-5118
`Cell: 217-377-9905
`
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