`To:
`Cc:
`Subject:
`Date:
`
`Henning Schmidt
`Trials
`Nash, Brian C.; Intel-SRC; Cecil Key; Ari Rafilson (arafilson@shorechan.com); Henning Schmidt; Jay Kesan
`IPR2020-01449 -- Request for Authorization to Obtain Additional Discovery
`Friday, June 18, 2021 12:23:49 AM
`
`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 requests permission from the Board to file a Motion for Additional Discovery
`pursuant to 37 C.F.R. § 42.52. Specifically, Patent Owner seeks to obtain a subpoena for testimony
`pursuant to 35 U.S.C. § 24 to the primary author, Mr. Zhang, of the primary prior art reference
`(Zhang, EX1003) underlying every ground for invalidation for all of the challenged claims. Patent
`Owner requests a waiver of the requirement to file a formal Motion for Additional Discovery in order
`to obtain the requested discovery in time for the Patent Owner Response or Patent Owner Sur-reply.
`
`
`Petitioner has indicated that it opposes Patent Owner’s request. Accordingly, Patent Owner
`respectfully requests a conference call at the Board’s earliest convenience. Patent Owner has
`conferred with Petitioner, and both parties are available for a call at the following times:
`Monday 6/21: between 12-1pm ET
`Tuesday 6/22: after 3pm ET
`Wednesday 6/23: between 2:30pm to 4pm ET
`
`
`Sincerely,
`
`
`Henning Schmidt, Esq
`KeyIPLaw Group, PLLC
` Counsel for Patent Owner FG SRC LLC
`
`Inglewood Business Center
`1502 Inglewood, B
`Austin, TX, 78741
`(: (512) 826-7067
`*: Henning@KeyIPLaw.com
`Confidentiality: The information contained in this e-mail and any attachments is confidential and privileged information and intended
`only for the use of the individual or entity to whom it is intended. This e-mail and any attachments are or may constitute information
`which is confidential and privileged as an attorney-client communication and/or as attorney work product. If the reader of this e-mail is
`not the intended recipient, or the employee or agent responsible to deliver this communication to the intended recipient, you are hereby
`notified that any distribution, copying, or use of this communication, electronic or otherwise, is strictly prohibited. Furthermore, we
`expressly reserve and do not waive any privilege. If you have received this communication in error, please notify us immediately by
`telephone or by reply to the sender via e-mail, and please delete this e-mail and any accompanying attachments from your inbox, recycle
`bin, and any other directory, file, or electronic storage. Thank you for your cooperation.
`
`
`
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`
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