`To:
`Cc:
`Subject:
`Date:
`
`Trials
`Goodson, Timothy; Jurgovan, Jon; Weatherly, Mitchell
`Trials
`FW: Case Nos. IPR2020-01556 // IPR2020-01557
`Monday, October 18, 2021 1:36:20 PM
`
`Please see below
`
`Thanks
`Andrew
`
`From: Thomas, Henry C. <HThomas@willkie.com>
`Sent: Monday, October 18, 2021 1:53 PM
`To: Trials <Trials@USPTO.GOV>
`Cc: 'tpowers-PTAB@sternekessler.com' <tpowers-PTAB@sternekessler.com>; 'dyonan-
`PTAB@sternekessler.com' <dyonan-PTAB@sternekessler.com>; 'dbanowit-
`PTAB@sternekessler.com' <dbanowit-PTAB@sternekessler.com>; 'kconklin-
`PTAB@sternekessler.com' <kconklin-PTAB@sternekessler.com>; 'toneill-PTAB@sternekessler.com'
`<toneill-PTAB@sternekessler.com>; 'jbuchanan-PTAB@sternekessler.com' <jbuchanan-
`PTAB@sternekessler.com>; 'gphero-PTAB@sternekessler.com' <gphero-PTAB@sternekessler.com>;
`'PTAB@sternekessler.com' <PTAB@sternekessler.com>; Babbitt, Michael G.
`<MBabbitt@willkie.com>; ProvisurTeam@willkie.com
`Subject: Case Nos. IPR2020-01556 // IPR2020-01557
`
`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, Provisur Technologies, Inc., respectfully requests authorization to file a motion to
`strike the following Petitioner Reply sections and Exhibit sections:
`
`
`• From IPR2020-01556 and IPR2020-01557: Pet. Reply Sections III.A.2.b and IV.2; Ex. 1051
`(Declaration of Richard Hooper) ¶61;
`• From IPR2020-01556 and IPR2020-01557: Pet. Reply (-01556) Section V.4; Pet. Reply
`(-01557) Section V.A.5; Ex. 1051 (-01556), ¶¶104-107; Ex. 1051 (-01557), ¶¶95-98; Ex. 1060,
`¶ 36; Ex. 1088;
`• From IPR2020-01556: Pet. Reply Sections V.3 and V.4; Ex.1051, ¶¶95-107;
`• From IPR2020-01557: Pet. Reply Section VI; Ex. 1051, ¶ 108.
`
`These sections of Petitioner’s Replies, and the evidence to which they cite, improperly raise new
`arguments and are based on belatedly presented evidence.
`
`Petitioner opposes a motion to strike. If the Board believes a conference call is necessary, the
`parties have conferred and are available for a call on Wednesday (10/20) from 12pm-2pm and
`Thursday (10/21) from 9am-12pm. Patent Owner’s Sur-Reply is due Nov. 2.
`
`
`
`
`Regards,
`Henry Thomas
`(pro hac vice forthcoming),
`On behalf of Mike Babbitt
`(Lead Counsel for Patent Owner Provisur)
`
`
`Henry C. Thomas
`Willkie Farr & Gallagher LLP
`300 North LaSalle Dr. | Chicago, IL 60654-3406
`Direct: +1 312 728 9021 | Fax: +1 312 728 9199
`hthomas@willkie.com | vCard | www.willkie.com bio
`
`
`
`Important Notice: This email message is intended to be received only by persons entitled to receive the
`confidential information it may contain. Email messages to clients of Willkie Farr & Gallagher LLP
`presumptively contain information that is confidential and legally privileged; email messages to non-
`clients are normally confidential and may also be legally privileged. Please do not read, copy, forward or
`store this message unless you are an intended recipient of it. If you have received this message in error,
`please forward it back. Willkie Farr & Gallagher LLP is a limited liability partnership organized in the
`United States under the laws of the State of Delaware, which laws limit the personal liability of partners.
`
`

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