`To:
`Cc:
`Subject:
`Date:
`Attachments:
`
`Joel Glazer
`Trials
`oceansemi-dlf; Sano, Jeannine; ekrause@axinn.com; plee@axinn.com; Applied-Ocean@axinn.com; Joseph Zito
`Applied Materials v. Ocean, IPR2021-01339, -01340, -01342, and -01344
`Monday, August 15, 2022 8:28:20 PM
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`
`Dear Honorable Board,
`
`Patent Owner Ocean Semiconductor LLC seeks to notify the Board of a discovery impasse between
`Patent Owner Ocean Semiconductor LLC and Petitioner Applied Materials, Inc. regarding four
`pending IPRs; namely:
`
`
`1. IPR2021-01339 (Patent No. 8,676,538);
`2. IPR2021-01340 (Patent No. 6,725,402);
`3. IPR2021-01342 (Patent No. 6,968,248); and
`4. IPR2021-01344 (Patent No. 6,907,305).
`
`
`On July 28, 2022, Patent Owner contacted Petitioner to schedule depositions of Petitioner’s two
`expert witnesses whose expert declarations are being relied upon by Petitioner in its Reply to Patent
`Owner’s Response. Petitioner refused to produce its two experts for deposition on the purported
`basis that they are not “reply witnesses” and that Petitioner did not submit any “new expert
`declaration.” Petitioner, however, left open the door to reconsidering Patent Owner’s request
`subject to additional authorities on this issue, which Patent Owner provided on August 2 and August
`3, 2022. On August 9, 2022, Patent Owner served notices of deposition in the above-referenced
`actions. On August 10, 2022, Petitioner maintained its position and refused to make its experts
`available for deposition.
`
`Given this discovery impasse, and given the time sensitive nature of this request based on the
`September 7, 2022 deadline for Patent Owner’s sur-reply, Patent Owner seeks the Board’s guidance
`and respectfully requests a conference call with the Board. Patent Owner is available at the Board’s
`convenience.
`
`Respectfully,
`Joel Glazer (Reg. No. 76, 493)
`
`
`
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`