`To:
`Cc:
`Subject:
`Date:
`
`Alyssa Holtslander
`Trials
`Brent Bumgardner; Carder Brooks; DG-MicroPairing-IPR; Ashraf Fawzy
`IPR2021-01557: Request for Reply
`Friday, February 4, 2022 3:35:32 PM
`
`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before
`responding, clicking on links, or opening attachments.
`
`Dear Honorable Board,
`
`Petitioner requests to file a reply to address the following issues in Micropairing’s Preliminary
`Response (“POPR,” Paper 7) filed on January 27, 2022:
`
`1. Patent Owner’s arguments in favor of discretionary denial based on 35 U.S.C. 314(a) (POPR,
`pages 28-33).
`2. Patent Owner’s arguments that Petitioner has not identified all real parties in interest (POPR,
`pages 33-37).
`
`Petitioner submits that good cause exists to request a reply. For example, Petitioner could not have
`reasonably foreseen Patent Owner’s arguments regarding potential Board conflicts related to third-
`parties not involved in this proceeding or in concurrent litigation or Patent’s Owner’s arguments
`related to RPI that include misstatements of fact and ignore or contradict controlling precedent
`(e.g., Shark Ninja) and prior Board decisions.
`
`Petitioner and Patent Owner have conferred. Although Patent Owner does not agree that good
`cause exists, Patent Owner does not oppose Petitioner filing a 10-page reply (to be filed within 10
`days of the Board’s approval) as long as the Patent Owner receives a 5-page sur-reply (to be filed
`within 10 days of Petitioner’s reply).
`
`If necessary, the parties are available for a conference call at the following times: 2/8 between 9 AM
`and 4 PM ET; or 2/9 between 9 AM and 11:30 AM ET and between 2 PM and 4 PM ET.
`
`Regards,
`Alyssa Holtslander
`Counsel for Petitioner
`
`Alyssa Holtslander
`Senior Patent Counsel | Unified Patents ®
`+1.202.750.3605
`alyssa@unifiedpatents.com
`
`Sign up for the only FREE Daily PTAB and Litigation Report
`
`IPR2021-01557
`Ex. 3001
`
`
`
`This e-mail message is intended only for individual(s) to whom it is addressed and may contain information that is
`privileged, confidential, proprietary, personal, or otherwise exempt from disclosure under applicable law. Note that
`Unified does not have an attorney-client relationship with its members. If you believe you have received this message in
`error, please advise the sender by return e-mail and delete it from your mailbox. Thank you.
`
`
`
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