`To:
`
`Hayes, Jennifer
`Trials
`
`
`
`Cc:Angelo;Christopher O. Green;Jeremy Monaldo; Hyun Jin In; Schwartz, Daniel; Werber, Matthew; Christopher,
`Karl Renner
`
`
`
`Subject:
`Date:
`
`IPR 2022-00222
`Wednesday, March 15, 2023 1:46:16 PM
`
`Your Honors,
`
`Patent Ownerseeks authorization from the Board to (1) move to terminate IPR2022-00222 because
`Samsungis estopped from maintaining this IPR pursuantto at least 35 U.S.C. § 315(e)(1) and 316(b)
`in view of the Board’s recent findings in IPR2021-01413 that Samsungand Applearereal parties in
`interest in that proceeding, involving the same patent, and that claims 1-7 of the patent are
`unpatentable. Presenting oral argument constitutes “maintain[ing] a proceeding before the Office”
`and would beprohibited should the Board determine that Samsungis estopped. 35 U.S.C. § 315(e)
`(1). The Board also has discretion to terminate IPRs pursuantto at least 35 U.S.C. § 315(d), 37 CFR §
`42.72, and 37 CFR § 42.5.
`
`Patent also requests the Boardstay this IPR pursuantto at least 35 U.S.C. § 315(d) until the Board
`determines whether Samsungis estopped and prevented from maintain this proceeding under § 315
`and therefore requests authorization to file a motion to stay the proceeding, including oral
`argument, until it determine whetherthis proceeding should be terminated.
`
`Samsung opposesboth requests.
`
`Both parties are available to discuss these requests today between 2 and 4pm ET.
`
`Best Regards,
`
`Jennifer Hayes
`Lead Counsel for Patent Owner
`
`Reg. No. 50,845
`
`Jennifer Hayes
`Partner
`jenhayes@nixonpeabody.com
`T/ 213.629.6179 M/ 650.575.2400 F/ 866.781.9391
`
`| 5
`
`Nixon Peabody LLP
`300 South Grand Avenue, Suite 4100, Los Angeles, CA 90071-3151
`nixonpeabody.com MNixonPeabodyLLP
`
`This email message and any attachmentsare confidential and maybe protected bythe attorney/client or other applicable privileges. The
`
`IPR2022-00031
`
`Ex. 3007
`
`
`
`information is intended to be conveyed only to the designated recipient(s) of the message. If you are not an intended recipient, please
`notify the sender immediately and delete the message from your email system. Unauthorized use, dissemination, distr bution or
`reproduction of this message by other than the intended recipient is strictly prohibited and may be unlawful. Thank you.
`
`
`
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