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`From: Alyssa Holtslander <alyssa@unifiedpatents.com>
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`Sent: Monday, May 23, 2022 1:55 PM
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`To: Trials <Trials@USPTO.GOV>
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`JGlabicki@vklaw.com; rrigby@intven.com; dkerner@vklaw.com
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`Subject: IPR2022-00429 -Request for Reply to POPR
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`Cc: Roshan Mansinghani <roshan@unifiedpatents.com>; RODonnell@vklaw.com; rleonard@vklaw.com;
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`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before responding, clicking on
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`Dear Honorable Board,
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`Petitioner requests to file a reply to address the following issues in IV's Preliminary Response ("POPR," Paper 7) filed on
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`May 16, 2022:
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`1.Patent Owner's arguments that Petitioner has not identified all real parties in interest (POPR, pages 3-14).
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`2.Patent Owner's arguments in favor of discretionary denial based on 35 U.S.C. 314(a) (POPR, pages 14-
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`29).
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`Petitioner submits that good cause exists to request a reply. For example, Petitioner could not have reasonably foreseen
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`and prior Patent Owner's arguments related to RPI that ignore or contradict controlling precedent (e.g., Shark Ninja)
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`Board decisions or arguments regarding that include, for example, district court filings that were made after the
`Fintiv
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`filing of the Petition.
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`Petitioner requests authorization to file a ten page reply to address these issues.
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`Petitioner and Patent Owner have conferred. Patent Owner opposes Petitioner's request. Patent Owner not agree with
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`Petitioner's characterization of Patent Owner's arguments, and believe that issues raised in Patent Owner's POPR
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`by Petitioner based on anticipated challenge should have been readily regarding the real parties in interest and Fintiv
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`similar issues having been raised by patent owners in other IPR proceedings brought by Petitioner.
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`If necessary, the parties are available for a conference call at the following times: 2/24 between 11 AM and 4 PM ET;
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`2/25 between 9 AM and 2 PM ET; or 2/26 between 11 AM and 3 PM ET.
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`Regards,
`Alyssa Holtslander
`Counsel for Petitioner
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`IPR2022-00429
`Ex. 3001
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`Alyssa Holtslander 
`Senior Patent Counsel | Unified Patents ® 
`+1.202.750.3605
`alyssa@unifiedpatents.com
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