`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Summerfield, George <George.Summerfield@klgates.com>
`Monday, February 14, 2022 4:01 PM
`'Peter Tong'
`Seth Sproul; Tony Nguyen; Jeff Burton; Joy Kete; Kate Quisenberry; Marc Abrahams; KLG_US_Charter Pacific
`CPC Patent Technologies Pty Ltd. v. Apple Inc., 6:21-cv-00165 (W.D. Tex.)
`
`[This email originated outside of F&R.]
`
`Dear Mr. Tong:
`
`Per the Court’s instruction of February 10, 2022, the parties have conferred. CPC agrees to narrow the asserted claims against Apple in the instant
`litigation to the following:
`
`Claim 1 of the ‘039 Patent;
`
`Claim 10 of the ‘208 Patent; and
`
`Claims 1, 10, 11 and 15-17 of the ‘705 Patent
`
`The parties have further agreed to adopt: 1) Apple’s proposed construction of “means for receiving the transmitted secure access signal” in claim 10
`of the ‘208 Patent, i.e., “Structure: receiver 118 Function: receiving the transmitted secure access signal;” and 2) Apple’s proposed construction of
`“means for providing conditional access to the controlled item dependent upon [said] information [in said secure access signal] from that claim,” i.e.,
`“Structure: controller 109 executing software 304 Function: providing conditional access to the controlled item dependent upon information in said
`secure access signal.”
`
`The parties will continue to confer regarding the remainder of the deadlines proposed by the Court in its email of February 10, 2021.
`
`Respectfully submitted,
`
`George C. Summerfield
`K&L Gates LLP
`70 West Madison Street
`Chicago, Illinois 60525
`
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`IPR2022-00602
`Apple EX1079 Page 1
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`(312) 807-4376
`
`
`Counsel for Plaintiff
`CPC Patent Technologies Pty Ltd.
`
`This electronic message contains information from the law firm of K&L Gates LLP. The contents may be privileged and confidential and are intended for the use of the intended addressee(s) only. If you
`are not an intended addressee, note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. If you have received this e-mail in error, please contact me at
`George.Summerfield@klgates.com.-4
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`IPR2022-00602
`Apple EX1079 Page 2
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