Douglas Wentzel
`
`From:
`Sent:
`To:
`Cc:
`
`Subject:
`
`Dear PTAB,
`
`Jacob Peterson
`Tuesday, September 20, 2022 9:01 AM
`'Trials@USPTO.GOV'
`IPR50095-0042IP1@fr.com; IPR50095-0042IP2@fr.com; IPR50095-0043IP1@fr.com;
`IPR50095-0043IP2@fr.com; IPR50095-0044IP1@fr.com; IPR50095-0044IP2@fr.com;
`IPR50095-0045IP1@fr.com; IPR50095-0045IP2@fr.com; IPR50095-0045IP3@fr.com;
`IPR50095-0045IP4@fr.com; PTABInbound@fr.com; AppleIPR501-1; AppleIPR501-2;
`AppleIPR502-1; AppleIPR502-2; AppleIPR648-1; AppleIPR648-2; AppleIPR745-1;
`AppleIPR745-2; AppleIPR745-3; AppleIPR745-4
`IPR2022-01271/-01272/-01273/-01274/-01275/-01276/-01291/-01292/-01465/-01466
`– Request for Authorization to File Motions for Additional Discovery
`
`Patent Owner respectfully requests authorization to file a motion for additional discovery under 37 C.F.R. § 42.51(b)(2)
`in IPR2022-01271/-01272/-01273/-01274/-01275/-01276/-01291/-01292/-01465/-01466. Patent Owner seeks
`information relevant to objective indicia of non-obviousness in these proceedings, including evidence identified in the
`publicly available materials of a related ITC proceeding, but the identified evidence that would be the subject of Patent
`Owner’s motion is not publicly available.
`
`Patent Owner has conferred with Petitioner’s counsel regarding this request. Petitioner indicated that it opposes the
`request.
`
`Counsel for both parties are available for a call with the Board to discuss on Friday (9/23) between 12:30p-2p and 3p-
`4:30p Eastern time. If amenable to the Board, Patent Owner requests that Mr. Jeremiah Helm be allowed to present
`Patent Owner’s request to file the motions for additional discovery during the teleconference because he is intimately
`familiar with the particulars of the proposed motions. Lead or back-up counsel for Patent Owner also would be present
`during the call. Motions for Mr. Helm’s pro hac vice admission are pending in these proceedings, and Petitioner does not
`oppose his admission.
`
`Petitioner’s counsel has been copied on this email.
`
`Sincerely,
`Jacob
`
`Jacob Peterson
`Partner
`Jacob.Peterson@knobbe.com
`206-405-2007 Direct
`Knobbe Martens
`925 Fourth Ave., Suite 2500
`Seattle, WA 98104
`www.knobbe.com/jacob-peterson
`
`1
`
`MASIMO 2014
`Apple v. Masimo
`IPR2022-01291
`
`