`Sent: Thursday, January 5, 2023 10:21 AM
`To: Trials <Trials@USPTO.GOV>
`Cc: Wayne M. Helge <whelge@davidsonberquist.com>; James Wilson
`<jwilson@davidsonberquist.com>; Ethan Song <esong@davidsonberquist.com>; ecobee-IPRs
`<ecobee-IPRs@Venable.com>
`Subject: IPR2022-01339 / ecobee Technologies ULC v Causam Enterprises Inc - Request for
`Authorization for a Reply and Sur-Reply to the POPR
`
`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before
`responding, clicking on links, or opening attachments.
`
`To the Board,
`
`The Patent Owner Preliminary Response raises procedural issues including (1) whether the petition
`is time-barred due to an alleged RPI issue (see POPR, pp. 6-21) and (2) a patent ownership issue that
`relates to whether service of the petition was made on the true patent owner (see POPR, pp. 21-24).
`The parties have met and conferred and agree that further briefing on these issues is warranted in
`order to provide the Board with all necessary information. Consequently, the parties jointly seek
`leave for authorization to file a reply and sur-reply directed to these issues. Given the nature of the
`issues and factual details to be addressed, the parties propose that each paper be limited to 10
`pages. The parties also propose that Petitioner’s reply be due 10 days from the Board granting
`permission for these filings, and Patent Owner’s sur-reply be due 10 days after the filing of
`Petitioner’s reply.
`
`Should the Board deem a conference call necessary to discuss this joint proposal, the parties are
`available for a conference call during the following dates and times: (i) January 6, from 1:30-5pm, (ii)
`January 9, from 10am-12pm and 2-4pm, and (iii) January 10, from 3-5pm. Further available times
`can be provided if needed by the Board.
`
`Regards,
`Justin Oliver
`Counsel for Petitioner
`
`Justin J. Oliver, Esq.
`Venable | Fitzpatrick
`t 202.721.5423
`Venable LLP, 600 Massachusetts Avenue, NW
`Washington, DC 20001
`
`JOliver@Venable.com | www.Venable.com
`
`************************************************************************
`This electronic mail transmission may contain confidential or privileged information. If
`you believe you have received this message in error, please notify the sender by reply
`transmission and delete the message without copying or disclosing it.
`************************************************************************
`
`Exhibit 3001
`
`
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