`
`Subject:
`RE: Valtrus' discovery mo5ons in IPR2022-01497, -01545
`Date:
`Thursday, May 4, 2023 at 3:39:44 PM Eastern Daylight Time
`From:
`Kamber, MaJhias A.
`To:
`Andrew Baluch
`AFachments: mg_info.txt
`
`Andy,
`
`Following up on the below, I have confirmed that neither of my clients have responsive documents da5ng
`back to before their departure from Verity. Accordingly, I cannot see how their deposi5ons would be
`warranted.
`
`As I understand the mo5on, the patent owner seeks evidence “regarding the concep5on and reduc5on to
`prac5ce of the claimed inven5ons, including, for example, inven5on disclosure forms, diaries, calendars, lab
`notebooks, publica5ons, correspondence, and materials related to the prepara5on and filing of the Patent
`applica5ons.” Furthermore, patent owner seeks related documenta5on “to corroborate inventor tes5mony.”
`But given the absence of documenta5on, and therefore the inability to corroborate related tes5mony, it
`would seem that any deposi5ons would be superfluous.
`
`Please let me know if I can help answer any addi5onal ques5ons.
`
`MaJhias
`
`From: Kamber, MaJhias A.
`Sent: Wednesday, May 3, 2023 9:11 AM
`To: 'Andrew Baluch' <baluch@smithbaluch.com>
`Subject: RE: Valtrus' discovery mo5ons in IPR2022-01497, -01545
`
`Andy,
`
`Thanks for passing these along—I will take a look and circle back. To date, Valtrus/Irell has not reached out to
`me in connec5on with poten5al discovery from either J.C. Mao or Prabhakar Raghavan.
`
`MaJhias
`
`From: Andrew Baluch <baluch@smithbaluch.com>
`Sent: Tuesday, May 2, 2023 6:42 AM
`To: Kamber, MaJhias A. <maJhiaskamber@paulhas5ngs.com>
`Subject: [EXT] Valtrus' discovery mo5ons in IPR2022-01497, -01545
`
`You don't often get email from baluch@smithbaluch.com. Learn why this is important
`Hello MaJhias,
`
`I am passing along the aJached two mo5ons for addi5onal discovery filed by Valtrus Innova5ons
`Limited in IPR2022-01497, -01545. Appendices B-C of the mo5ons are directed to the named
`inventors of the challenged patents, including your clients Jianchang Mao and Prabhakar Raghavan.
`Has Valtrus/Irell ever contacted you in connec5on with poten5al discovery from either Jianchang Mao
`or Prabhakar Raghavan since you were designated as their contact under FRAP 26 in Google’s ini5al
`Ex.1029
`Page 1 of 2
`
`
`
`disclosures back in April 2022?
`
`Best regards,
`Andy
`
`Andrew Baluch
`SMITH BALUCH LLP
`+1.202.880.2397
`Counsel for Google LLC
`
`Ex.1029
`Page 2 of 2
`
`
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