`To:
`Cc:
`
`Subject:
`Date:
`Attachments:
`
`Sangeeta G. Shah
`Director_PTABDecision_Review
`mspecht-ptab@sternekessler.com; jfitzsimmons-ptab@sternekessler.com; isoule-ptab@sternekessler.com;
`dyonan-ptab@sternekessler.com; PTAB@sternekessler.com; ehaug@haugpartners.com;
`rcolletti@haugpartners.com; ptab-porsche@haugpartners.com; TRCH0110IPR@brookskushman.com;
`TRCH0110IPR1@brookskushman.com
`Patent Owners Request for Director Review IPR2022-01586
`Friday, June 21, 2024 6:51:19 PM
`Patent Owners Request for Director Review 2022-01586.pdf
`
`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before
`responding, clicking on links, or opening attachments.
`
`Dear Director Vidal,
`
`Patent Owner in the above-captioned proceedings respectfully requests Director Review of the final
`written decision on the grounds that 1) the request presents important issues of law and policy as to
`whether partial final written decisions, those that fail to address all grounds, run afoul of the AIA
`statutory framework and the Supreme Court’s guidance in SAS Inst., v. Iancu, 138 S. Ct. 1348
`(2018) and 2) the decision constitutes legal error and abuse of discretion as it fails to address
`material intrinsic evidence of patentability that contradicts the Board’s rationale.
`
`Patent Owner further provides the following description and priority-ranked list of issues for which it
`seeks Director Review:
`
`1. Important Issue of Law or Policy as to Whether Partial Final Written Decisions Are
`Permitted Under Governing Law
`
`2. Legal Error Involving the Failure to Address Material Intrinsic Evidence of Patentability
`
`All counsel of record have been copied on this email, and a copy of the Request for Director Review
`has been filed in the PTACTS system as Paper 34, a copy of which is attached hereto. Should the
`Director require or wish to request supplemental briefing on any issues presented in the Request for
`Director Review, Patent Owner would be happy to provide it.
`
`Respectfully submitted,
`Sangeeta G. Shah
`Counsel for Patent Owner
`
`IPR2022-01586
`Ex. 3100
`
`
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