`To:
`Cc:
`
`Subject:
`Date:
`
`Rowland, Clarence
`Trials
`Michael Shanahan; Omar J. Johnny; Scott H. Kaliko; "AMoon@winstead.com"; Fink, Tim; Almeling, David; Liang,
`Mark; Haber, Ben
`IPR2023-00104: Partly opposed request to submit district court documents
`Friday, April 28, 2023 3:26:31 PM
`
`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before
`responding, clicking on links, or opening attachments.
`
`Dear Honorable Board,
`
`Patent Owner filed its POPR in IPR2023-00104 on February 21, 2023. Petitioner
`requests authorization to file various recent and relevant documents from a parallel
`district court litigation between Patent Owner and Petitioner. Specifically, Petitioner
`seeks authorization to file (1) the transcript from the recent claim construction hearing
`(“transcript”) (2) the tentative order from the recent claim construction hearing
`(“tentative construction”), and (3) the April 20, 2023 Joint Motion to Amend the Docket
`Control Order and the proposed order to that motion (“DCO and motion”). Petitioner
`also intends to seek permission to provide a 2-page paper briefly stating the
`relevance of each of those items to Patent Owner’s arguments for discretionary denial
`under 35 U.S.C. §325(d) and §314. Petitioner will not oppose Patent Owner being
`granted a response paper of equal length.
`
`Counsel for Patent Owner is copied on this request and opposes submission of the
`transcript and tentative constructions as premature. Patent Owner does not oppose
`submission of the DCO and a 1–2 page paper explaining the relevance of the DCO
`and motion with a reciprocal reply granted to Patent Owner. The parties are available
`on Wednesday May 3rd 3 PM – 5 PM EST and Thursday and Friday May 4th and 5th
`12 PM - 5 PM EST for a conference call, should the Board find one helpful.
`
`Thank you
`Clarence Rowland,
`Counsel for Petitioner, LG
`
`O’Melveny
`Clarence A. Rowland
`CRowland@omm.com
`O: +1-213-430-7245
`
`O’Melveny & Myers LLP
`400 South Hope Street, 18th
`Floor
`Los Angeles, CA 90071
`Website | LinkedIn | Twitter
`This message and any attached documents contain information from the law firm of O'Melveny & Myers LLP that
`may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or
`use this information. If you have received this transmission in error, please notify the sender immediately by reply
`e-mail and then delete this message.
`
`IPR2023-00104
`Ex. 3002
`
`
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