`To:
`Cc:
`
`Subject:
`Date:
`
`McGuffin, Asher S.
`Trials
`"Emily.Whelan@wilmerhale.com"; "Deric.Geng@wilmerhale.com"; "Cindy.Kan@wilmerhale.com";
`"david.bassett@wilmerhale.com"; "vinita.ferrera@wilmerhale.com"; Pheng, Mary;
`"WHMerckMavencladIPRs@wilmerhale.com"; Eldora L. Ellison; Olga A. Partington; Chandrika Vira; JC Rozendaal;
`Christina Dashe; PTAB Account; Madeleine Bond; Tyler Liu; Prati Khanduri
`IPR2023-00480 and -00481: Request to Expunge and Replace Ex. 2050
`Wednesday, March 13, 2024 3:03:06 PM
`
`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before
`responding, clicking on links, or opening attachments.
`
`Case Nos. IPR2023-00480 and IPR2023-00481
`U.S. Patent Nos. 7,713,947 and 8,377,903
`
`Dear Honorable Board:
`
`Patent Owner writes to respectfully request the expungement and substitution of Ex. 2050
`in IPR2023-00480 and IPR2050-00481. Patent Owner has conferred with Petitioner, and it
`does not oppose this request.
`
`It recently came to Patent Owner’s attention that Ex. 2050 was inadvertently filed, under
`seal, with three paragraphs of unredacted privileged information from a third-party that is
`subject to a common-interest with Patent Owner. Patent Owner seeks to replace Ex. 2050
`with a substitute exhibit, which redacts the privileged information. The privileged material is
`not relevant to the issues in these proceedings. If the Board authorizes this expungement
`and substitution, we propose to file a substitute exhibit under seal having the three
`paragraphs redacted.
`
`Patent Owner respectfully asks that the Honorable Board grant this request. Should the
`Honorable Board desire further information, Patent Owner seeks permission to submit a
`two-page motion further explaining the reasons for this request along with a copy of the
`proposed redacted exhibit, and/or discuss in a teleconference at the Board’s convenience.
`
`Respectfully submitted,
`
`Asher S. McGuffin
`Back-up Counsel for Patent Owner
`Registration No. 81,206
`
` --
`
`Asher S. McGuffin | WilmerHale
`60 State Street
`Boston, MA 02109 USA
`+1 617 526 6201 (t)
`+1 617 526 5000 (f)
`asher.mcguffin@wilmerhale.com
`Please consider the environment before printing this email.
`
`IPR2023-00480, -00481
`Ex. 3001
`
`
`
`This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be
`privileged. If you are not the intended recipient, please notify us immediately—by replying to this message or by sending an email to
`postmaster@wilmerhale.com—and destroy all copies of this message and any attachments. Thank you.
`
`For more information about WilmerHale, please visit us at http://www.wilmerhale.com.
`
`
`
`
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