From:
`To:
`Cc:
`
`Subject:
`Date:
`
`Trials
`Moulder, Christopher; Trials
`"jwyde@aatriallaw.com"; "sjugle@aatriallaw.com"; "IPR2023-00757@aatriallaw.com"; Netflix-GTS-WFG; Carrano,
`Aliza George; Mukerji, Indranil (Indy)
`RE: IPR2023-00757
`Friday, June 30, 2023 10:38:50 AM
`
`Counsel, the Board will expunge improperly filed Exhibit 1023 from the record in IPR2023-00757.
`There is no need to update the exhibit list provided with the Petition filed on May 7, 2023.
`
`Thank you,
`Eric W. Hawthorne
`Supervisory Paralegal Specialist
`Patent Trial and Appeal Board
`
`From: Moulder, Christopher <cmoulder@willkie.com>
`Sent: Thursday, May 11, 2023 3:00 PM
`To: Trials <Trials@USPTO.GOV>
`Cc: 'jwyde@aatriallaw.com' <jwyde@aatriallaw.com>; 'sjugle@aatriallaw.com'
`<sjugle@aatriallaw.com>; 'IPR2023-00757@aatriallaw.com' <IPR2023-00757@aatriallaw.com>;
`Netflix-GTS-WFG <Netflix-GTS-WFG@willkie.com>; Carrano, Aliza George <ACarrano@willkie.com>;
`Mukerji, Indranil (Indy) <IMukerji@willkie.com>
`Subject: IPR2023-00757
`
`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before
`responding, clicking on links, or opening attachments.
`
`Dear Board,
`
`On May 10, 2023, we received a “Notice of Filing Date Accorded to Petition” for IPR2023-00757
`indicating a defect in the exhibit list and that Petitioner must “enter an updated exhibit list to include
`exhibit number 1023.” Paper 5 at 2. It has come to our attention that Exhibit 1023 was filed in error
`in IPR2023-00757. That exhibit was meant for and filed in IPR2023-00758 and is stamped for that
`IPR. Accordingly, the exhibit list in the Petition of IPR2023-00757 is correct.
`
`We immediately contacted the Board on May 10th and spoke to a supervising paralegal to discuss
`options for resolving the defect. We were informed to email the Board explaining the situation and
`request that the exhibit be expunged. We understand that the Board will take up this issue when it
`is empaneled.
`
`Accordingly, we respectfully request that Exhibit 1023 in IPR2023-00757 be expunged. Expunging
`Exhibit 1023 of IPR2023-00757 will correct the defect.
`
`Exhibit 3002 page 1
`
`

`

`Regards,
`
`J. Christopher Moulder
`Reg. No. 70,490
`Counsel for Petitioner
`
`Christopher Moulder
`Willkie Farr & Gallagher LLP
`1875 K Street, N.W. | Washington, DC 20006-1238
`Direct: +1 202 303 1069 | Fax: +1 202 303 2000
`cmoulder@willkie.com | www.willkie.com
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`
`Exhibit 3002 page 2
`
`