throbber
Adam Fitzgerald
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`John Wittenzellner
`Friday, February 16, 2024 8:02 AM
`Stein, Alexander B.
`IPR Dynapass WSL; Hsu-Hoffman, Ahren C.; Zuck, Austin L.
`Re: IPR2024-00283 | Membership of Unified Patents
`
`Counsel:
`
` I
`
` reiterate my request that you provide your availability next week for a call with the Board.
`
`
`
`Best regards,
`John Wittenzellner
`
`From: John Wittenzellner <johnw@wsltrial.com>
`Date: Friday, February 2, 2024 at 9:26 PM
`To: Stein, Alexander B. <alexander.stein@morganlewis.com>
`Cc: IPR Dynapass WSL <iprdynapasswsl@wsltrial.com>, Hsu-Hoffman, Ahren C. <ahren.hsu-
`hoffman@morganlewis.com>, Zuck, Austin L. <austin.zuck@morganlewis.com>
`Subject: Re: IPR2024-00283 | Membership of Unified Patents
`
`Please provide your availability next week for a call with the Board.
`
`
`Best regards,
`John
`
`John Wittenzellner
`Williams Simons & Landis PLLC
`1735 Market Street, Suite A #453
`Philadelphia, PA 19103
`Direct: 512.543.1373
`
`From: Stein, Alexander B. <alexander.stein@morganlewis.com>
`Sent: Friday, February 2, 2024 20:49
`To: John Wittenzellner <johnw@wsltrial.com>
`Cc: IPR Dynapass WSL <iprdynapasswsl@wsltrial.com>; Hsu-Hoffman, Ahren C. <ahren.hsu-
`hoffman@morganlewis.com>; Zuck, Austin L. <austin.zuck@morganlewis.com>
`Subject: RE: IPR2024-00283 | Membership of Unified Patents
`
`[EXTERNAL EMAIL]
`
`John,
`
`
`Nothing in the case you cited below changes our position that we have fully complied with the Board’s mandatory-
`notice requirements of 37 C.F.R. § 42.8.
`
`
`1
`
`Ex. 2003, p. 1
`Amazon.com, Inc. v. Dynapass IP Holdings LLC, IPR2024-00283
`
`

`

`Best,
`
`-Alex
`
`
`Alexander B. Stein
`Morgan, Lewis & Bockius LLP (Seattle and Silicon Valley Offices)
`Cell: (650) 213-6296 | Seattle: (206) 274-6437 | Silicon Valley: (650) 843-7278
`
`
`From: John Wittenzellner <johnw@wsltrial.com>
`Sent: Friday, January 26, 2024 7:08 AM
`To: Stein, Alexander B. <alexander.stein@morganlewis.com>
`Cc: IPR Dynapass WSL <iprdynapasswsl@wsltrial.com>; Hsu-Hoffman, Ahren C. <ahren.hsu-
`hoffman@morganlewis.com>; Zuck, Austin L. <austin.zuck@morganlewis.com>
`Subject: Re: IPR2024-00283 | Membership of Unified Patents
`
`[EXTERNAL EMAIL]
`Good morning, Alex. Whether Petitioner is or has ever been a direct or indirect member of Unified Patents, which has a
`pending IPR, is highly relevant to at least the first factor of General Plastic. See Valve Corp. v. Electronic Scripting
`Products, Inc., IPR2019-00062, -00063, -00084, Paper 11 at 2 (P.T.A.B. Apr. 2, 2019) (“However, our application of the
`General Plastic factors is not limited solely to instances when multiple petitions are filed by the same petitioner. Rather,
`when different petitioners challenge the same patent, we consider any relationship between those petitioners when
`weighing the General Plastic factors.”). Please provide the requested information immediately.
`
`
`Best regards,
`John Wittenzellner
`
`
`From: Stein, Alexander B. <alexander.stein@morganlewis.com>
`Date: Wednesday, January 24, 2024 at 12:11 PM
`To: John Wittenzellner <johnw@wsltrial.com>
`Cc: IPR Dynapass WSL <iprdynapasswsl@wsltrial.com>, Hsu-Hoffman, Ahren C. <ahren.hsu-
`hoffman@morganlewis.com>, Zuck, Austin L. <austin.zuck@morganlewis.com>
`Subject: RE: IPR2024-00283 | Membership of Unified Patents
`
`[EXTERNAL EMAIL]
`
`
`Hi John,
`
`
`Do you have any authority supporting this request? We have fully complied with the Board’s mandatory-notice
`requirements of 37 C.F.R. § 42.8.
`
`
`Best,
`
`-Alex
`
`
`Alexander B. Stein
`Morgan, Lewis & Bockius LLP (Seattle and Silicon Valley Offices)
`Cell: (650) 213-6296 | Seattle: (206) 274-6437 | Silicon Valley: (650) 843-7278
`
`
`From: John Wittenzellner <johnw@wsltrial.com>
`Sent: Wednesday, January 24, 2024 8:05 AM
`
`2
`
`Ex. 2003, p. 2
`Amazon.com, Inc. v. Dynapass IP Holdings LLC, IPR2024-00283
`
`

`

`To: Stein, Alexander B. <alexander.stein@morganlewis.com>; Hsu-Hoffman, Ahren C. <ahren.hsu-
`hoffman@morganlewis.com>; Zuck, Austin L. <austin.zuck@morganlewis.com>
`Cc: IPR Dynapass WSL <iprdynapasswsl@wsltrial.com>
`Subject: Re: IPR2024-00283 | Membership of Unified Patents
`
`[EXTERNAL EMAIL]
`Counsel:
`
`I write to follow up on my previous email. Please identify whether Petitioner is or has ever been a direct or indirect
`member of Unified Patents.
`
`
`
`Best regards,
`John Wittenzellner
`
`
`From: John Wittenzellner <johnw@wsltrial.com>
`Date: Tuesday, January 2, 2024 at 8:00 AM
`To: alexander.stein@morganlewis.com <alexander.stein@morganlewis.com>, ahren.hsu-
`hoffman@morganlewis.com <ahren.hsu-hoffman@morganlewis.com>, austin.zuck@morganlewis.com
`<austin.zuck@morganlewis.com>
`Cc: IPR Dynapass WSL <iprdynapasswsl@wsltrial.com>
`Subject: IPR2024-00283 | Membership of Unified Patents
`
`Counsel:
`
`I represent Patent Owner in the above-referenced IPR. I write to request that Petitioner identify whether it is or has
`ever been a direct or indirect member of Unified Patents.
`
`
`Best regards,
`John
`
`
`John Wittenzellner
`Williams Simons & Landis PLLC
`1735 Market Street, Suite A #453
`Philadelphia, PA 19103
`Direct: 512.543.1373
`
`
`
`
`
`
`
`CONFIDENTIALITY NOTICE: The information in this email may be confidential and/or privileged. This email is intended to
`be reviewed by only the individual or organization named above. If you are not the intended recipient or an authorized
`representative of the intended recipient, you are hereby notified that any review, dissemination or copying of this email
`and any attachments or the information contained herein is prohibited. If you have received this email in error, please
`immediately notify the sender by return email and delete this email from your system. Thank You.
`CONFIDENTIALITY NOTICE: The information in this email may be confidential and/or privileged. This email is intended to
`be reviewed by only the individual or organization named above. If you are not the intended recipient or an authorized
`representative of the intended recipient, you are hereby notified that any review, dissemination or copying of this email
`and any attachments or the information contained herein is prohibited. If you have received this email in error, please
`immediately notify the sender by return email and delete this email from your system. Thank You.
`3
`
`Ex. 2003, p. 3
`Amazon.com, Inc. v. Dynapass IP Holdings LLC, IPR2024-00283
`
`

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