`To:
`Cc:
`
`Subject:
`Date:
`
`Andrew Sherman
`Yung-Hoon (Sam) Ha; Trials
`Laura Avena; Taeg Sang (Tim) Cho; Alex Chan; Jason Shapiro; Mariam Clayton; DLF- Lit Paras; Joel Glazer; Peter
`Mazur; Sung-Samsung-DLF_Intl; Andrew Sherman
`Re: IPR2024-00533, IPR2024-00534, IPR2024-00535 - Request for leave to file Replies to POPRs
`Friday, July 12, 2024 8:07:33 AM
`
`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 requests a conference call to explain its position, the substance of which is not
`addressed fully by Petitioner’s email.
`
`Patent Owner is available for a conference during the following times indicated by Petitioner:
`July 16: 10am-2pm ET
`July 17: 10am-5pm ET
`
`Respectfully,
`Andrew Sherman
`Counsel for Patent Owner
`
`From: Yung-Hoon (Sam) Ha <YHa@desmaraisllp.com>
`Date: Thursday, July 11, 2024 at 9:05 PM
`To: trials@uspto.gov <trials@uspto.gov>
`Cc: Laura Avena <LAvena@desmaraisllp.com>, Taeg Sang (Tim) Cho
`<TCho@desmaraisllp.com>, Alex Chan <achan@devlinlawfirm.com>, Jason Shapiro
`<jshapiro@devlinlawfirm.com>, Mariam Clayton <mclayton@devlinlawfirm.com>,
`DLF- Lit Paras <dlflitparas@devlinlawfirm.com>, Joel Glazer
`<jglazer@devlinlawfirm.com>, Peter Mazur <PMazur@devlinlawfirm.com>, Sung-
`Samsung-DLF_Intl <Sung-Samsung-DLF_Intl@devlinlawfirm.com>
`Subject: IPR2024-00533, IPR2024-00534, IPR2024-00535 - Request for leave to file
`Replies to POPRs
`
`Dear Honorable Board,
`
`Petitioner requests leave to file replies to the Patent Owner’s Preliminary Responses (POPRs) in the
`following IPRs: IPR2024-00533 (‘270 Patent), IPR2024-00534 (’862 Patent), and IPR2024-00535
`(‘802 Patent).
`
`For each of IPR2024-00533 and IPR2024-00535, Petitioner requests authorization to submit a five-
`page Reply to the POPRs to:
`1. address the likelihood of a stay, including authorization from the Board to submit a copy
`
`Exhibit 3001
`
`
`
`of Sung’s Sur-Reply in Opposition of Motion to Stay filed on June 24, 2024 in the parallel
`district court litigation that includes certain concessions made by Dr. Sung regarding the
`stay at the end of Markman briefing;
` 2. address Patent Owner’s statement regarding the purported significant expenses that
`were incurred so that Petitioner can provide certain omitted facts that would provide
`the Board with a more complete picture; and
` 3. provide Petitioner’s willingness to submit a Sotera stipulation should the district court
`deny our motion to stay for summary judgment of invalidity in the parallel district court
`(which has been fully briefed) or upon institution of the IPRs, whichever occurs earlier.
`
`
`For IPR2024-00534, Petitioner requests authorization to provide seven-page Reply to the POPR to
`address the issues noted above for IPR2024-00533 and IPR2024-00535, and to request address the
`inconsistent positions Patent Owner is taking regarding Sung’026 (U.S. Patent Publication No.
`2007/0060026 filed as U.S. Patent Application No. 11/223,786) between the POPRs filed in
`IPR2024-00533 and IPR2024-00535.
`
`Patent Owner’s counsel has indicated they oppose the request with respect to IPR2024-00533, but
`has not responded to our various emails (beginning on July 8) for a meet and confer regarding
`IPR2024-00534 and IPR2024-00535.
`
`Should the Board request a conference call to discuss the requests, Petitioners are available at the
`following times.
`
`
`· July 15: 2pm-5pm ET
`· July 16: 10am-2pm ET
`· July 17: 10am-5pm ET
`
`
`Yung-Hoon Ha
`Lead Counsel for Petitioner
`
`
`
`This email may contain confidential and privileged material for the use of the intended
`recipient. Any review, use, or distribution by anyone other than the addressee is
`strictly prohibited. If you are not the intended recipient, please contact the sender by
`reply email and delete all copies of this message.
`
`
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