`To:
`Cc:
`
`Subject:
`Date:
`Attachments:
`
`Melissa Kalka
`Director_PTABDecision_Review
`kaiser-ptab@perkinscoie.com; brewer-ptab@perkinscoie.com; carter-ptab@perkinscoie.com; Amazon-
`NokiaIPR@perkinscoie.com; beigelmacher-ptab@perkinscoie.com; baitchev-ptab@perkinscoie.com;
`Nokia_IPRs_Amazon_HP
`IPR2024-00847/IPR2024-00848
`Thursday, December 26, 2024 7:45:10 PM
`image872704.png
`image076855.png
`2024 12 26 IPR2024-00847 (808) - PO"s Request for Rehearing by the Director.pdf
`2024 12 26 IPR2024-00848 (808) - PO"s Request for Rehearing by the Director.pdf
`
`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 Director Brent,
`
`I write on behalf of lead counsel for Nokia in IPR2024-00847 and 00848. As required by the Revised
`Interim Director Review Process, Nokia notifies the Director that it has filed a Request for Director
`Review of the Board’s decision to institute IPR. A courtesy copy is attached.
`
`As explained more fully in the Request, the Board abused its discretion in instituting IPR. Nokia’s
`priority ranking of issues is as follows: (1) whether the Board erred in determining that a POSITA
`would have combined two mutually exclusive modes of operation in Karczewicz into one mode
`without any findings about reasonable expectation of success, and (2) whether the Board erred in
`disregarding parts the inventor’s lexicography of “skip coding mode” when determining Frojdh’s
`IGMC mode discloses a “skip coding mode” because IGMC may sometimes result in zero-valued
`motion vectors and sometimes result in non-zero valued motion vectors as was the case with prior
`art modes discussed in the ’808 Patent.
`
`Nokia respectfully requests that these decisions be vacated and these IPRs not be instituted.
`
`Respectfully Submitted,
`
`Scott Hejny
`Lead Counsel for Nokia
`
`NOTICE OF CONFIDENTIALITY: The information contained in and transmitted with this e-mail is SUBJECT TO THE ATTORNEY-CLIENT and ATTORNEY
`WORK PRODUCT PRIVILEGE and is CONFIDENTIAL. It is intended only for the individual or entity designated above. You are hereby notified that any
`dissemination, distribution, copying, use or reliance upon the information contained in and transmitted with this e-mail by or to anyone other than the
`addressee designated above by the sender is unauthorized and strictly prohibited. If you have received this e-mail in error, please notify the sender by
`reply immediately. Any e-mail erroneously transmitted to you should be immediately destroyed.
`
`IPR2024-00848
`Ex. 3100
`
`
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