From:
`To:
`Cc:
`Subject:
`Date:
`
`Sommers, Erin
`Trials
`Feldstein, Mark; Sweet, Mark; Mitchell, Charles; LoCascio, Gregg F.; #HON_PTAB_SERVICE; Frank, Noah S.
`Arkema v. Honeywell: PGR2016-00011 & PGR2016-00012
`Friday, January 17, 2020 12:04:52 PM
`
`Arkema Inc. and Arkema France v. Honeywell International Inc.
`PGR2016-00011 and PGR 2016-00012
`
`Dear Honorable Board:
`
`We write on behalf of Petitioner to request a conference call with the Board regarding Petitioner’s
`January 14, 2020, Notices of Deposition of Mr. Joseph Posillico (Papers 63, 43 in PGR 2016-00011
`and -00012, respectively), who submitted declarations (Exs. 2167 and 2165 in PGR2016-00011 and
`-00012, respectively) in support of Patent Owner’s January 10, 2020, Motions for Leave to Request a
`Certificate of Correction (Papers 61 and 41 in PGR2016-00011 and -00012, respectively).
`
`To meet the deadline for notice under the rules, Petitioner filed its Notices on January 14, scheduling
`the deposition for January 29, but indicated that it was willing to consider another day during
`January 27-30 that may be more convenient for Mr. Posillico. Despite attempts to confirm a
`deposition date, Patent Owner has failed to confirm that Mr. Posillico is available on January 29 or to
`offer another date. Petitioner further understands that Patent Owner believes it is not required
`and/or is unwilling to produce Mr. Posillico for cross-examination as routine discovery under the
`rules.
`
`Accordingly, and given that Petitioner’s oppositions to Patent Owner’s Motions for Leave are due on
`February 10, 2020, Petitioner seeks the Board’s guidance as to how to proceed. Petitioner is
`generally available for a conference call with the Board on January 21 or 22, 2020. Patent Owner
`has not provided its availability for a conference call, other than, as we understand it, January 21 at 2
`pm.
`
`Respectfully submitted,
`Erin M. Sommers
`Counsel for Petitioner
`Reg. No. 60,974
`
`Erin M. Sommers
`Partner
`Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
`901 New York Avenue, NW, Washington, DC 20001-4413
`+1 202 408 4292 | fax +1 202 408 4400 | erin.sommers@finnegan.com | www.finnegan.com
`
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