`
`Exhibit 3
`
`
`
`Case 2:12-cv-02824-JPM-tmp Document 53-4 Filed 08/09/13 Page 2 of 4 PageID 632
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Justin MacLean
`Saturday, July 13, 2013 3:02 PM
`James Lin; raskinj@gtlaw.com
`Richard Pettus; BETechFTKALL; Jonathan Nelson; Shepherd Tate; Craig Kaufman
`RE: B.E. Tech/Samsung
`
`Dear James,
`
`As discussed below, and as the Court has lifted the stay in the Samsung cases, we intend to move forward with a motion
`to compel amended infringement contentions in the coming days. Please let us know your availability for a meet and
`confer either on Monday, July 15, after 3:00 pm Eastern time, or at any time on Tuesday, July 16.
`
`In addition, to facilitate service of Samsung’s initial non‐infringement contentions, including the chart required under
`Patent Local Rule 3.3(a), we ask that you send us a Microsoft Word‐formatted copy of Appendix A to B.E. Technology’s
`initial infringement contentions. Please let us know if this is acceptable.
`
`Kind Regards,
`
`Justin A. MacLean
`Associate
`Greenberg Traurig, LLP | MetLife Building | 200 Park Avenue | New York, NY 10166
`Tel 212.801.3137 | Fax 212.801.6400
`macleanj@gtlaw.com | www.gtlaw.com
`
`
`Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet.
`Description: Description: Greenberg Traurig
`
`
`
`
`
`From: James Lin [mailto:jlin@ftklaw.com]
`Sent: Wednesday, February 13, 2013 10:13 AM
`To: Raskin, Joshua L. (Shld-NY-IP-Tech)
`Cc: MacLean, Justin A. (Assoc-NY-IP-Tech); Pettus, Richard C. (Shld-NY-IP-Tech); BETechFTKALL; Jonathan Nelson;
`Shepherd Tate; Craig Kaufman
`Subject: RE: B.E. Tech/Samsung
`
`Josh:
`
`The Samsung cases are stayed. We will respond in an appropriate manner when the stay is lifted.
`
`Regards,
`
`James
`
`
`
`From: raskinj@gtlaw.com [mailto:raskinj@gtlaw.com]
`Sent: Monday, February 11, 2013 1:27 PM
`To: James Lin
`Cc: Justin MacLean; Richard Pettus; BETechFTKALL; Jonathan Nelson; Shepherd Tate; Craig Kaufman
`Subject: RE: B.E. Tech/Samsung
`
`1
`
`
`
`Case 2:12-cv-02824-JPM-tmp Document 53-4 Filed 08/09/13 Page 3 of 4 PageID 633
`
`
`James:
`
`In light of your January 30 letter declining to amend your infringement contentions, we intend to move forward with a
`motion to compel amended contentions shortly after the Court decides our pending motion to transfer (assuming, of
`course, that motion is denied). Please let us know if you will oppose that motion or, alternatively, if you would like to
`discuss the proposed motion by telephone. I am available this week for a call.
`
`Thanks,
`
`Josh
`
`From: James Lin [mailto:jlin@ftklaw.com]
`Sent: Wednesday, January 30, 2013 5:01 PM
`To: Jonathan Nelson; Craig Kaufman
`Cc: MacLean, Justin A. (Assoc-NY-IP-Tech); Pettus, Richard C. (Shld-NY-IP-Tech); Raskin, Joshua L. (Shld-NY-IP-Tech);
`BETechFTKALL; Shepherd Tate
`Subject: RE: B.E. Tech/Samsung
`
`Jonathan:
`
`Please see the attached correspondence.
`
`Regards,
`
`James
`
`__________________________________
`James Lin
`Partner
`Freitas Tseng & Kaufman LLP
`100 Marine Parkway, # 200 | Redwood Shores, CA 94065
`Direct: 650‐730‐5568 | Main: 650‐593‐6300 | Fax: 650‐593‐6301
`
`
`
`From: Nelson, Jonathan E. [mailto:JENelson@bassberry.com]
`Sent: Friday, January 18, 2013 1:57 PM
`To: Craig Kaufman
`Cc: Justin MacLean; Richard Pettus; raskinj@gtlaw.com; BETechFTKALL; Shepherd Tate
`Subject: B.E. Tech/Samsung
`
`Craig:
`
`Please see the attached letter which I am submitting on behalf of the two Samsung entities.
`
`Thank you.
`
`Jonathan E. Nelson
`The Tower at Peabody Place - 100 Peabody Place, Suite 900
`Memphis, TN 38103-3672
`(901) 543-5988 • (877) 521-2817 F
`jenelson@bassberry.com • www.bassberry.com
`
`
`2
`
`
`
`Case 2:12-cv-02824-JPM-tmp Document 53-4 Filed 08/09/13 Page 4 of 4 PageID 634
`
`
`
`
`Note: This e-mail may contain PRIVILEGED and CONFIDENTIAL information and is intended only for the use of the specific
`individual(s) to whom it is addressed. Your receipt of this e-mail is not intended to waive any applicable privilege. If you are
`not an intended recipient of this e-mail, you are hereby notified that any unauthorized use, dissemination or copying of this e-
`mail or the information contained in it or attached to it is strictly prohibited. If you have received this e-mail in error, please
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`If you are not an intended recipient of confidential and privileged information in this email, please delete it,
`notify us immediately at postmaster@gtlaw.com, and do not use or disseminate such information. Pursuant to
`IRS Circular 230, any tax advice in this email may not be used to avoid tax penalties or to promote, market or
`recommend any matter herein.
`
`3
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