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`Case 2:15-cv-00037-RWS Document 87-7 Filed 02/05/16 Page 1 of 3 PageID #: 2129
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`Case 2:15-cv-00037-RWS Document 87-7 Filed 02/05/16 Page 2 of 3 PageID #: 2130
`Case 2:15-cv-00037-RWS Document 87-7 Filed 02/05/16 Page 2 of 3 PagelD #: 2130
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`
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`From:
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`Sent:
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`To:
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`Cc:
`
`Subject:
`Attachments:
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`Dear Patrick,
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`ali.dhanani@bakerbotts.com
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`Friday, January 29, 2016 9:05 PM
`
`Flynn, Patrick N
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`d|hughesvelbit@bakerbotts.com; Elbit—Hughes; patrickclutter@potterminton.com;
`johnbufe@potterminton.com; mikejones@potterminton.com; wh@wsfirm.com
`
`Elbit v. Hughes
`Hughes_E|bit — Proposed Order Focusing Patent Claims and
`Edits]_Active_20648489_3.DOCX
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`Prior Art [Hughes
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`Thank you for your letter. 'While we disagree that Defendants’ Invalidity Contentions violate the rules, we will
`investigate your Complaints and provide a full response by February 8.
`
`As an initial matter, however, we think that your letter raises issues that the Court has provided tools to
`address and we think now is an opportune time to discuss them. In particular, as Defendants certainly have no
`intention of asserting “billions” of combinations of references, or requiring Elbit to consider such
`combinations, we would suggest that the parties discuss the Court’s general “ORDER FOCUSING PATENT
`CLAIMS AND PRIOR ART TO REDUCE COSTS" and come to an agreement 011 when the parties will narrow
`the case 011 both sides. Attached is the latest proposal from Defendants. Please review and let us know if you
`agree or provide a counter-proposal in red—line so that we can continue our discussion.
`
`Best,
`
`Ali Dhanani
`
`Tel: (713) 229-1108
`Cell: (281 ) 250-2294
`
`From: Flynn, Patrick N |mailto:PFlynn@cov.com|
`Sent: Tuesday, January 26, 2016 8:04 PM
`To: Dhanani, Ali; Hughes v Elbit; Qatrickclutter@mtterminton.com; johnbufe@mtterminton.com; EXT Jones, Mike
`Cc: wh@wsfimi.com; claire@wsfirm.com; Elbit-Hughes
`Subject: Elbit v. Hughes
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`Counsel,
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`Please see the attached letter.
`
`Regards,
`-Patrick
`
`Patrick Flynn
`
`Covington & Burling LLP
`333 Twin Dolphin Drive, Suite 700
`Redwood Shores, CA 94065—1418
`T +1 650 632 4732 | pflmn@oov.com
`WWVV.COV.com
`
`COVINGTON
`
`
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`Case 2:15-cv-00037-RWS Document 87-7 Filed 02/05/16 Page 3 of 3 PageID #: 2131
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`This message is from a law firm and may contain information that is confidential or legally privileged. If you are not the intended recipient, please
`immediately advise the sender by reply e-mail that this message has been inadvertently transmitted to you and delete this e-mail from your system.
`Thank you for your cooperation.
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`Confidentiality Notice: The information contained in this email and any attachments is intended only for the recipient[s]
`listed above and may be privileged and confidential. Any dissemination, copying, or use of or reliance upon such
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`error, please notify the sender immediately at the email address above and destroy any and all copies of this message.
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`2
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