`
`Case 2:15—cv—01274—JRG—RSP Document 110-2 Filed 06/09/16 Page 1 of 3 Page|D #: 2455
`
`EXHIBIT B
`
`
`
`Case 2:15-cv-01274-JRG-RSP Document 110-2 Filed 06/09/16 Page 2 of 3 PageID #: 2456
`
`Re: Blitzsafe Claim Construction Briefing
`Joe Beauchamp to: Lambrianakos, Peter
`3-3835
`"H. Albert Liou", BlitzsafeTX, "Brian K. Shelton", "Deron R. Dacus",
`"Fadi N. Kiblawi", Randy Akin, Joseph Melnik, Joseph Beauchamp,
`"Jeffrey S. Patterson", "John F. Rabena", "Matthew D. Satchwell",
`
`Cc:
`
`05/03/2016 04:38 PM
`
`Peter,
`
`The PTAB was not asked by Unified Patents to find any claim term indefinite. As I suspect you know, the
`PTAB does not have the power to invalidate a claim for indefiniteness in an IPR proceeding. We intend to
`brief this issue.
`
`Thanks,
`
`Joe
`
`Joseph M. Beauchamp
`Partner
`JONES DAY® - One Firm Worldwide℠
`717 Texas, Suite 3300
`Houston, Texas 77002
`Office +1.832.239.3835
`Mobile +1.713.826.5726
`jbeauchamp@jonesday.com
`
`"Lambrianakos, Peter"
`
`Joe, Thanks for your call yesterday concerni...
`
`04/27/2016 04:00:49 PM
`
`From:
`To:
`Cc:
`
`Date:
`Subject:
`
`"Lambrianakos, Peter" <PLambrianakos@brownrudnick.com>
`Joseph Beauchamp <Joseph.Beauchamp@esquiresolutions.com>
`BlitzsafeTX <BlitzsafeTX@brownrudnick.com>, "H. Albert Liou" <aliou@jonesday.com>, "Joseph
`M. Beauchamp" <jbeauchamp@jonesday.com>, Joseph Melnik <jmelnik@jonesday.com>, Randy
`Akin <gra@randyakin.com>, "Matthew D. Satchwell" <matthew.satchwell@dlapiper.com>, "Patrick
`S. Park" <patrick.park@dlapiper.com>, "Paul R. Steadman" <paul.steadman@dlapiper.com>,
`"Brian K. Shelton" <bshelton@sughrue.com>, "Fadi N. Kiblawi" <fkiblawi@sughrue.com>, "J. Thad
`Heartfield" <thad@heartfieldlawfirm.com>, "John F. Rabena" <jrabena@sughrue.com>, "Margaret
`M. Welsh" <mwelsh@sughrue.com>, "William H. Mandir" <wmandir@sughrue.com>, "Jeffrey S.
`Patterson" <jpatterson@hdbdlaw.com>, "Sean N. Hsu" <shsu@hdbdlaw.com>, "Theresa M.
`Dawson" <tdawson@hdbdlaw.com>, "Deron R. Dacus" <ddacus@dacusfirm.com>, "Michael J.
`Lennon" <mlennon@kenyon.com>, Peter Kerr <pkerr@dacusfirm.com>, Sheila Mortazavi
`<smortazavi@kenyon.com>, "Susan A. Smith" <ssmith@kenyon.com>
`04/27/2016 04:00 PM
`Blitzsafe Claim Construction Briefing
`
`Joe,
`
`Thanks for your call yesterday concerning claim construction briefing. We have considered your
`proposal but have decided that we will not consent to any changes in the briefing schedule. In light of
`the PTAB's construction of "integration subsystem" and our upcoming claim construction brief, please
`
`
`
`Case 2:15-cv-01274-JRG-RSP Document 110-2 Filed 06/09/16 Page 3 of 3 PageID #: 2457
`
`advise as soon as possible whether defendants will persist in their indefiniteness argument. Thank you.
`
`Regards,
`
`Peter
`
`
`Peter Lambrianakos
`Partner
`Brown Rudnick LLP
`Seven Times Square
`New York, NY 10036
`T: 212.209.4813
`F: 212.938.2981
`plambrianakos@brownrudnick.com
`www.brownrudnick.com
`Please consider the environment before printing this e-mail
`
`
`
`***********************************************************************************
`
`The information contained in this electronic message may be legally privileged and confidential under applicable law, and is
`intended only for the use of the individual or entity named above. If the recipient of this message is not the above-named intended
`recipient, you are hereby notified that any dissemination, copy or disclosure of this communication is strictly prohibited. If you have
`received this communication in error, please notify Brown Rudnick LLP, (617) 856-8200 (if dialing from outside the US,
`001-(617)-856-8200) and purge the communication immediately without making any copy or distribution.
`
`***********************************************************************************[ attachment "decision denying institution-19.pdf" deleted by
`Joe Beauchamp/JonesDay]
`
`==========
`This e-mail (including any attachments) may contain information that is private, confidential, or protected
`by attorney-client or other privilege. If you received this e-mail in error, please delete it from your system
`without copying it and notify sender by reply e-mail, so that our records can be corrected.
`==========
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