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Case 1:20-cv-00393-LO-TCB Document 1144-2 Filed 03/11/22 Page 1 of 3 PageID# 30564
`Case 1:20-cv-00393-LO-TCB Document 1144-2 Filed 03/11/22 Page 1 of 3 PagelD# 30564
`
`EXHIBIT B
`EXHIBIT B
`
`

`

`Case 1:20-cv-00393-LO-TCB Document 1144-2 Filed 03/11/22 Page 2 of 3 PageID# 30565
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Laud, Sanjiv P. <slaud@jonesday.com>
`Wednesday, February 23, 2022 5:20 PM
`Okuda, Takashi (NY); RJREDVA; cmolster@molsterlaw.com
`#C-M PMIEDVA - LW TEAM
`RE: RAI Strategic Holdings, Inc. v. Altria Client Services LLC - Case No. 1:20-cv-00393-
`LO-TCB (E.D. Va.)
`
`Follow Up Flag:
`Flag Status:
`
`Follow up
`Flagged
`
`Takashi,
`
`Reynolds does not dispute that CN 667 has the same inventor as the ’374 patent, but we disagree with your proposed
`stipulation for the reasons discussed in our summary judgment briefing. Moreover, we do not believe your stipulation
`reflects what the court had in mind. We read the footnote in the court’s order as asking the parties to advise whether
`they believe the issue needs to be resolved and, if so, how and when it should be resolved.
`
`We are available to meet and confer Friday at 1 pm CT.
`
`Regards,
`Sanjiv
`
`Sanjiv P. Laud (bio)
`Partner
`JONES DAY® - One Firm Worldwide℠
`90 South Seventh Street, Suite 4950
`Minneapolis, MN 55402
`Office +1.612.217.8879
`
`From: Takashi.Okuda@lw.com <Takashi.Okuda@lw.com>
`Sent: Tuesday, February 22, 2022 4:27 PM
`To: Laud, Sanjiv P. <slaud@jonesday.com>; RJREDVA <RJREDVA@jonesday.com>; cmolster@molsterlaw.com
`Cc: pmiedva.lwteam@lw.com
`Subject: RE: RAI Strategic Holdings, Inc. v. Altria Client Services LLC - Case No. 1:20-cv-00393-LO-TCB (E.D. Va.)
`
`** External mail **
`
`Sanjiv,
`
`Thank you for your email. We would appreciate a response by COB tomorrow.
`
`Regards,
`
`Takashi Okuda
`
`
`LATHAM & WATKINS LLP
`1271 Avenue of the Americas
`New York, NY 10020
`Direct Dial: +1.212.906.1773
`
`1
`
`

`

`Case 1:20-cv-00393-LO-TCB Document 1144-2 Filed 03/11/22 Page 3 of 3 PageID# 30566
`Email: takashi.okuda@lw.com
`https://www.lw.com
`
`
`
`From: Laud, Sanjiv P. <slaud@jonesday.com>
`Sent: Friday, February 18, 2022 5:39 PM
`To: Okuda, Takashi (NY) <Takashi.Okuda@lw.com>; RJREDVA <RJREDVA@jonesday.com>; cmolster@molsterlaw.com
`Cc: #C-M PMIEDVA - LW TEAM <pmiedva.lwteam@lw.com>
`Subject: RE: RAI Strategic Holdings, Inc. v. Altria Client Services LLC - Case No. 1:20-cv-00393-LO-TCB (E.D. Va.)
`
`Takashi,
`
`We are reviewing your draft stipulation and will get back to you next week.
`
`Regards,
`Sanjiv
`
`Sanjiv P. Laud (bio)
`Partner
`JONES DAY® - One Firm Worldwide℠
`90 South Seventh Street, Suite 4950
`Minneapolis, MN 55402
`Office +1.612.217.8879
`
`From: Takashi.Okuda@lw.com <Takashi.Okuda@lw.com>
`Sent: Wednesday, February 16, 2022 4:47 PM
`To: RJREDVA <RJREDVA@jonesday.com>; cmolster@molsterlaw.com
`Cc: pmiedva.lwteam@lw.com
`Subject: RAI Strategic Holdings, Inc. v. Altria Client Services LLC - Case No. 1:20-cv-00393-LO-TCB (E.D. Va.)
`
`** External mail **
`
`Counsel:
`
`In light of the Court’s statement in its recent summary judgment order that “the Parties are encouraged to confer with
`each other” as to their dispute concerning the inventorship of Chinese Utility Model Patent CN 201482667, please
`confirm that RJR accepts the attached stipulation. If RJR does not agree, please identify why not, and provide your
`availability to meet and confer on February 18, 2022.
`
`Regards,
`
`Takashi Okuda
`
`
`LATHAM & WATKINS LLP
`1271 Avenue of the Americas
`New York, NY 10020
`Direct Dial: +1.212.906.1773
`Email: takashi.okuda@lw.com
`https://www.lw.com
`
`
`_________________________________
`
`
`2
`
`

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