`Case 1:20-cv-00393-LO-TCB Document 720-14 Filed 06/16/21 Page 1 of 2 Page|D# 17694
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`Case 1:20-cv-00393-LO-TCB Document 720-14 Filed 06/16/21 Page 2 of 2 PageID# 17695
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`Laud, Sanjiv P.
`From:
`Sent:
`To:
`Cc:
`Subject:
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`Michalik, John M.
`Monday, June 14, 2021 3:05 PM
`pmiedva.lwteam@lw.com
`RJREDVA; Charles Molster
`Case No: 1:20-cv-00393-LO-TCB (motion to dismiss/amend)
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`Counsel ‐ ‐
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`Reynolds intends to file a motion to dismiss its inequitable conduct counterclaim against the ‘545 patent, as well as its
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`inequitable conduct defense as to the ‘545 patent
` equitable defenses of estoppel, acquiescence, waiver, and unclean hands as to the ’911, ’556, ‘265, and ‘374
`patents
` equitable defense of unclean hands as to the ‘545 patent
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`limitation on damages defense as to the ’911, ’556, and ‘265 patents
` extraterritorial claims defense for the ’911, ’556, ‘265, ‘545, and ‘374 patents
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`Reynolds also will seek leave to amend its responses to PMP’s and Altria’s infringement counterclaims
`accordingly. Please confirm Counterclaim‐Plaintiffs oppose or otherwise provide your availability to meet and confer
`this afternoon or tomorrow morning.
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`John M. Michalik
`Partner
`JONES DAY® - One Firm Worldwide℠
`77 West Wacker
`Chicago, Illinois 60601-1692
`Office +1.312.269.4215
`Mobile +1.312.315.5926
`jmichalik@jonesday.com
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