`Case 1:20-cv-00393-LO-TCB Document 735-1 Filed 06/16/21 Page 1 of 2 Page|D# 20089
`
`EXHIBIT A
`EXHIBIT A
`
`
`
`Case 1:20-cv-00393-LO-TCB Document 735-1 Filed 06/16/21 Page 2 of 2 PageID# 20090
`
`
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Jennifer.Koh@lw.com
`Tuesday, June 1, 2021 4:16 PM
`RJREDVA
`pmiedva.lwteam@lw.com
`RAI Strategic Holdings v. Altria Client Services (EDVa) - Summary Judgment
`
`** External mail **
`
`Counsel,
`
`
`Please confirm whether Reynolds will withdraw its claim of inequitable conduct on the ’545 patent,
`and whether Reynolds will withdraw the “Liao” reference as prior art to the ’374 patent. If Reynolds
`does not agree, we intend to seek summary judgment. Further, since Reynolds has not withdrawn its
`other affirmative defenses identified in our May 14 email, we plan to seek summary judgment on
`those defenses as well. We assume Reynolds opposes a motion for summary judgment on these
`issues, otherwise, please confirm your availability to meet and confer on these issues tomorrow at 9
`a.m. PT.
`
`Regards,
`Jennifer
`
`Jennifer Koh
`
`
`LATHAM & WATKINS LLP
`12670 High Bluff Drive
`San Diego, CA 92130
`Direct Dial: +1.858.523.3949
`Email: jennifer.koh@lw.com
`https://www.lw.com
`
`
`_________________________________
`
`This email may contain material that is confidential, privileged and/or attorney work product for the sole use of
`the intended recipient. Any review, disclosure, reliance or distribution by others or forwarding without express
`permission is strictly prohibited. If you are not the intended recipient, please contact the sender and delete all
`copies including any attachments.
`
`Latham & Watkins LLP or any of its affiliates may monitor electronic communications sent or received by our
`networks in order to protect our business and verify compliance with our policies and relevant legal
`requirements. Any personal information contained or referred to within this electronic communication will be
`processed in accordance with the firm's privacy notices and Global Privacy Standards available at www.lw.com.
`
`1
`
`