`Case 1:20-cv-00393-LO-TCB Document 735-14 Filed 06/16/21 Page 1 of 2 Page|D# 20196
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`EXHIBIT O
`EXHIBIT 0
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`Case 1:20-cv-00393-LO-TCB Document 735-14 Filed 06/16/21 Page 2 of 2 PageID# 20197
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`12670 High Bluff Drive
`San Diego, California 92130
`Tel: +1.858.523.5400 Fax: +1.858.523.5450
`www.lw.com
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`May 10, 2021
`
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`VIA EMAIL
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`FIRM / AFFILIATE OFFICES
`Beijing
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`John Michalik
`Jones Day
`77 West Wacker, Suite 3500
`Chicago, IL 60601
`jmichalik@jonesday.com
`rjredva@jonesday.com
`
`
`Re:
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`RAI Strategic Holdings, Inc. et al. v. Altria Client Services LLC, et al.,
`No. 1:20-cv-393-LO-TCB (E.D. Va.)
`
`Dear Counsel:
`
`We write to object to Reynolds’ incomplete and misleading translation of CN201482667
`produced at RJREDVA_001626584-598.
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`Reynolds’ translation suggests different inventorship between CN201482667 and the ’374
`patent. That is not the case. Specifically, Reynolds’ translation identifies the inventor as “Liao
`Laiying.” However, as shown on the face of the original reference, the sole inventor of
`CN201482667 is the same as the inventor of the ’374 patent, Loi Ying Liu. It appears Reynolds’
`translation is based on a Mandarin Romanization of the inventor’s name. Yet, based on a
`Cantonese Romanization, the inventor’s name as identified on CN201482667 is “Loi Ying Liu,”
`as it appears on the ’374 patent. This is of course a material difference given that common
`inventorship renders CN201482667 not prior art under 35 U.S.C. § 102(a) (or any other provision).
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`Although the parties are scheduled to exchange objections at a later date, we write now to
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`provide Reynolds with an opportunity to produce a complete and accurate translation of
`CN201482667 before discovery closes. PMI/Altria reserve all rights, including the right to strike
`any reliance by Dr. Blalock on CN201482667 as prior art to the ’374 patent.
`
`Sincerely,
`
`/s/ Jennifer Koh
`
`Jennifer Koh
`of LATHAM & WATKINS LLP
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