`Case 1:20-cv-00393-LO-TCB Document 763-4 Filed 06/30/21 Page 1 of 2 Page|D# 20594
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`EXHIBIT 6
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`EXHIBIT 6
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`Case 1:20-cv-00393-LO-TCB Document 763-4 Filed 06/30/21 Page 2 of 2 PageID# 20595
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`From:
`Sent:
`To:
`Cc:
`Subject:
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`Counsel,
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`Koh, Jennifer (SD)
`Tuesday, June 1, 2021 4:16 PM
`RJREDVA
`#C-M PMIEDVA - LW TEAM
`RAI Strategic Holdings v. Altria Client Services (EDVa) - Summary Judgment
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`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 Further, since Reynolds has not withdrawn its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.
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`Regards,
`Jennifer
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`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
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