`Thursday, September 10, 2020 3:21 PM
`Bokar, Erik M. (Assoc-CHI-IP-Tech); Heintz, James M.; Miller, Tiffany; dlachervon-
`oneworld@dlapiper.com
`Lukas Jr., James J. (Shld-Chi-IP-Tech); Jarosik, Gary (Shld-Chi-IP-Tech); Jarosik, Gary (Shld-Chi-IP-
`Tech); Levinstein, Matthew J. (Shld-Chi-IP-Tech); Gilford, Benjamin P. (Assoc-Chi-IP-Tech); Sand, Callie
`(Assoc-CHI-IP-Tech)
`RE: IPR2020-00883 to 00888, PGR2020-0059 to 00061 - Motion to Seal
`
`
`From:
`Sent:
`To:
`
`Cc:
`
`Subject:
`
`*EXTERNAL TO GT*
`
`Dear Erik,
`
`While I appreciate you asking whether Petitioner will join your motion to seal, your 11th‐hour request raises a significant
`concern as to how your firm may be treating documents produced in the litigation. I should not have to remind you that
`your law firm agreed, under the Protective Order in the District Court case, to limit its use of documents designated
`“Highly Confidential – Outside Counsel’s Eyes Only” for the litigation only. You particularly agreed to Paragraph 8 of the
`Protective Order which states that such documents “may only be used for purposes of preparation, trial, and appeal of
`this action. Neither ‘Highly Confidential – Outside Counsel’s Eyes Only’ nor ‘Confidential’ information may be used
`under any circumstances for any other proceeding….”
`
`The documents you identify in your email are apparently designated under the Protective Order according to the above,
`and I take issue with your request for me to make an accelerated decision to waive your obligations under the Protective
`Order on the afternoon that your Opposition is due. With due respect, my afternoon today has been booked with
`ongoing meetings in another matter and I simply cannot agree on such short notice to let you submit those documents
`without having a chance to confer with members of the litigation team. I will note, however, that filing the identified
`documents (or other similarly designated documents) with the PTAB – even under seal – in the absence of permission is
`itself a violation of the same Protective Order.
`
`Respectfully,
`Ed Sikorski
`
`From: bokare@gtlaw.com <bokare@gtlaw.com>
`Sent: Thursday, September 10, 2020 12:00 PM
`To: Sikorski, Ed <Ed.Sikorski@us.dlapiper.com>; Heintz, James M. <Jim.Heintz@us.dlapiper.com>; Miller, Tiffany
`<tiffany.miller@us.dlapiper.com>; dlachervon‐oneworld@dlapiper.com
`Cc: lukasj@gtlaw.com; Jarosikg@gtlaw.com; Jarosikg@gtlaw.com; levinsteinm@gtlaw.com; gilfordb@gtlaw.com;
`sandc@gtlaw.com
`Subject: IPR2020‐00883 to 00888, PGR2020‐0059 to 00061 ‐ Motion to Seal
`
`[EXTERNAL]
`
`Dear Ed,
`
`In connection with Chervon’s Opposition to Petitioner’s Motion to Update Mandatory Notices due today, Chervon
`intends to file under seal the following documents produced by TTI in the parallel district court litigation having
`beginning Bates number:
`
`1
`
`Chervon (HK) Limited
`Exhibit 2020 - Page 1
`
`
`
` TTI1293_736;
` TTI1293_764; and
` TTI1293_1293.
`
`
`Please let us know if you would like to join the motion to seal these exhibits, see attached.
`
`Thanks,
`
`Erik M. Bokar
`Associate
`Greenberg Traurig, LLP
`77 West Wacker Drive | Suite 3100 | Chicago, IL 60601
`T +1 312.456.1050 | C 216 534 0056
`bokare@gtlaw.com | www.gtlaw.com | View GT Biography
`
`
`
`
`
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`
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`
`2
`
`Chervon (HK) Limited
`Exhibit 2020 - Page 2
`
`