`From:
`Sent:
`To:
`Cc:
`
`Subject:
`
`Dear Board,
`
`Strang, Jonathan (DC)
`Wednesday, September 30, 2020 9:08 AM
`Trials
`Gross, Gabriel (Bay Area); Lumish, Douglas (Bay Area); Lee, Joseph (OC); #C-M LGD
`SOLAS - LW TEAM; Davis, Blake (Bay Area); nrubin_raklaw.com; Reza Mirzaie; Kent
`Shum; rak_solas@raklaw.com; 'Philip Wang'
`IPR2020-01055 (LG Display v. Solas, ’137 patent) - Reply to POPR
`
`Petitioner LG seeks leave to file a five-page Reply addressing the NHK Spring/Fintiv issues raised in Patent Owner Solas’s
`preliminary response in the subject IPR. Good cause exists because Petitioner could not meaningfully address, predict, or
`rebut Patent Owner’s arguments, or the facts as they currently stand, when it filed its Petition nearly four months ago.
`
`In the spirit of cooperation between the parties, Petitioner offered to agree to a sur-reply of the same length if Patent
`Owner would agree to Petitioner’s proposed Reply. Patent Owner refused the offer. Nonetheless, in the interest of
`fairness and ensuring the Board is fully briefed before reaching its decision, Petitioner will not oppose a Patent Owner
`sur-reply should the Board grant leave to Petitioner to file a Reply.
`
`Patent Owner opposes because NHK Spring and Fintiv were designated precedential well before the Petition, and
`Petitioner already addressed discretionary denial in the Petition.
`
`If a five-page Reply is allowed, Patent Owner respectfully requests a five-page sur-reply limited to the same issues.
`
`The parties are available for a conference call with the Board at the following times (all times Eastern).
`
`•
`Friday, October 2, after 1 p.m.
`• Monday, October 5, after 1 p.m.
`•
`Tuesday, October 6, after noon.
`• Wednesday, October 7, after noon.
`
`Respectfully,
`
`Jonathan Strang
`Counsel for Petitioner
`
`Jonathan M. Strang
`LATHAM & WATKINS LLP
`555 Eleventh Street, NW
`Suite 1000
`Washington, D.C. 20004-1304
`Direct Dial: +1.202.637.2362
`Fax: +1.202.637.2201
`Email: jonathan.strang@lw.com
`https://www.lw.com
`
`1
`
`LG Display Co., Ltd.
`Exhibit 1020
`LG Display v. Solas
`IPR2020-01055
`
`Ex. 1020-001
`
`
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