`
`From:
`Sent:
`To:
`Cc:
`
`Subject:
`Attachments:
`
`Ferguson, Brian <brian.ferguson@weil.com>
`Wednesday, April 06, 2016 4:00 PM
`trials@uspto.gov
`Stockwell, Mitch; Kadaba, Wab; Olinger, Jonathan; Ansley, Sutton; Desai, Anish;
`Marando, Christopher; Garthe, Zac; Andersen, Timothy
`IPR2015-00698 and IPR2015-00700: Request to Substitute Documents
`27. Reply Brief (IPR2015-00698) (SEALED-CONFIDENTIAL)_Redacted.pdf; Exhibit 1014
`(IPR2015-00698) Declaration of Julie Davis (PUBLIC-REDACTIONS)_Redacted.pdf;
`Exhibit 1014 (IPR2015-00698) Declaration of Julie Davis (SEALED-
`CONFIDENTIAL)_Redacted.pdf; 30. Reply Brief (IPR2015-00700) (PUBLIC-
`REDACTED)_Redacted.pdf; 31. Reply Brief (IPR2015-00700) (SEALED-
`CONFIDENTIAL)_Redacted.pdf; Exhibit 1014 - (IPR2015-00700) Second Declaration of
`Shawn Burke_Redacted.pdf; Exhibit 1016 (IPR2015-00700) Declaration of Julie Davis
`REDACTED (SEALED-CONFIDENTIAL).pdf
`
`
`IPR2015-00698
`Patent No. 8,092,345
`
`IPR2015-00700
`Patent No. 8,579,767
`
`
`
`Dear Board:
`
`We are counsel of record for petitioner in the above-identified proceedings. Petitioner and Patent Owner have met and
`conferred regarding a discovery dispute between the parties. In order to resolve that dispute, Petitioner has agreed to
`strike paragraphs 24-28 in Exhibit 1016 in IPR2015-00700; paragraph 36 in Exhibit 1014 in IPR2015-00700; and
`paragraphs 23-27 in Exhibit 1014 in IPR2015-00698. Petitioner has also agreed to strike those portions of its reply briefs
`in IPR2015-00700 and IPR2015-00698 that rely on the above paragraphs. Attached to this email are copies of the revised
`exhibits with the relevant paragraphs redacted.
`
`Petitioner seeks permission to either substitute or expunge the above referenced exhibits and reply briefs and replace
`them with the revised documents attached to this email. Please let us know if Petitioner may proceed as requested, and
`if the Board has a preferred approach for accomplishing this. As noted, we have met and conferred with Patent Owner
`regarding this issue and the substitute exhibits/briefs, and Patent Owner does not object to Petitioner’s request.
`
`Respectfully submitted,
`
`Brian E. Ferguson
`Counsel of Record for Petitioner
`
`
`
`
`
`
`Brian E. Ferguson
`
`
`1
`
`Patent Owner adidas AG - Exhibit 2042
`Page 1 of 2
`
`
`
`Weil, Gotshal & Manges LLP
`1300 Eye Street NW, Suite 900
`Washington, DC 20005-3314
`brian.ferguson@weil.com
`+1 202 682 7516 Direct
`+1 301 801 8870 Mobile
`+1 202 857 0940 Fax
`
`
`
`The information contained in this email message is intended only for use of the individual or entity named above. If the
`reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended
`recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly
`prohibited. If you have received this communication in error, please immediately notify us by email, postmaster@weil.com,
`and destroy the original message. Thank you.
`
`2
`
`Patent Owner adidas AG - Exhibit 2042
`Page 2 of 2
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