`Suite 600
`
`Fans‘: 612.332.9081
`
`Madison, WI
`
`'5 5703
`
`Telephone: (608) 280-67 50
`
`wwwmerchantgould.com
`:\ Pm&_xuurul Curpurau-It
`
`Dm-ct Cnnuu
`
`(508) 280-6757
`wward@merchamgould.com
`
`July 15. 2016
`
`Kevin P. Shortsle
`
`McDern1ott Will & Emery LLP
`227 West Monroe Street
`
`Chicago. IL 60606-5096
`
`Re:
`
`Nalco Company. LLC v. Solenis LLC
`Case No. l5cv8913
`
`Dear Kevin:
`
`We are writing to notify you that there is a conflict of interest that precludes Dr. David Dyer. Solenis’
`expert declarant in its recently filed IPRS. from offering opinions related to the validity of Nalco’s patents.
`
`Specifically. Dr. Dyer received confidential information ursuant to an NDA between Nalco and
`International Pa er G)r. D er’s em 10 er)
`
`
`
`construction. Imexpected results. and secondary considerations of non-obviousness.
`
`Moreover. we are troubled by the fact that Solenis knew or should have known of this conflict fiom
`docimients previously produced by Nalco demonstrating that Dr. Dyer had received confidential
`infonnation. (See NAL003656-67: NAL0009120-26: NAL0009078-104.)
`
`Please let us know by COB Thursday. July 21 if you intend to withdraw and/or refile the [PR5 in view of
`Dr. Dyer’s conflict of interest. Unless we receive your confirmation by then. we will seek Board consent
`to file a motion to disqualify Dr. Dyer.
`
`Best regards.
`
`MERCHANT & GOULD. P.C.
`
`Wendy Ward
`
`Atlanta
`
`Denver
`
`Knoxville
`
`Madison
`
`Minneapolis
`
`New York
`
`Seattle
`
`W'ashington DC
`
`
`
`Solenis v. Ecolab USA, IPR2016-01281, Exhibit 2007
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