`To:
`Cc:
`Subject:
`Date:
`
`Ted.Cannon
`Trials
`Stein, James; Stroud Jonathan; Mansinghani Roshan; Lavenue, Lionel; Brent.Babcock; BoxPGL44
`IPR2016-01643: follow up to May 17, 2018 conference call
`Thursday, May 31, 2018 6:10:16 PM
`
`PTAB Trials,
`
`We are writing, pursuant to the Board’s request during the May 17, 2018 conference call, to
`put into an email the parties’ proposal regarding the disposition of claims and grounds that
`were not originally instituted in this IPR. The parties propose: (1) that the Board reinstitute
`this IPR on all claims and all grounds; (2) thereafter, that the parties stipulate to withdraw
`the originally uninstituted grounds and uninstituted claims from the proceeding; and (3) that
`the Board state in its re-institution decision (or another paper) that, pursuant to the parties’
`agreement: (a) the claims and grounds that were not instituted in the original decision will
`not be pursued by Unified and (b) Intellectual Ventures will not seek any further briefing,
`discovery, or evidence on those claims and grounds.
`
`Respectfully,
`
`Ted Cannon
`Counsel for Patent Owner
`
`Ted M. Cannon
`Partner
`Ted.Cannon@knobbe.com
`949-721-2897 Direct
`Knobbe Martens
`
`I N T E L L E C T U A L P R O P E R T Y L A W
`five decades. one focus.
`2040 Main Street, 14th Floor
`Irvine, CA 92614
`www.knobbe.com/ted-cannon
`
`NOTICE: This email message is for the sole use of the intended recipient(s) and may contain confidential and
`privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not
`the intended recipient, please contact the sender by reply email and destroy all copies of the original
`message.
`
`
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