`U.S. Patent No. 7,816,392
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________________
`
`WILLOWOOD USA, LLC
`Petitioner,
`
`v.
`
`BASF SE
`Patent Owner
`
`_______________________________
`
`Case IPR2018-01096
`Patent No. 7,816,392
`
`_______________________________
`
`JOINT MOTION TO EXTEND THE DUE DATE FOR
`PATENT OWNER PRELIMINARY RESPONSE
`
`
`
`Case IPR2018-01096
`U.S. Patent No. 7,816,392
`I.
`RELIEF REQUESTED
`
`Patent Owner BASF SE ("Patent Owner") and Petitioner Willowood USA,
`
`LLC ("Petitioner") jointly request that the Board enter an Order extending the
`
`deadline for Patent Owner's Preliminary Response by two weeks. As extended,
`
`Patent Owner's Preliminary Response would be due on September 6, 2018.
`
`Permission to file this motion as an attachment by email was granted by the
`
`Board by email on August 20, 2018.
`
`II.
`
`REASONS FOR REQUESTED RELIEF
`
`Patent Owner's Preliminary Response is currently due on August 23, 2018.
`
`The parties are currently engaged in settlement discussions, which involve many
`
`complex issues. The parties anticipate the need for additional time to determine
`
`whether settlement can be reached in advance of the current deadline for Patent
`
`Owner to file its Preliminary Response. As a result, the parties respectfully request
`
`that the Board enter an Order extending the deadline for Patent Owner's
`
`Preliminary Response by two weeks. As extended, Patent Owner's Preliminary
`
`Response would be due on September 6, 2018.
`
`Under Rule 42.5(c)(2), the Board has discretion to modify the deadline for
`
`Patent Owner's Preliminary Response and good cause for such modification has
`
`been shown above.
`
`1
`
`
`
`Case IPR2018-01096
`U.S. Patent No. 7,816,392
`
`III. CONCLUSION
`
`For the foregoing reasons, the parties respectfully request that the Board
`
`grant this motion to extend the due date for Patent Owner Preliminary Response
`
`until September 6, 2018.
`
`August 20, 2018
`
`Respectfully submitted,
`
`/Jeffrey S. Ginsberg/
`Jeffrey S. Ginsberg (Reg. No. 36,148)
`Zhiqiang Liu (Reg. No. 60,987)
`Ryan M. Mott (Reg. No. 65,214)
`PATTERSON BELKNAP WEBB & TYLER LLP
`1133 Avenue of the Americas
`New York, NY 10036-6710
`Tel.: (212) 336-2630
`Fax: (212) 336-1270
`E-mail: jginsberg@pbwt.com
`
`Attorneys for Patent Owner
`
`/Steven E. Tiller/
`Steven E. Tiller (Reg. No. 39,859)
`Peter J. Davis (Reg. No. 36,119)
`WHITEFORD, TAYLOR & PRESTON, LLP
`Seven Saint Paul Street, Suite 1500
`Baltimore, Maryland 21202-1636
`Tel.: (410) 347-9425
`Fax: (410) 223-4325
`stiller@wtplaw.com
`pdavis@wtplaw.com
`
`Attorneys for Petitioner
`
`- 2 -
`
`
`
`Case IPR2018-01096
`U.S. Patent No. 7,816,392
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on
`
`August 20, 2018, the foregoing JOINT MOTION TO EXTEND THE DUE DATE
`
`FOR PATENT OWNER PRELIMINARY RESPONSE was served via electronic
`
`mail upon the following counsel of record for the Petitioner:
`
`LEAD COUNSEL
`
`BACKUP COUNSEL
`
`Steven E. Tiller
`WHITEFORD, TAYLOR & PRESTON, LLP
`Seven Saint Paul Street, Suite 1500
`Baltimore, Maryland 21202-1636
`Tel.: 410-347-9425
`stiller@wtplaw.com
`
`Peter J. Davis
`WHITEFORD, TAYLOR & PRESTON, LLP
`Seven Saint Paul Street, Suite 1500
`Baltimore, Maryland 21202-1636
`Tel. 410-347-8738
`pdavis@wtplaw.com
`
`August 20, 2018
`
`Respectfully submitted,
`
`/Jeffrey S. Ginsberg/
`Jeffrey S. Ginsberg (Reg. No. 36,148)
`Zhiqiang Liu (Reg. No. 60,987)
`Ryan M. Mott (Reg. No. 65,214)
`PATTERSON BELKNAP WEBB & TYLER LLP
`1133 Avenue of the Americas
`New York, NY 10036-6710
`Tel.: (212) 336-2630
`Fax: (212) 336-1270
`E-mail: jginsberg@pbwt.com
`
`Attorneys for Patent Owner
`
`
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