`To:
`
`Cc:
`Subject:
`Date:
`
`Medina, Rolando
`Trials; mraymond@paulweiss.com; sbaughman@paulweiss.com; GRP-AmgenIPR@paulweiss.com;
`cnyarady@paulweiss.com
`Marandett, Eric J.; Ives, Margaret E.; Wang, Sophie F.
`IPR2019-00791 and -00797
`Tuesday, July 2, 2019 3:12:53 PM
`
`Honorable Board,
`
`Patent Owner filed Patent Owner Preliminary Responses (POPRs) in each of the above-referenced
`proceedings on June 14, 2019. Petitioner, Kashiv BioSciences, requests a call with the Board to seek
`authorization to file a short Reply to the POPR in each proceeding. The proposed Replies would
`respond to Patent Owner’s 314(a) arguments under the General Plastics factors and certain claim
`construction arguments for two terms, “refold buffer” and “applying the refold solution.” Petitioner
`expects that it may submit limited additional exhibits for the purposes of evidencing the post-
`Petition information.
`
`Petitioner requests a 15 page Reply in each of the above-referenced proceedings, due 10 business
`days after an Order granting Petitioner authorization.
`
`Petitioner represents that it has met and conferred. It is Patent Owner’s position that the meet and
`confer process is incomplete.
`
`Patent Owner opposes Petitioner’s request.
`
`To the extent Petitioner is allowed a Reply, Patent Owner requests a responsive briefing of equal
`length and requests 5 additional business days (or one additional week) in addition to the days or
`weeks Petitioner is allotted between the initial granting of its request (whether orally or in a formal
`paper) and the due date for its paper in view of the fact that Patent Owner will not be able to start
`preparing its submission until it receives Petitioner’s Reply.
`
`In view of the holiday this week, the parties are available for a call on Thursday, July 11, between
`2:30-3:30 PM Eastern.
`
`Best regards,
`Rolando
`
`
`Rolando Medina, PhD, JD
`
`Choate, Hall & Stewart LLP
`Two International Place
`Boston, MA 02110
`t 617.248.4048
`f 617.502.4048
`
`
`
`rmedina@choate.com
`www.choate.com
`
`
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