`To:
`Cc:
`Subject:
`Date:
`
`Chen, George
`Trials
`Isaac Rabicoff; Smith, Cory
`IPR No. 2020-00763: Request for conference call with the Board
`Tuesday, July 14, 2020 1:42:19 PM
`
`Dear Ms. Johnson:
`
`I write on behalf of Petitioner seeking a conference call with the Board in connection with IPR Case No. 2020-00763 to
`request permission for Petitioner to submit a brief reply to Patent Owner’s Preliminary Response. Petitioner seeks a short
`reply paper in order to address certain issues that only arose, for the first time, in Patent Owner’s Preliminary Response.
`
`Patent Owner’s first argument on pages 2-5 of its Preliminary Response introduces several misstatements regarding Chase
`being a real party-in-interest and privy. These misstatements, if not corrected, could be dispositive on the issue of whether
`Petitioner is time-barred under 35 U.S.C. § 315(b).
`
`Accordingly, Petitioner seeks an opportunity to assist the Board by identifying and correcting these inaccurate statements.
`To avoid introducing additional argument into the record at this time, Petitioner requests permission to file a 3-page reply that
`identifies and corrects the misstatements in the relevant portions of the Preliminary Response.
`
`Petitioner has met and conferred with Patent Owner regarding these issues, and the parties were unable to reach an
`agreement. The parties are available for a conference call with the Board during the following days/times:
`
`Thursday, July 16, 2020 (12 noon – 2 pm ET)
`Friday, July 16, 2020 (12 noon- 2 pm ET)
`
`Sincerely yours,
`
`George Chen
`Lead Counsel for Petitioner
`
`GEORGE C. CHEN
`Partner
`george.chen@bclplaw.com
`T: +1 602 364 7367 M: +1 602 769 7233
`
`BRYAN CAVE LEIGHTON PAISNER LLP
`Two North Central Avenue, Suite 2100, Phoenix, AZ 85004-4406
`bclplaw.com
`LinkedIn Twitter Facebook
`Phoenix Patent Law Lawyer of the Year, The Best Lawyers in America 2020; Phoenix Intellectual Property Litigation
`Lawyer of the Year, The Best Lawyers in America 2019; WTR1000 2020; Top Attorney, Super Lawyers 2020; Power
`List, Lawyers of Color 2020
`
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`
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`
`IPR2020-00763
`Ex. 3001
`
`
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