`| }
`f
`PARTNERS
`
`July 25, 2019
`Via Email
`
`D. Timothy Daze
`Assistant General Counsel
`Los Angeles International Airport
`1 World Way
`Los Angeles, California 90045
`
`Haug Partners LLP
`745 Fifth Avenue, 10th Floor
`New York, NY 10161
`+1.212.588.0800 Main
`haugpartners.com
`
`JosephV. Saphia
`jsaphia@haugpartners.com
`
`Re:
`
`Notice for Los Angeles International Airport to cease use of shallow
`mountbollards
`
`Dear Mr. Daze:
`
`Werepresent RSA Protective Technologies, LLC (“RSA”). RSA is a leading designer,
`manufacturer, and installer of shallow mount bollards, who is the ownerof U.S. Patent No.
`8,215,865 (the “’865 Patent”), entitled “Anti-Ram System and MethodofInstallation.” The ’865
`patent covers an anti-ram system and method of construction having a shallow mounted base pad
`from which extenda plurality of bollards (a “shallow bollard system”). Enclosed you will find a
`copy of the °865 Patent.
`
`It has cometo our attention that infringing anti-ram systems (“shallow mountbollards”) are
`installed on Los Angeles International Airport (“LAX”) property, causing harm and damageto
`our client. Accordingly, RSA hereby demands that LAX cease use of any infringing shallow
`mountbollard.
`
`RSAreservesall rights and does not waive anyofits rights at law and equity. Please let me
`know if you would like to discuss at your earliest convenience.
`
`Very truly yours,
`
`Encl.
`
`Ameristar v RSA IPR2020-01369
`RSA Ex. 2013, Page 1
`
`Ameristar v RSA IPR2020-01369
`RSA Ex. 2013, Page 1
`
`
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