`To:
`Cc:
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`Hayes. Jennifer
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`Jeremy Monaldo: Hyun Jin In: Schwartz. Daniel: Werber. Matthew; Christopher. Angelo: Christopher 0. Green:
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`Karl Renner
`Subject: IPR 2022-00222
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`Date:
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`Wednesday, March 15, 2023 1:46:16 PM
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`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before
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`responding, clicking on links, or opening attachments.
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`Your Honors,
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`Patent Owner seeks authorization from the Board to (1) move to terminate IPR2022-00222 because
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`Samsung is estopped from maintaining this IPR pursuant to at least 35 U.S.C. § 315(e)(l) and 316(b)
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`in view of the Board's recent findings in IPR2021-01413 that Samsung and Apple are real parties in
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`interest in that proceeding, involving the same patent, and that claims 1-7 of the patent are
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`unpatentable. Presenting oral argument constitutes "maintain[ing] a proceeding before the Office"
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`and would be prohibited should the Board determine that Samsung is estopped. 35 U.S.C. § 315(e)
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`(1). The Board also has discretion to terminate IPRs pursuant to at least 35 U.S.C. § 315(d), 37 CFR §
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`42.72, and 37 CFR § 42.5.
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`Patent also requests the Board stay this IPR pursuant to at least 35 U.S.C. § 315(d) until the Board
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`determines whether Samsung is estopped and prevented from maintain this proceeding under§ 315
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`and therefore requests authorization to file a motion to stay the proceeding, including oral
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`argument, until it determine whether this proceeding should be terminated.
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`Samsung opposes both requests.
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`Both parties are available to discuss these requests today between 2 and 4pm ET.
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`Best Regards,
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`Jennifer Hayes
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`Lead Counsel for Patent Owner
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`Reg. No. 50,845
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`Jennifer Hayes
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`Partner
`jenhayes@oixonpeabody com
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`,___ _____ __, Tl 213.629.6179 M/ 650.575.2400 F/ 866.781.9391
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`Nixon Peabody LLP
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`300 South Grand Avenue, Suite 4100, Los Angeles, CA 90071-3151
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`oixonpeabocty com @NixonPeabodyLLP
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`This email message and any attachments are confidential and may be protected by the attorney/client or other applicable privileges. The
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`IPR2022-00222
` Ex.3006
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`information is intended to be conveyed only to the designated recipient(s) of the message. If you are not an intended recipient, please
`notify the sender immediately and delete the message from your email system. Unauthorized use, dissemination, distr bution or
`reproduction of this message by other than the intended recipient is strictly prohibited and may be unlawful. Thank you.
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