throbber
From: "Modi, Naveen" <naveenmodi@paulhastings.com>
`Subject: RE: Re: Samsung v. Broadphone IPRs2024-00153, 2024-00154 and
`2024-00155 - Patent Owner's Preliminary Responses
`Date: February 26, 2024 at 04:47:38 HST
`To: "Christian W. Conkle" <cconkle@raklaw.com>
`Cc: Alexandra Loew <aloew@raklaw.com>, Samsung-Broadphone-IPR <PH-
`Samsung-Broadphone-IPR@paulhastings.com>, "broadphone@raklaw.com"
`<broadphone@raklaw.com>, Reza Mirzaie <rmirzaie@raklaw.com>
`
`Christian,
`
`Samsung will take a position after it is able to review Broadphone’s as-filed motion.
`
`Many thanks,
`Naveen
`
`Naveen Modi
`Global Co-Chair of IP & Partner
`Paul Hastings LLP
`(202) 551-1990
`
`From: Christian W. Conkle <cconkle@raklaw.com>
`Sent: Friday, February 23, 2024 3:14 PM
`To: Modi, Naveen <naveenmodi@paulhastings.com>
`Cc: Alexandra Loew <aloew@raklaw.com>; Samsung-Broadphone-IPR <PH-Samsung-
`Broadphone-IPR@paulhastings.com>; broadphone@raklaw.com; Reza Mirzaie
`<rmirzaie@raklaw.com>
`Subject: [EXT] Re: Samsung v. Broadphone IPRs2024-00153, 2024-00154 and 2024-
`00155 - Patent Owner's Preliminary Responses
`
`Naveen, Following up on this. Please let us know your position today so that we can include it in our motion. All best, Christian W. Conkle Russ, August & Kabat 12424 Wilshire Boulevard, 12th Floor Los Angeles, CA 90025310 826-7474 On Feb
`
`Naveen,
`
`Following up on this. Please let us know your position today so that we can include
`it in our motion.
`
`All best,
`
`Christian W. Conkle
`Russ, August & Kabat
`12424 Wilshire Boulevard, 12th Floor
`
`Broadphone LLC, Ex. 2002
`Samsung Electronics Co., Ltd., et al. v. Broadphone LLC, IPR2024-00155
`
`

`

`Los Angeles, CA 90025
`310 826-7474
`
`
`
`On Feb 21, 2024, at 16:51, Reza <rmirzaie@raklaw.com> wrote:
`
`
`Hello Naveen,
`
`
`As a quick follow-up to Christian’s email, we intend to email the Board today, at 7
`pm PST. Please let us know whether your client opposes the relief we seek before
`then and we will let the Board know. If so, please let us know what prejudice you
`believe your client has suffered. And if we do not hear from you by 7 pm, we will
`let the Board know that we’ve notified your side and are still waiting for a response
`(which is understandable given the timing of all this).
`
`
`Thanks,
`Reza
`
`
`
`On Feb 21, 2024, at 3:03 PM, Christian W. Conkle <cconkle@raklaw.com> wrote:
`
`Naveen,
`
`
`Due to an internal miscommunication, our filing staff was unexpectedly unable to
`log into the new electronic filing system until this morning. Because we served you
`with copies of the briefs before the deadline, and because the briefs were filed less
`than twenty-four hours after the deadline, we believe that excusing the late filing
`would be supported by good cause and would be in the interests of justice.
`
`
`We intend to email the Board requesting that the Board deem the POPRs timely
`filed or excused. Please indicate whether you oppose that request. To be clear, we
`have not communicated with the Board without copying you.
`
`
`All best,
`
`Christian W. Conkle
`Russ, August & Kabat
`12424 Wilshire Boulevard, 12th Floor
`
`Broadphone LLC, Ex. 2002
`Samsung Electronics Co., Ltd., et al. v. Broadphone LLC, IPR2024-00155
`
`

`

`Los Angeles, CA 90025
`310 826-7474
`
`
`
`On Feb 21, 2024, at 13:12, Modi, Naveen <naveenmodi@paulhastings.com>
`wrote:
`
`
`Counsel,
`
`
`We noticed that Broadphone filed the POPRs today. From Samsung’s perspective, these
`were filed late. We assume Broadphone will contact the Board regarding its late
`filings. Also, we ask again for more details regarding the technical difficulties you
`encountered. Please also provide us with details of all communications with the Board
`regarding the filings, including copies of all correspondence you have had with the
`Board on which Samsung was not copied.
`
`
`Thanks,
`Naveen
`
`
`Naveen Modi
`Global Co-Chair of IP & Partner
`Paul Hastings LLP
`(202) 551-1990
`
`
`From: Modi, Naveen
`Sent: Wednesday, February 21, 2024 12:48 PM
`To: Alexandra Loew <aloew@raklaw.com>; Samsung-Broadphone-IPR <PH-Samsung-
`Broadphone-IPR@paulhastings.com>
`Cc: broadphone@raklaw.com
`Subject: RE: [EXT] Samsung v. Broadphone IPRs2024-00153, 2024-00154 and 2024-
`00155 - Patent Owner's Preliminary Responses
`
`
`Counsel,
`
`
`Thank you for your email. Can you please explain the technical difficulties you
`had? Please also include us on any communications with the Board on this issue.
`
`
`Many thanks,
`Naveen
`
`Broadphone LLC, Ex. 2002
`Samsung Electronics Co., Ltd., et al. v. Broadphone LLC, IPR2024-00155
`
`

`

`
`
`Naveen Modi
`Global Co-Chair of IP & Partner
`Paul Hastings LLP
`(202) 551-1990
`
`
`From: Alexandra Loew <aloew@raklaw.com>
`Sent: Tuesday, February 20, 2024 11:57 PM
`To: Samsung-Broadphone-IPR <PH-Samsung-Broadphone-IPR@paulhastings.com>
`Cc: broadphone@raklaw.com
`Subject: [EXT] Samsung v. Broadphone IPRs2024-00153, 2024-00154 and 2024-00155 -
`Patent Owner's Preliminary Responses
`
`Counsel Please find attached Patent Owner's Preliminary Responses in the above-referenced cases. Please note that, due to technical difficulties with the online system, we will be filing these as soon as possible tomorrow morning.
`Counsel
`
`
`Please find attached Patent Owner's Preliminary Responses in the above-referenced
`cases. Please note that, due to technical difficulties with the online system, we will
`be filing these as soon as possible tomorrow morning.
`
`*****************************************************************************
`*************
`This message is sent by a law firm and may contain information that is privileged or confidential.
`If you received
`this transmission in error, please notify the sender by reply e-mail and delete the message and
`any attachments.
`If you reply to this message, Paul Hastings may collect personal information including your
`name, business name
`and other contact details, and IP address. For more information about Paul Hastings’ information
`collection, privacy
`and security principles please click HERE. If you have any questions, please
`contact Privacy@paulhastings.com.
`
`
`Broadphone LLC, Ex. 2002
`Samsung Electronics Co., Ltd., et al. v. Broadphone LLC, IPR2024-00155
`
`

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