From: Trials
`To: Joshua Stowell; Trials
`Cc: hamilton-ptab@perkinscoie.com; parker-ptab@perkinscoie.com; williams-ptab@perkinscoie.com; Joe Re; Brian
`Barnes
`Subject: RE: Imperative Care v. Inari Medical - IPR2025-00989 - Request to File Reply to the POPR
`Date: Thursday, September 25, 2025 10:47:37 AM
`Attachments: image001.png
`Counsel,
`
`Petitioner is authorized to file a preliminary reply of no more than five pages that
`addresses items numbered 1 and 2 in Petitioner’s email request. The preliminary
`reply is due no later than October 3, 2025.
`
`Regards,
`
`Andrew Kellogg,
`Deputy Chief Clerk, Trials
`Patent Trial and Appeal Board
`USPTO
`andrew.kellogg@uspto.gov
`(571) 272-5366
`
`
`
`
`From: Joshua Stowell <Joshua.Stowell@knobbe.com>
`Sent: Wednesday, September 24, 2025 7:28 PM
`To: Trials <Trials@USPTO.GOV>
`Cc: hamilton-ptab@perkinscoie.com; parker-ptab@perkinscoie.com; williams-
`ptab@perkinscoie.com; Joe Re <Joe.Re@knobbe.com>; Brian Barnes <Brian.Barnes@knobbe.com>
`Subject: Imperative Care v. Inari Medical - IPR2025-00989 - Request to File Reply to the POPR
`
`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before
`responding, clicking on links, or opening attachments.
`
`RE: Imperative Care, Inc. v. Inari Medical, Inc., IPR2025-00989
`
`Dear PTAB Trials,
`
`Petitioner requests leave to file a 5-page reply brief to Patent Owner’s Preliminary Response
`(“POPR”) pursuant to 37 CFR § 42.108(c) to respond to the arguments identified below. The parties
`have met and conferred, and Patent Owner does not oppose this request. Patent Owner’s counsel is
`CC’d on this email.
`
`
`
`
`
`
`
`
`Petitioner’s reply will address the following issues in the POPR:
`
`1. Patent Owner’s characterizations of Mr. Thornton’s deposition testimony in related IPR2024-
`01157 and IPR2025-00156 identified at pages 46, 49-50, 63, 65-66, 69-70 of the POPR.
`Petitioner contends good cause exists for a reply on this issue because the deposition in
`IPR2025-00156 occurred after Petitioner filed the Petition and because Petitioner has not had
`an opportunity to address Patent Owner’s characterizations of the testimony from either IPR.
`2. Patent Owner’s argument regarding the qualifications of a person of ordinary skill in the art.
`Petitioner contends good cause exists for a reply because Patent Owner’s expert, Paul
`Zalesky, has provided testimony since the filing of the Petition that Petitioner contends is
`relevant to this issue. Petitioner also seeks leave to file as a new exhibit the Transcript from
`the Deposition of Paul Zalesky dated June 23, 2025 (IPR2024-01157) with its reply.
`
`Petitioner proposes to file the reply within one week of any order authorizing the reply.
`
`If the Board would like to conduct a hearing to discuss this request, the parties are available at the
`following times for the requested conference call (all times eastern):
`
`Monday, September 29: 1 p.m.-5 p.m. (ET)
`Tuesday, September 30: 1 p.m.- 3 p.m. (ET)
`Wednesday, October 1: 1 p.m.-5 p.m. (ET)
`
`Best Regards,
`
`Joshua Stowell
`Counsel for Petitioner Imperative Care, Inc.
`
`Joshua Stowell
`Partner
`Joshua.Stowell@knobbe.com
`949-721-5252 Direct
`Knobbe Martens
`2040 Main St., 14th Fl.
`Irvine, CA 92614
`www.knobbe.com/joshua-stowell
`
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