`
`To: Trials
`
`Cc: Rita C. Chipperson; Morgan Golightly; Docketing; "gorourke@okorlaw.com”; "Sean O"Kelly"; All Rode-Dechert;
`“Icarrig@okorlaw.com”
`
`Subject: R@DE Microphones, LLC, et al. v. Zaxcom, Inc., IPR2025-00557
`
`Date: Thursday, July 17, 2025 12:51:04 PM
`
`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before
`responding, clicking on links, or opening attachments.
`
`To the Board:
`
`Petitioners RODE Microphones, LLC and Freedman Electronics Pty Ltd. (“Petitioners” or
`“RODE”) request authorization to move for leave to file a 6-page Reply to the Patent Owner’s
`Preliminary Response (“POPR”) in the above-referenced case, in order to address the
`following issues raised in the POPRs:
`
`1. Construction of “locally generated audio,” and/or the presence of such features in the
`prior artin view of Zaxcom's proposed construction;
`
`2. Construction of “local audio device wearable by a creator of said locally generated
`audio,” and/or the presence of such features in the prior art in view of Zaxcom's
`proposed construction;
`
`3. Construction of “master timecode” and “master timecode generator,” and/or the
`presence of such features in the prior artin view of Zaxcom's proposed construction;
`and
`
`4. Construction of “multi-track recorder,” and/or the presence of such features in the prior
`
`art in view of Zaxcom's proposed construction.
`R@DE proposes August 7, 2025 as the deadline for the Reply.
`
`Patent Owner Zaxcom, Inc. opposes RODE’s request. The parties have met and conferred on
`the matter but have been unable to reach agreement.
`
`The parties are available for a teleconference with the Board to discuss RADE’s request at the
`following times:
`
`® Friday, July18: 11:00 am -noon ET
`
`® Monday July 21: 9:00-11:30 am or 3:00-4:00 pm ET
`
`Regards,
`
`Michael A. Fisher
`Counsel for Petitioners RADE Microphones, LLC and Freedman Electronics Pty Ltd.
`
`Ex. 3001
`
`
`
`
`
`
`
`
`Michael A. Fisher
`Dechert LLP
`
`+1 215994 2079 Direct
`+1 917 406 5729 Mobile
`
`michael.fisher@dechert.com
`
`dechert.com
`
`This e-mail is from Dechert LLP, a law firm, and may contain information that is confidential
`or privileged. If you are not the intended recipient, do not read, copy or distribute the e-mail or
`any attachments. Instead, please notify the sender and delete the e-mail and any attachments.
`Thank you
`
`
`
`
`
`
`
`
`
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