A Standard Document that a petitioner's counsel may use as a starting point when drafting a response to a patent owner's request for a rehearing of a Patent Trial and Appeal Board (PTAB) decision granting institution of inter partes review (IPR) under 37 C.F.R. § 42.71(c) and (d). This Standard Document includes model language the petitioner's counsel may use to respond to patent owner arguments that the PTAB misapprehended or overlooked certain matters in its IPR institution decision. This Standard Document has integrated drafting notes with important explanations and drafting tips.