A sample opposition to a motion for additional discovery regarding a purported real party in interest or privy of a petitioner in an inter partes review (IPR) proceeding at the Patent Trial and Appeal Board (PTAB). This Standard Document includes language that a petitioner's counsel may use as a starting point to oppose the patent owner's request for additional discovery, including addressing the "Garmin factors" identified in the PTAB's precedential Garmin International, Inc. v. Cuozzo Speed Technologies LLC decision. This Standard Document has integrated drafting notes with important explanations and drafting tips.