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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`IRONWORKS PATENTS, LLC,
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`v.
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`APPLE INC.,
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`Plaintiff,
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`Defendants.
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`Case No. 17-1399-RGA
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`JOINT MOTION TO DISMISS AND [PROPOSED] ORDER
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`Plaintiff Ironworks Patents, LLC and Defendant Apple Inc. have reached a settlement
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`agreement that resolves all matters in this controversy between them and jointly move the Court
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`to dismiss the above-captioned action as follows:
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`IT IS HEREBY ORDERED that all claims, counterclaims, and defenses that have been,
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`or could have been, asserted in this lawsuit against Apple Inc. by Ironworks Patents, LLC are
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`dismissed with prejudice.
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`IT IS HEREBY ORDERED that all claims, counterclaims, and defenses that have been
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`or could have been asserted in this lawsuit against Ironworks Patents, LLC by Apple Inc. are
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`dismissed without prejudice.
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`IT IS HEREBY ORDERED that all attorneys’ fees, costs of court, and expenses shall be
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`borne by each party incurring the same.
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`IT IS HEREBY ORDERED that the Court shall retain jurisdiction to enforce the
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`settlement agreement.
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`1
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`Case 1:17-cv-01399-RGA Document 46 Filed 11/30/18 Page 2 of 2 PageID #: 520
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`Dated: November 30, 2018
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`
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`FARNAN LLP
`
`/s/ Michael J. Farnan
`Brian E. Farnan (Bar No. 4089)
`Michael J. Farnan (Bar No. 5165)
`919 N. Market St., 12th Floor
`Wilmington, DE 19801
`Telephone: (302) 777-0300
`bfarnan@farnanlaw.com
`mfarnan@farnanlaw.com
`
`David Berten (admitted Pro Hac)
`dberten@giplg.com
`Alison Aubry Richards (admitted Pro Hac)
`Arichards@giplg.com
`Hannah Sadler (admitted Pro Hac)
`hsadler@giplg.com
`Global IP Law Group, LLC
`55 W. Monroe St., Ste. 3400
`Chicago, Illinois 60603
`Phone: 312.241.1500
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`
`Attorneys for Plaintiff, Ironworks Patents, LLC
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`POTTER ANDERSON & CORROON LLP
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`/s/ Bindu A. Palapura
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Stephanie E. O’Byrne (#4446)
`Jennifer Penberthy Buckley (#6264)
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`sobyrne@potteranderson.com
`jbuckley@potteranderson.com
`
`Xin-Yi Zhou (admitted pro hac vice)
`O’MELVENY & MYERS LLP
`400 South Hope Street, 18th Floor
`Los Angeles, CA 90071
`Tel: (213) 430-6000
`vzhou@omm.com
`
`Luann L. Simmons (admitted pro hac vice)
`O’MELVENY & MYERS LLP
`Two Embarcadero Center, 28th Floor
`San Francisco, CA 94111
`Tel: (415) 984-8700
`lsimmons@omm.com
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`Attorneys for Defendant, Apple Inc.
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`IT IS SO ORDERED this ___ day of ______________, 2018.
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`_________________________________
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`United States District Judge
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`2
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