`Case 1:19-cv-01937-MFK-JLH Document 276-1 Filed 01/13/23 Page 1 of 4 PagelD #: 39358
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`EXHIBIT 1
`EXHIBIT 1
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`Case 1:19-cv-01937-MFK-JLH Document 276-1 Filed 01/13/23 Page 2 of 4 PageID #: 39359
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`EXPRESS MOBILE, INC.,
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`
`Plaintiff,
`
`v.
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`GODADDY.COM, LLC,
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`
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`
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`Defendant.
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`
`
`Civil Action No. 1:19-cv-01937-MFK
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`)
`)
`)
`)
`)
`)
`)
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`))
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`JOINT STATEMENT OF UNDISPUTED FACTS
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`
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`Case 1:19-cv-01937-MFK-JLH Document 276-1 Filed 01/13/23 Page 3 of 4 PageID #: 39360
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`
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`I.
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`THE PARTIES’ STATEMENT OF FACTS THAT ARE ADMITTED AND
`REQUIRE NO PROOF
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`The parties stipulate to the following facts. These stipulated facts require no proof at trial
`
`and will become part of the evidentiary record in this case.
`
`A.
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`1.
`
`2.
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`Jurisdiction and Parties
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`No party contests subject-matter jurisdiction, personal jurisdiction, or venue.
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`Express Mobile, Inc. is a Delaware corporation with a place of business at 38
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`Washington Street, Novato, California 94947.
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`3.
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`GoDaddy.com, LLC is a limited liability company organized and existing under the
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`laws of Delaware, with a place of business at 14455 N. Hayden Road, Scottsdale, AZ 85260.
`
`B.
`
`4.
`
`The Patents-In-Suit
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`Steven H. Rempell, David Chrobak, and Ken Brown are the named inventors of
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`U.S. Patent No. 9,063,755 (“’755 Patent”).
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`5.
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`Express Mobile filed the PCT application for the ’755 Patent on April 6, 2009, with
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`a § 371 date of November 3, 2010.
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`2015.
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`6.
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`7.
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`The United States Patent and Trademark Office issued the ’755 Patent on June 23,
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`Steven H. Rempell, David Chrobak, and Ken Brown are the named inventors of
`
`U.S. Patent No. 9,471,287 (“’287 Patent”).
`
`Express Mobile filed the application for the ’287 Patent on May 8, 2015.
`
`The United States Patent and Trademark Office issued the ’287 Patent on October
`
`8.
`
`9.
`
`18, 2016.
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`10.
`
`Steven H. Rempell, David Chrobak, and Ken Brown are the named inventors of
`
`U.S. Patent No. 9,928,044 (“’044 Patent”).
`
`1
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`
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`Case 1:19-cv-01937-MFK-JLH Document 276-1 Filed 01/13/23 Page 4 of 4 PageID #: 39361
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`
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`11.
`
`12.
`
`27, 2018.
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`Express Mobile filed the application for the ’044 Patent on September 17, 2017.
`
`The United States Patent and Trademark Office issued the ’044 Patent on March
`
`13.
`
`Express Mobile owns all right, title and interest in and to the ’755, ’287, and ’044
`
`patents (collectively “Asserted Patents”) and has since at least May 5, 2010.
`
`C.
`
`14.
`
`The Prior Art
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`U.S. Patent Appl. Publ. No. 2009/0013310, which claims priority to U.S.
`
`Provisional Patent Appl. No. 60/969,428 with a priority date of August 31, 2007, was granted as
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`U.S. Patent No. 8,341,595 (“Arner”).
`
`15.
`
`U.S. Patent Application Publication No. 2007/0118844 (“Huang”) was filed on
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`November 23, 2005 and published on May 24, 2007 and incorporates by reference in its entirety
`
`the material included in U.S. Patent Appl. Publ. No. 2007/0079282 to Nachnani (“Nachnani”),
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`filed on Sep. 30, 2005 and published on Apr. 5, 2007.
`
`16.
`
`U.S. Patent Application Publication No. 2004/0243931 A1 (“Stevens”) was filed
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`as PCT application PCT/US02/20662 on July 1, 2002 and published on December 2, 2004.
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`
`
`2
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