`5677
`
`IN THE UNITED STATES DISTRICT COURT
`FOR DISTRICT OF DELAWARE
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`
`ORCA SECURITY LTD.,
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`C.A. No. 23-758-JLH-SRF
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`
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`)))))))))
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`WIZ, INC.,
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`
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`Plaintiff and Counter-Defendant
`
`v.
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`Defendant and Counter-Plaintiff.
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`
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`WIZ, INC.’S STIPULATION CONCERNING INVALIDITY GROUNDS
`
`On July 31, 2024, Defendant Wiz, Inc. (“Wiz”) filed petition number IPR2024-01190
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`with the Patent Trial and Appeal Board requesting inter partes review (“IPR”) of U.S. Patent No.
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`11,740,926 (“the ’926 patent”). The petition advances at least one ground of unpatentability
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`against every claim of its associated patent (“the ’926 Challenged Claims”).
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`On August 7, 2024 Wiz filed petition number IPR2024-01191 with the Patent Trial and
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`Appeal Board requesting IPR of U.S. Patent No.11,775,326 (“the ’326 patent”). The petition
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`advances at least one ground of unpatentability against every claim of its associated patent (“the
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`’326 Challenged Claims”).
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`Wiz hereby stipulates that if the Patent Trial and Appeal Board institutes an IPR on the
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`petitions filed in IPR2024-01190 or IPR2024-01191, then Wiz will not pursue in this case,
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`against any of the ’326 and ’926 Challenged Claims in the instituted IPR, the specific grounds
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`advanced in the instituted IPR or any ground that reasonably could have been raised in an IPR
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`(i.e., any ground that could be raised under §§ 102 or 103 against any of the ’326 and ’926
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`Challenged Claims only on the basis of prior art patents or printed publications).
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`Case 1:23-cv-00758-JLH-SRF Document 213 Filed 12/10/24 Page 2 of 2 PageID #:
`5678
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`This stipulation is not intended and should not be construed to limit Wiz’s ability to
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`assert invalidity of the claims of the ’926 and ’326 patents on any other ground regardless of
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`
`
`
`
`/s/ Christine D. Haynes
`Frederick L. Cottrell, III (#2555)
`Kelly E. Farnan (#4395)
`Christine D. Haynes (#4697)
`RICHARDS, LAYTON & FINGER, P.A.
`One Rodney Square
`920 N. King Street
`Wilmington, DE 19801
`(302) 658-6541
`cottrell@rlf.com
`farnan@rlf.com
`haynes@rlf.com
`
`Attorneys for Defendant and Counter-
`Plaintiff Wiz, Inc
`
`
`whether the IPR is instituted.
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`
`
`
`
`OF COUNSEL:
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`Jordan R. Jaffe
`Catherine Lacy
`Alex Miller
`WILSON SONSINI GOODRICH &
`ROSATI, P.C.
`One Market Plaza
`Spear Tower, Suite 3300
`San Francisco, CA 94105
`(415) 947-2000
`
`Lisa D. Zang
`Callie Davidson
`WILSON SONSINI GOODRICH &
`ROSATI P.C.
`1900 Avenue of the Stars, 28th Floor
`Los Angeles, CA 90067
`(424) 466-6900
`
`Praatika Prasad
`WILSON SONSINI GOODRICH &
`ROSATI P.C.
`1301 Ave. of the Americas, 40th Fl.
`New York, NY 10019
`(212) 453-2803
`
`Dated: December 10, 2024
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`-2-
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