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Case: 1:13-cv-08413 Document #: 74 Filed: 11/14/14 Page 1 of 2 PageID #:414
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`
`
`VELOCITY PATENT LLC,
`
`
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`MERCEDES-BENZ USA, LLC;
`MERCEDES-BENZ U.S.
`INTERNATIONAL INC.
`
`
`
`
`
`
`
`Defendants.
`
`
`
`
`)
`
`)
`
`)
`Civil Action No. 1:13-cv-08413
`)
`
`)
`) Hon. John W. Darrah
`)
`
`)
`
`)
`)
`)
`)
`)
`
`
`
`
`
`
`
`
`
`
`STIPULATED ORDER
`
`Pursuant to the Court’s instruction at the Status Hearing on September 16, 2014,
`Plaintiff Velocity Patent LLC and Defendants Mercedes-Benz USA, LLC and Mercedes-
`Benz U.S. International Inc. (collectively “the parties”) have agreed to the following
`Stipulated Order concerning the stay of Civil Action No. 1:13-cv-08413 (“the Action”):
`
`1. The Action is stayed until completion of the reexamination of U.S. Patent No.
`5,954,781 (which reexamination has been assigned Reexamination Control No.
`90/013,252), including any appeals taken by Velocity Patent.
`
`2. The stay entered by this Stipulated Order is limited to U.S. Patent Application No.
`90/013,252. The stay is not affected by any subsequent reexamination request or
`petition for inter partes review filed with the USPTO (e.g., a further request for ex
`parte reexamination). Defendants reserve the right, however, to renew their motion
`to stay the Action until the completion of their IPR proceeding, IPR2014-01247, in
`the event such proceeding takes longer than such reexamination.
`
`
`3. Defendants shall provide, to the extent it has not done so already within thirty (30)
`days of entry of this Order, a list of third parties (including address) that supply
`components (including hardware and software) of the features identified in Plaintiff’s
`Preliminary Infringement Contentions to Defendants or Defendant’s related foreign
`entities. For each third party identified, Defendants shall, to the extent it has not done
`so already, also state whether it has control over the third party, and whether
`Defendant’s counsel can accept service of process requesting production of relevant
`evidence (e.g., a subpoena) on behalf of the third party.
`
`
`
`

`

`Case: 1:13-cv-08413 Document #: 74 Filed: 11/14/14 Page 2 of 2 PageID #:415
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`Respectfully submitted,
`
`/s/ James A. Shimota
`
`James A. Shimota (IL Bar No. 6270603)
`Howard E. Levin (IL Bar No. 6286712)
`Aaron C. Taggart (IL Bar No. 6302068)
`MAVRAKAKIS LAW GROUP LLP
`180 North LaSalle Street, Suite 2215
`Chicago, Illinois 60601
`Telephone: 312-216-1626
`jshimota@mavllp.com
`hlevin@mavllp.com
`ataggart@mavllp.com
`
`Counsel for Plaintiff Velocity Patent LLC
`
`
`
`
`Dated: November 13, 14
`
`/s/ Celine J. Crowson
`
`Steven A. Weiss
`David L. DeBruin
`Anand C. Mathew
`SCHOPF & WEISS LLP
`One South Wacker Drive, 28th Floor
`Chicago, Illinois 60606
`Telephone: 312-701-9300
`Weiss@sw.com
`DeBruin@sw.com
`Mathew@sw.com
`
`
`Admitted Pro Hac Vice
`Raymond A. Kurz
`Celine Jimenez Crowson
`Joseph J. Raffetto
`HOGAN LOVELLS US LLP
`Columbia Square
`555 Thirteenth Street, NW
`Washington, D.C. 20004
`Telephone: 202-637-5600
`raymond.kurz@hoganlovells.com
`celine.crowson@hoganlovells.com
`joseph.raffetto@hoganlovells.com
`
`Counsel for Defendants
`Mercedes-Benz USA, LLC and
`Mercedes-Benz U.S. International, Inc.
`
`DATED: 11/14/14
`
`
`
`JOHN W. DARRAH
`UNITED STATES DISTRICT JUDGE
`
`

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