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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`TOYOTA MOTOR NORTH AMERICA, INC., SUBARU OF AMERICA, INC.,
`AMERICAN HONDA MOTOR CO., INC., NISSAN NORTH AMERICA, INC.,
`FORD MOTOR COMPANY, JAGUAR LAND ROVER NORTH AMERICA,
`LLC, and VOLVO CARS OF NORTH AMERICA, LLC,
`Petitioner
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`v.
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`CRUISE CONTROL TECHNOLOGIES LLC,
`Patent Owner
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`____________
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`CASE IPR: 2014-00280
`Patent 6,324,463
`____________
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`JOINT MOTION TO TERMINATE THE INTER PARTES REVIEW WITH
`RESPECT TO AMERICAN HONDA MOTOR CO., INC.
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`Pursuant to 35 U.S.C. § 317(a) and 37 C.F.R. § 42.72, Patent Owner and
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`American Honda Motor Co., Inc. (“Honda”) jointly request termination of Inter
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`Partes Review Case No. IPR2014-00289 with respect to Honda and its identified
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`real parties-in-interest Honda Motor Co. Ltd. and Honda Patents and Technologies,
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`N.A., LLC.
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`Patent Owner and Honda respectfully submit that termination is appropriate
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`because they have reached an agreement resolving the dispute involving the patent
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`at issue in the above-captioned Inter Partes Review, it is prior to full briefing on the
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`issues raised in the above-captioned Inter Partes Review, and the Board has not
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`issued a final written decision. Further, Honda represents that it will no longer
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`participate even if the Board does not terminate its participation in the above-
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`captioned Inter Partes Review. That means Honda will file no further papers. It
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`also will not be conducting any further cross examination of Patent Owner’s
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`witnesses and will not be participating in any oral argument.
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`As required under 35 U.S.C. §317(b) and 37 C.F.R. § 42.72(b), filed herewith
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`is a true copy of the written Confidential Settlement Agreement resolving the dispute
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`in the above-captioned Inter Partes Review and the related litigation. See
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`Confidential Exhibit 2000.
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`Also attached as Exhibit A to the written Settlement Agreement is a copy of
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`the Stipulated Motion for Dismissal With Prejudice of the action in the United States
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`District Court for the Eastern District of Michigan. Exhibit 2001, which is being
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`filed concurrently with this Joint Motion, includes the executed Stipulated Motion
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`for Dismissal With Prejudice and the resulting Order.
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`Patent Owner and Honda are concurrently filing a Joint Request that the
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`Settlement Agreement, Confidential Exhibit 2000, shall be treated as business
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`confidential information, shall be kept separate from the file of the involved patents,
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`and shall be made available only to Federal Government agencies on written request,
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`or to any person on a showing of good cause pursuant to 35 U.S.C. § 317(b) and 37
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`C.F.R. §42.74(c).
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`Dated: November 14, 2014
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`Respectfully submitted,
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`By: /John R. Kasha/
`John R. Kasha
`Reg. No. 53,100
`KASHA LAW LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(703) 867-1886, telephone
`(301) 340-3022, facsimile
`Email: john.kasha@kashalaw.com
`Counsel for Patent Owner
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`By: /John M. Caracappa/
`John M. Caracappa
`Reg. No. 43,532
`Tremayne M. Norris
`Reg. No. 58,683
`Stephanie L. Schonewald
`Reg. No. 72,452
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`Steptoe & Johnson LLP
`1330 Connecticut Avenue, NW
`Washington, DC 20036-1795
`Telephone: 202-429-3000
`Facsimile: 202-429-3902
`Counsel for American Honda Motor Co. Inc.
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`CERTIFICATE OF SERVICE
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`In accordance with 37 C.F.R. § 1.550(f), a copy of JOINT MOTION TO
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`TERMINATE THE INTER PARTES REVIEW WITH RESPECT TO AMERICAN
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`HONDA MOTOR CO., INC. filed on November 14, 2014 was duly served via
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`electronic mail upon Toyota-CCT-IPR@sughrue.com – counsel of record for
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`Petitioner Toyota Motor North America, Inc., Subaru of America, Inc., American
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`Honda Motor Co., Inc., Nissan North America, Inc., Ford Motor Company, Jaguar
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`Land Rover North America, LLC, and Volvo Cars of North America, LLC
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`(collectively “Petitioner”).
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`Respectfully submitted,
`/John R. Kasha/
`Registration No. 53,100
`Attorney for Patent Owner
`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(703) 867-1886, telephone
`(301) 340-3022, facsimile
`Email: john.kasha@kashalaw.com
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