`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`Civil Action No. 14-850-RGA
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`JURY TRIAL DEMANDED
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`INNOVATIVE DISPLAY
`TECHNOLOGIES LLC,
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`
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`Plaintiff,
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`
`v.
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`
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`GENERAL MOTORS LLC,
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`
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`Defendant.
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`
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`STIPULATION OF VOLUNTARY PARTIAL DISMISSAL
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`Plaintiff Innovative Display Technologies LLC (“IDT”) and Defendant General Motors
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`LLC (“GM”), hereby agree, subject to the approval of the Court, to:
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`1) the voluntary dismissal with prejudice of Count 7 of the Amended Complaint (D.I. 11 at
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`13-14) concerning U.S. Patent No. 6,886,956 (“the ’956 Patent”), and any prayers for
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`relief predicated thereon, but only to the extent that they are based on products provided
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`by Koito Manufacturing Co., Ltd. or its Affiliates (collectively “Koito”) or by Stanley
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`Electric Co., Ltd. or its Affiliates (collectively “Stanley”); and
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`2) the voluntary dismissal with prejudice of that portion of GM’s First and Second
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`Counterclaims (D.I. 12 at 16-17) concerning the ’956 Patent, and any prayers for relief
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`predicated thereon, but only to the extent that they are based on products provided by
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`Koito or Stanley.
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`This voluntary dismissal shall not be construed as a dismissal of Count 7, or any prayers for
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`relief predicated thereon, with respect to products not provided by Koito or Stanley, or of that
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`portion of GM’s First and Second Counterclaims concerning the ’956 Patent, or any prayers for
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`relief predicated thereon, with respect to products not provided by Koito or Stanley.
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`As grounds, the parties state that the components provided by Koito and Stanley and utilized
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`Petitioners Koito et al. - Exhibit 1013 - Page 1
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`
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`Case 1:14-cv-00850-RGA Document 40 Filed 07/22/15 Page 2 of 2 PageID #: 541
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`by GM that are accused of infringing the ’956 Patent have become subject to a license. As to the
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`scope of IDT’s Amended Complaint and GM’s Counterclaims hereby dismissed, all parties shall
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`bear their own fees and costs.
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`
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`Respectfully submitted,
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`CONNOLLY GALLAGHER LLP
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`
`
`
`
`
`
`
`/s/ Ryan P. Newell
`Arthur G. Connolly III
`Ryan P. Newell
`Mary I. Akhimien
`Connolly Gallagher LLP
`The Brandywine Building
`1000 West Street
`Wilmington, DE 19801
`aconnolly@connollygallagher.com
`mewell@connollygallagher.com
`makhimien@connollygallagher.com
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`Attorneys for Defendant General Motors
`Company
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`Dated: July 22, 2015
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`FARNAN LLP
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`
`
`
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`
`
`/s/ Brian E. Farnan
`Brian E. Farnan (Bar No. 4089)
`919 North Market St., 12th Floor
`Wilmington, DE 19801
`(302) 777-0300
`bfarnan@farnanlaw.com
`
`Attorneys for Plaintiff
`Innovative Display Technologies LLC
`
`
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`IT IS SO ORDERED this ______ day of ________________________, 2015.
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`______________________________________
`The Honorable Richard G. Andrews
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`
`
`2
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`Petitioners Koito et al. - Exhibit 1013 - Page 2
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