`Filed: October 28, 2015
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`
`
`
`
`FORD MOTOR COMPANY,
`
`Petitioner
`
`v.
`
`INNOVATIVE DISPLAY TECHNOLOGIES, LLC
`
`Patent Owner
`
`____________
`
`Case No. IPR2015-01540
`Patent No. 6,886,956
`
`____________
`
`JOINT MOTION TO TERMINATE INTER PARTES REVIEW
`
`
`
`
`
`
`
`Pursuant to 35 U.S.C. § 317(a) and 37 C.F.R. §§ 42.72 and 42.74, Petitioner
`
`Case No. IPR2015-001540
`Patent No. 6,886,956
`
`
`
`Ford Motor Company
`
`(“Ford”) and Patent Owner
`
`Innovative Display
`
`Technologies, LLC (“Patent Owner”) jointly request termination of Inter Partes
`
`Review Case No. IPR2015-01540. The Board authorized the parties to file this
`
`joint request via e-mail correspondence on October 27, 2015.
`
`Patent Owner and Ford respectfully submit that termination is appropriate
`
`because they have reached an agreement resolving the dispute involving the patent
`
`at issue in the above-captioned Inter Partes Review, prior to any institution
`
`decision in the above-captioned Inter Partes Review. Further, Ford represents that
`
`it will no longer participate even if the Board does not terminate the above-
`
`captioned Inter Partes Review. This means that Ford will file no further papers,
`
`will not be conducting any further cross examination of any Patent Owner
`
`witnesses, and will not be participating in any oral argument.
`
`As required under 35 U.S.C. § 317(b) and 37 C.F.R. § 42.72(b), filed
`
`herewith is a true copy of the written settlement agreement (“Agreement”)
`
`resolving the dispute in the above-captioned Inter Partes Review and the related
`
`litigation. See Confidential Exhibit 1015. The parties do not foresee any further
`
`litigation among them relating to the Subject Patent. The parties further certify
`
`that there are no collateral agreements or understandings made in connection with
`
`2
`
`
`
`
`
`the termination of the present Inter Partes review proceeding.
`
`Case No. IPR2015-001540
`Patent No. 6,886,956
`
`Ford and Patent Owner are concurrently filing a Joint Request that the
`
`Agreement, Confidential Exhibit 1015, be treated as business confidential
`
`information, kept separate from the file of the involved patents, and made available
`
`only to Federal Government agencies on written request, or to any person on a
`
`showing of good cause pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. §42.74(c).
`
`
`By: /s/ George W. Webb ______
`George W. Webb III (Lead Counsel)
`Reg. No. 60,737
`AHMAD, ZAVITSANOS,
`ANAIPAKOS, ALAVI &
`MENSING P.C.
`1221 McKinney, Suite 3460
`Houston, TX 77010
`Tel: (713) 655-1101
`Facsimile: (713) 655-0062
`gwebb@azalaw.com
`
`Counsel for Patent Owner,
`Innovative Display Technologies
`LLC
`
`
`
`
`
`Dated: October 28, 2015
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`By: /s/ Eric A. Buresh
`Eric A. Buresh (Lead Counsel)
`Reg. No. 50,394
`Jason R. Mudd (Backup Counsel)
`Reg. No. 57,700
`Albert F. Harris III (Backup Counsel)
`Reg. No. 63,935
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, Kansas 66211
`P: 913-777-5600 / F: 913-777-5601
`eric.buresh@eriseip.com
`jason.mudd@eriseip.com
`al.harris@eriseip.com
`
`Counsel for Petitioner, Ford Motor
`Company
`
`
`
`3
`
`
`
`
`
`Case No. IPR2015-001540
`Patent No. 6,886,956
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that a copy of the foregoing JOINT REQUEST
`
`TO TERMINATE INTER PARTES REVIEW was served on October 28, 2015,
`
`via electronic mail directed to counsel of record for the Patent Owner at the
`
`following:
`
`
`
`
`
`George W. Webb III
`Reg. No. 60,737
`AHMAD, ZAVITSANOS,
`ANAIPAKOS, ALAVI & MENSING P.C.
`1221 McKinney, Suite 3460
`Houston, TX 77010
`gwebb@azalaw.com
`
`
`
`/s/ Jason R. Mudd
`Jason R. Mudd
`
`ERISE IP, P.A.
`
`4
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