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`SMART EXHIBIT 1021
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`SETTLEMENT TERM SHEET
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`This term sheet sets forth the principle terms of settlement between JAMES B. GOODMAN and
`SMART MODULAR TECHNOLOGIES, INC; Case No. 4:14-CV-01380 GHM.
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`This term sheet sets forth the principle terms of settlement. The parties anticipate that they will
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`supplement this term sheet with a formal settlement agreement.
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`THE PARTIES AGREE AND STIPULATE THAT THE DISTRICT COURT SHALL
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`ENFORCE THIS TERM SHEET AS A SETTLEMENT AGREEMENT.
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`The parties agree to settle their dispute on the following principle terms:
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`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`8.
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`Goodman shall dismiss all legal claims with prejudice;
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`Goodman shall stipulate that all accused products do not infringe his U.S. Patent
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`No. 6,243,315;
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`Goodman shall grant to Smart Modular a fully paid up, non-terminable, non -
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`royalty bearing, perpetual license to the ‘3 15 patent;
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`Smart Modular shall dismiss all counterclaims;
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`Smart Modular shall terminate its Inter Partes Review of the ‘3 15 patent;
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`Goodman shall obtain Smart Modular’s approval of the form of Goodman’s
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`dismissal and stipulation before Goodman files such dismissal or stipulation.
`Smart Modular shall not unreasonably withhold its approval;
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`the parties shall bear their own costs, including attorney fees; and
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`this term sheet and any other agreement between the parties relating to this
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`litigation or the ‘3 15 patent shall be NON-CONFIDENTIAL.
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` By: . ’
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`"Bruce Goldberg
`General Counsel
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`/'
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`SMART EXHIBIT 1021- Page 1
`SMART EXHIBIT 1021- Page 1
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