`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`T-MOBILE US, INC., T-MOBILE USA, INC.,
`TELECOMMUNICATION SYSTEMS, INC., ERICSSON INC., and
`TELEFONAKTIEBOLAGET LM ERICSSON
`Petitioners,
`
`v.
`
`TRACBEAM, LLC,
`Patent Owner
`__________________
`
`Case No. IPR2015-01711
`Patent 7,525,484
`__________________
`
`JOINT SUBMISSION OF NARROWING AGREEMENT
`UNDER 37 U.S.C. § 317
`
`
`
`
`
`
`
`
`
`
`
`
`
`Pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74, Petitioners T-Mobile
`
`US, Inc., T-Mobile USA, Inc., TeleCommunication Systems, Inc., Ericsson Inc.,
`
`and Telefonaktiebolaget LM Ericsson (collectively “Petitioners”) and Patent
`
`Owner TracBeam, LLC (“Patent Owner”) jointly submit a signed and binding
`
`Narrowing Agreement, memorializing their agreement to narrow their disputes
`
`relating to Patent Owner’s patents, including the present proceeding.
`
`The agreement recites certain confidential and sensitive business
`
`information of both Petitioners and Patent Owner. Accordingly, the parties jointly
`
`request that the Board treat this agreement (Exhibit 2001) as business confidential
`
`information, maintain the agreement separate from the file of the involved patent,
`
`and make the agreement available only as necessary and permitted under 35 U.S.C.
`
`§317(b) and 37 C.F.R. § 42.74(c).
`
`
`
`Respectfully submitted,
`
`
`
`
`
`/ Sean Luner /
`Sean Luner
`Registration No. 36,588
`DOVEL & LUNER, LLP
`201 Santa Monica Blvd, Suite 600
`Santa Monica, CA 90401
`Main Telephone (310) 656-7066
`sean@dovel.com
`Counsel for Patent Owner
`
`Date: November 24, 2015
`
`
`
`
`
`
`
`
`
`
`By:
`
`1
`
`
`
`
`
`
`/s/ Bryan W. Oaks (with permission)
`Brian W. Oaks
`Reg. No. 44,981
`
`BAKER BOTTS LLP
`98 San Jacinto Blvd., Suite 1500
`Austin, TX 78701
`Phone: (512) 322-5470
`Fax: (512) 322-
`3621 brian.oaks@bakerbotts.com
`
`Counsel for Petitioners
`
`2
`
`
`
`
`
`
`
`
`CERTIFICATE OF FILING AND SERVICE
`
`I hereby certify that true and correct copies of the foregoing JOINT
`
`SUBMISSION OF NARROWING AGREEMENT UNDER 37 U.S.C. § 317
`
`AND EXHIBIT 2001 are being filed via PRPS and served by electronic mail this
`
`24th day of November, 2015 on counsel for Petitioners as follows:
`
`Brian W. Oaks
`BAKER BOTTS, LLP,
`98 San Jacinto Blvd., Suite 1500
`Austin, TX 78701
`Telephone (512) 322-5470
`Facsimile (512) 322-3621
`brian.oaks@bakerbotts.com
`
`Douglas M. Kubehl
`BAKER BOTTS, LLP,
`2001 Ross Avenue
`Dallas, TX 75201
`Telephone (214) 953-6486
`Facsimile (214) 661-4486
`doug.kubehl@bakerbotts.com
`
`Chad C. Walters
`BAKER BOTTS, LLP,
`2001 Ross Avenue
`Dallas, TX 75201
`Telephone (214) 953-6511
`Facsimile (214) 661-4511
`chad.walters@bakerbotts.com
`
`Ross G. Culpepper
`BAKER BOTTS, LLP,
`2001 Ross Avenue
`Dallas, TX 75201
`Telephone (214) 953-6543
`Facsimile (214) 661-4543
`3
`
`
`
`
`ross.culpepper@bakerbotts.com
`
`
`
`
`
`
`
`Date: November 24, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Sean Luner/
`Sean Luner
`Registration No. 36,588
`DOVEL & LUNER, LLP
`201 Santa Monica Blvd, Suite 600
`Santa Monica, CA 90401
`Main Telephone (310) 656-7066
`sean@dovel.com
`Counsel for Patent Owner
`
`
`
`
`
`4
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