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IPR2016-00118
`Patent 8,155,342
`

`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`BLITZSAFE TEXAS, LLC
`Patent Owner
`

`IPR2016-00118
`Patent 8,155,342
`Multimedia Device Integration System
`
`  
`

`PROPOSED STIPULATION
`
`
`

`
`
`
`

`
`IPR2016-00118
`Patent 8,155,342
`
`Unified Patents Inc. (“Unified”) proffers this Proposed Stipulation, as
`
`suggested by the Board, to obviate the need to make reference to and thus the need
`
`to include and redact otherwise confidential produced exhibits. See Order,
`
`Conduct of the Proceeding, Unified Patents Inc. v. Blitzsafe Texas LLC, IPR2016-
`
`00118, Paper 16 (PTAB Mar. 15, 2016). As noted, Unified has agreed that the
`
`patent owner’s preliminary response no longer needs to be redacted.1 Unified,
`
`having previously proffered this stipulation to Patent Owner, proposes to stipulate
`
`to the following:
`
`
`
`1. Unified has produced 27 membership agreements, one for each of the
`
`members of the Automotive Zone as of the date of filing.
`
`2. Unified has produced the 23 agreements for Pledge members (see
`
`http://unifiedpatents.com/#membership) in the Automotive Zone as of the
`
`date of filing; Pledge members receive membership without paying fees and
`
`compensate Unified by, among other things, agreeing to give Unified notice
`
`rights and license rights to their patent portfolios.
`
`                                                       
`1 Unified regrets the inconvenience, noting that at the time the response was filed,
`
`the identities of two members were confidential. Those entities have since
`
`consented to become public members, and so there is no longer any need to redact
`
`any portion of the response. 
`

`
`2
`
`

`
`IPR2016-00118
`Patent 8,155,342
`
`3. Unified has produced the 4 agreements for Enterprise members (see
`
`http://unifiedpatents.com/#membership) in the Automotive Zone signed as
`
`of the date of filing; Toyota Motor Corporation, Honda Patents &
`
`Technologies North America LLC, Nissan Motor Co., Ltd., and DENSO
`
`Corporation are the only members to have paid subscription fees to the
`
`Automotive Zone as of the date of filing.
`
`4. Unified is funding IPR2016-00118 from the Automotive Zone.
`
`5. No subscription fees paid by a member with respect to one zone are used by
`
`Unified for other zones. If a patent involves more than one zone, any
`
`acquisition, licensing, or other costs (including any sale proceeds) for that
`
`patent are equally allocated amongst the zones.
`
`6. Unified seeks to reduce NPE litigation in each zone by, for example:
`
`acquiring rights necessary to grant members licenses, sublicenses, releases,
`
`and other rights; acquiring rights necessary to participate in bids or auctions,
`
`or otherwise to participate in acquisition, with respect to the sale of patents
`
`(including acquiring rights-of-first-offer or rights-of-first-refusal for patents
`
`in a zone from small businesses in exchange for reduced or free
`
`membership); filing and conducting reexaminations and review proceedings
`
`on patents in a zone before the U.S. Patent and Trademark Office;
`
`conducting prior art searches for patents in the zone; providing members
`

`
`3
`
`

`
`IPR2016-00118
`Patent 8,155,342
`
`with opinions of counsel regarding the patentability of patents in the zone;
`
`providing members and other parties in the zone with information relating to
`
`non-practicing entity (NPE) business practices, NPE litigation trends, NPE
`
`market data and statistics, and other information with respect to NPEs;
`
`participating in legislative and judicial reform initiatives on patent law
`
`(including, but not limited to, filing or joining amicus briefs and/or
`
`providing data to governmental agencies and/or legislators); and providing
`
`additional related services.
`
`7. For each zone, among other things, Unified: analyzes issued patents and
`
`published applications
`
`in each zone; monitors patents, published
`
`applications, assignment records, and patent owners in each zone for NPE
`
`activity; monitors patent owners in each zone for performance and other
`
`market data; provides members with an annual report on the NPE activity in
`
`their zones, including information derived from Unified’s activities; and
`
`performs other additional services.
`
`8. Unified provides members with an annual report that includes the following
`
`information: a list of all licensed patents and rights acquired; the amount
`
`spent for the assets and rights acquired, the date of each acquisition, and the
`
`identity of sellers; a list of all proceedings and the amount spent for each
`
`proceeding; estimated administrative and other costs; and a list of all zone
`

`
`4
`
`

`
`IPR2016-00118
`Patent 8,155,342
`
`patents sold, the amount received for each, the date of the sales, and the
`
`identity of the purchasers.
`
`
`Dated: March 15, 2016
`
`
`

`
`
`
`
`
`Respectfully submitted,
`
`
`By:
`
`/Paul C. Haughey/
`Paul C. Haughey
`Registration No. 31,836
`Lead Counsel for Petitioners
`
`
`
`
`
`
`
`5
`
`

`
`CERTIFICATE OF SERVICE
`
`IPR2016-00118
`Patent 8,155,342
`
`
`The undersigned hereby certifies
`
`that
`
`the
`
`foregoing PROPOSED
`
`STIPULATION is being served on March 15, 2016, by e-mail at the following
`
`agreed address for service:
`
`Peter Lambrianakos (Reg. No. 58,279)
`Brown Rudnick LLP
`7 Times Square
`New York, NY 10036
`plambrianakos@brownrudnick.com
`
`By: /Paul C. Haughey/
`Paul C. Haughey
`Registration No. 31,836
`Counsel for Petitioner
`
`
`
`
`6
`
`Dated: March 15, 2016
`
`
`

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