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`Paper No.
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
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`CISCO SYSTEMS, INC.,
`Petitioner,
`
`v.
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`TRACBEAM, LLC
`Patent Owner
`
`———————
`Case IPR2018-01724
`U.S. Patent No. 7,525,484
`(Claim 49)
`_____________________
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`
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`JOINT MOTION TO DISMISS THE PETITION
`UNDER 37 C.F.R. § 42.71(a)
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`Joint Motion to Dismiss the Petition
`IPR2018-01724 (Patent 7,525,484)
`Pursuant to 37 C.F.R. § 42.71(a), Petitioner Cisco Systems, Inc. (“Cisco”) and
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`Patent Owner TracBeam, LLC (“TracBeam”) (collectively, the “Parties”) jointly
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`move for dismissal of the Petition for Inter Partes Review of U.S. Patent No.
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`7,525,484 (“the `484 Patent”). The filing of this motion was authorized by the Board
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`via e-mail dated November 16, 2018.
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`The Parties have settled their dispute with respect to the `484 Patent and have
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`reached agreement to seek termination of Cisco’s IPR challenge against the `484
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`Patent. The Settlement Agreement between Cisco and TracBeam has been made in
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`writing, and a true and correct copy shall be filed with this Office as business
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`confidential information pursuant to 35 U.S.C. § 317(b). See Exhibit CSCO-1018.
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`There are no collateral agreements or understandings made in connection with, or in
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`contemplation of, the termination of this proceeding.
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`Therefore, Petitioner and Patent Owner respectfully request dismissal of the
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`Petition for Inter Partes Review in Case No. IPR2018-01724.
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`November 26, 2018
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`Respectfully submitted,
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`/David L. McCombs/
`David L. McCombs
`Lead Counsel for Petitioner
`Registration No. 32,271
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`/Sean Luner/
`Sean Luner
`Lead Counsel for Patent Owner
`Registration No. 36,588
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`Joint Motion to Dismiss the Petition
`IPR2018-01724 (Patent 7,525,484)
`PETITIONER’S EXHIBIT LIST
`November 26, 2018
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`CSCO-1001 U.S. Patent No. 7,525,484 to Dupray et al. (“the ’484 patent”)
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`CSCO-1002 Prosecution File History of U.S. Patent No. 7,525,484
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`CSCO-1003 Declaration of Dr. William Michalson under 37 C.F.R. § 1.68
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`CSCO-1004 Curriculum Vitae of Dr. William Michalson
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`CSCO-1005 Reserved
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`CSCO-1006 U.S. Patent No. 5,774,829 to Cisneros et al. (“Cisneros”)
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`CSCO-1007 Reserved
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`CSCO-1008 Reserved
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`CSCO-1009 Reserved
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`CSCO-1010 U.S. Patent No. 5,218,367 to Sheffer II et al. (“Sheffer II”)
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`CSCO-1011 Preliminary Construction, TracBeam LLC v. Cisco Systems, Inc.,
`No. 6:17-cv-525.
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`CSCO-1012 Reserved
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`CSCO-1013 Reserved
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`CSCO-1014 Reserved
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`CSCO-1015 Reserved
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`CSCO-1016 Joint Claim Construction and Prehearing Statement, TracBeam LLC
`v. Cisco Systems, Inc., No. 6:17-cv-525, Docket No. 60 (Apr. 18,
`2018).
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`CSCO-1017 Reserved
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`CSCO-1018 Settlement Agreement (Parties and Board only)
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`Cisco Systems, Inc.
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`Petitioner
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`§
`§
`§
`§
`§
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`Petition for Inter Partes Review
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`IPR2018-01724
`U.S. Patent No. 7,525,484
`(Claim 49)
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`
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`CERTIFICATE OF SERVICE
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`The undersigned certifies, in accordance with 37 C.F.R. § 42.6, that service
`was made on the Patent Owner as detailed below.
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`Date of service November 26, 2018
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`
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`Manner of service Electronic Service by E-Mail: sean@dovel.com;
`ssereboff@socalip.com
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`Documents served Joint Motion to Terminate Proceedings
`Exhibit CSCO-1018
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`Persons served Sean Luner, Esq.
`DOVEL AND LUNER, LLP
`201 Santa Monica Blvd., Suite 600
`Santa Monica, CA 90401
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`Steven C. Sereboff, Esq.
`SOCAL IP LAW GROUP LLP
`310 N. Westlake Blvd, Suite 120
`Westlake Village, CA 91362
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`
`/David L. McCombs/
`David L. McCombs
`Lead Counsel for Petitioner
`Registration No. 32,271
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