`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Counsel,
`
`Brianne Straka <briannestraka@quinnemanuel.com>
`Wednesday, November 11, 2020 2:36 PM
`Huawei-Verizon-ServiceonFR-NH
`QE-Verizon-Huawei; DLLP-Verizon-Huawei; ~Dacus, Deron
`'693 Patent: IPR Stipulation
`
`Verizon Business Network Services, Inc. (“Verizon”) hereby stipulates that if the PTAB institutes inter partes review in
`IPR2020-01130, then Verizon will not pursue in the district court proceeding (WDTX-6-20-cv-00090) the prior art
`obviousness combinations on which trial is instituted for the claims on which trial is instituted, while trial is instituted.
`The prior art obviousness combinations in the ‘1130 IPR petition are as follows:
`
`• Ground 1: Claims 1-9 are obvious over Moshchuk and Gribble.
`• Ground 2A: Claims 1, 3, 5, and 6 are obvious over Dubrovsky and Bertman.
`• Ground 2B: Claims 2, 4, and 7 are obvious over Dubrovsky and Bertman, and in further view of Campbell.
`• Ground 2C: Claim 8 is obvious over Dubrovsky.
`• Ground 2D: Claim 9 is obvious over Dubrovsky and Campbell.
`
`See IPR2020-01130 Petition at 15-16.
`
`Verizon further stipulates that if the PTAB institutes inter partes review in IPR2020-01131, then Verizon will not pursue
`in the district court proceeding (WDTX-6-20-cv-00090) that prior art obviousness ground for the claims on which trial is
`instituted, while trial is instituted. The prior art obviousness ground in the ‘1131 IPR petition is as follows:
`
`• Ground 1: Claims 1 – 9 are obvious over the ’691 publication.
`
`See IPR2020-01131 Petition at 39.
`
`Sincerely,
`Brianne
`
`Brianne Straka
`Partner
`Quinn Emanuel Urquhart & Sullivan, LLP
`191 N. Wacker Drive, Suite 2700 | Chicago, IL 60606
`312.705.7415 Direct | 312.705.7400 Main Office | 312.705.7401 Fax
`BrianneStraka@quinnemanuel.com
`www.quinnemanuel.com
`
`NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the
`recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is
`privileged and confidential. If the reader of this message is not the intended recipient or agent responsible for delivering it
`to the intended recipient, you are hereby notified that you have received this document in error and that any review,
`dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in
`error, please notify us immediately by e-mail, and delete the original message.
`
`1
`
`Juniper Ex. 1047-p.1
`Juniper v Huawei
`IPR2020-01130
`
`
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