`Direct Dial: 650.463.2633
`doug.lumish@lw.com
`
`December 10, 2020
`
`VIA EMAIL
`
`Philip X. Wang
`Russ August & Kabat
`12424 Wilshire Boulevard
`Twelfth Floor
`Los Angeles, California 90025
`pwang@raklaw.com
`
`140 Scott Drive
`Menlo Park, California 94025
`Tel: +1.650.328.4600 Fax: +1.650.463.2600
`www.lw.com
`
`FIRM / AFFILIATE OFFICES
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`
`Re:
`
`Solas OLED Ltd. v. LG Display Co., Ltd., et al., Case No. 6:19-cv-00236-ADA
`
`Dear Philip:
`
`Defendants LG Display Co., Ltd., LG Display America, Inc., LG Electronics Inc., LG
`Electronics USA, Inc., Sony Electronics Inc., and Sony Corporation hereby stipulate that, if the
`Patent Trial and Appeal Board (“PTAB”) institutes the pending inter partes review petition in
`IPR2020-01238 challenging the patentability of claims 1, 5, 9-13, and 17 of U.S. Patent Number
`7,573,068 then Defendants will not pursue the instituted invalidity grounds in the above-
`captioned litigation, 6:19-cv-00236. For convenient reference, the proposed invalidity grounds in
`IPR2020-01238 are:
`
`• Claims 1, 5, 10, 11 and 13 are unpatentable under 35 U.S.C. § 102 over Shin (WO
`2004/090853).
`• Claim 13 is unpatentable under 35 U.S.C. § 103 over Shin.
`• Claims 1, 5, 9-13 and 17 are unpatentable under 35 U.S.C. § 103 over Shin and
`Hector (WO 03/079442).
`
`To avoid any doubt, if the PTAB declines institution of IPR2020-01238, Defendants
`reserve the right to pursue these invalidity grounds in the parallel litigation.
`
`Best Regards,
`
`/s/ Douglas E. Lumish
`
`Douglas E. Lumish
`of LATHAM & WATKINS LLP
`
`LG Display
`Exhibit 1033
`LG Display v. Solas
`IPR2020-01238
`
`Ex. 1033-001
`
`
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