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IPR2020-01266
` PATENT 10,257,319
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _________________________
`CODE200, UAB; TESO LT, UAB; METACLUSTER LT, UAB; AND
`OXYSALES, UAB,
`Petitioners
`v.
`LUMINATI NETWORKS LTD.,
`Patent Owner
`_________________________
`
`Case IPR2020-01266
`Patent 10,257,319
`
`______________________
`
`
`STIPULATION
`
`
`
`
`
`
`
`
`

`

`
`
`Patent Owner Luminati Networks LTD (“Patent Owner”) and Petitioners
`
`IPR2020-01266
` PATENT 10,257,319
`
`Code200, UAB; Teso LT, UAB; Metacluster LT, UAB and Oxysales, UAB
`
`(“Petitioners”) hereby stipulate as follows:
`
`1. Petitioners have asserted four references against certain claims of U.S.
`
`Patent No. 10,257,319 in IPR 2020-01266, namely: (i) Crowds:
`
`Anonymity for Web Transactions, ACM Transactions on Information
`
`and System Security, Vol. 1, No. 1, Nov. 1998, at 66-92 (hereinafter
`
`“Crowds”); (ii) United States Patent No. 6,795,848 to Border et al.
`
`(hereinafter “Border”); (iii) MorphMix – A Peer-to-Peer-based System
`
`for Anonymous Internet Access (2004) (Doctoral Thesis) (hereinafter
`
`“MorphMix”); and (iv) Network Working Group 2616 (hereinafter
`
`“RFC 2616”).
`
`2. Petitioners, excluding Code200 which is not a defendant in the case,
`
`have asserted, among other references, Crowds, Border, MorphMix and
`
`RFC 2616, against certain claims of U.S. Patent No. 10,257,319 in
`
`Luminati Networks Ltd. v. Teso LT, UAB et al., 2:19-cv-00395-JRG
`
`(E.D.Tex.) and included those references as items 1-4 in their Invalidity
`
`Contentions.
`
`

`

`
`
`IPR2020-01266
` PATENT 10,257,319
`
`3. Petitioners have asserted the same four references, namely, Crowds,
`
`Border, Morphmix and RFC 2616, against certain claims of U.S. Patent
`
`No. 10,484,510 in IPR 2020-01358.
`
`4. Petitioners, excluding Code200 which is not a defendant in the case,
`
`have asserted, among other references, Crowds, Border, Morphmix and
`
`RFC 2616, against certain claims of U.S. Patent No. 10,484,510 in
`
`Luminati Networks Ltd. v. Teso LT, UAB et al., 2:19-cv-00395-JRG
`
`(E.D.Tex.) and included those references as items 1-4 in their Invalidity
`
`Contentions.
`
`5. Petitioners have asserted three references, namely, Morphmix, United
`
`States Patent No. 8,972,602 to Mithyantha (hereinafter “Mithyantha”)
`
`and RFC 2616, against certain claims of U.S. Patent No. 10,469,614 in
`
`IPR 2020-01506.
`
`6. Petitioners, excluding Code200 which is not a defendant in the case,
`
`have asserted, among other references, Morphmix, Mithyantha and RFC
`
`2616, against certain claims of U.S. Patent No. 10,484,614 in Luminati
`
`Networks Ltd. v. Teso LT, UAB et al., 2:19-cv-00395-JRG (E.D.Tex.)
`
`and included those references in their Invalidity Contentions.
`
`SO STIPULATED:
`
`
`

`

`IPR2020-01266
` PATENT 10,257,319
`
`
`
`
`
`Date: November 19, 2020
` /s/ Craig Tolliver
`
`
`
`Craig Tolliver
`
`Registration Number 44,975
`COUNSEL FOR PETITIONER S
`
`
`Date: November 19, 2020
`/s/ Thomas M. Dunham
`
`
`
`Thomas M. Dunham
`
`
`Registration Number 39,965
`COUNSEL FOR PATENT OWNER
`
`
`
`
`
`
`
`
`
`
`
`
`

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