`Sent:
`To:
`Cc:
`Subject:
`
`Counsel:
`
`Mar, Eugene (22) x4927
`Wednesday, July 15, 2020 10:31 AM
`John Lord; Deepali A. Brahmbhatt; 'Kevin Terrazas'
`Liaw, Winston (19) x4497; Chanana, Sushila (19) x4472; Dacus, Deron
`SynKloud Techs. v. Adobe Inc., No. 6:19-cv-00527 (W.D. Tex.)
`
`Adobe is filing today a petition for inter partes review of claims 9-15 of the ’780 Patent. If review is instituted based on
`this petition, Adobe stipulates that it will not pursue in the related district court action (Case No. 6:19-cv-00527) any
`grounds for unpatentability of the challenged claims of the ’780 Patent raised in this IPR or that reasonably could have
`been raised in this IPR. To be clear, this stipulation is contingent on, and applies only if, the PTAB institutes review of the
`petition we are filing today.
`
`Sincerely,
`
`Eugene
`
`Eugene Y. Mar
`Partner
`emar@fbm.com
`415.954.4927
`
`1
`
`Adobe - Exhibit 1041, page 1
`
`
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