`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Counsel,
`
`Lau, Jeffrey <jeffreylau@omm.com>
`Monday, March 22, 2021 4:40 PM
`Howard Wisnia; Karl Rupp; Derek Gilliland
`#OMM-Ikorongo; Blake Thompson; Mark Mann
`Ikorongo v. LG (No. 6:20-cv-257); Ikorongo v. Samsung (No. 6:20-cv-259)
`
`As you know, we represent LG Electronics Inc. and LG Electronics U.S.A., Inc. (collectively, “LG”) as well as Samsung
`Electronics Co., Ltd. and Samsung Electronics America, Inc. (collectively, “Samsung”) in the above‐referenced matters.
`We write to inform you that LG and Samsung hereby stipulate that if the PTAB institutes inter partes review nos.
`IPR2021‐00058, IPR2021‐00084, IPR2021‐00127, IPR2021‐00204, and IPR2021‐00205, then LG and Samsung will not
`pursue in the current district court proceedings (Ikorongo Texas LLC v. LG Electronics, Inc., No. 6:20‐cv‐00257 (W.D. Tex.
`filed March 31, 2020) and Ikorongo Texas LLC v. Samsung Electronics Co., No. 6:20‐cv‐00259‐ADA (W.D. Tex. filed March
`31, 2020)) the specific grounds in the instituted inter partes review petitions. This stipulation is not intended to limit LG
`and Samsung’s ability to assert invalidity of the asserted claims on any other ground.
`
`To be clear, this stipulation does not encompass any arguments made in the petitions relating to the priority date or
`dates of alleged invention. Accordingly, LG and Samsung preserve the right to make arguments regarding the priority
`date of Ikorongo’s asserted claims in the district court proceedings. This stipulation does not apply to claims of any
`patents other than those challenged in the above‐listed IPRs.
`
`Regards,
`
`Jeff
`
`
`
`O’Melveny
`Jeffrey Lau
`jeffreylau@omm.com
`O: +1-213-430-8383
`
`O’Melveny & Myers LLP
`400 South Hope Street, 18th Floor
`Los Angeles, CA 90071
`Website | LinkedIn | Twitter
`This message and any attached documents contain information from the law firm of O'Melveny & Myers LLP that may be confidential
`and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this information. If you have received
`this transmission in error, please notify the sender immediately by reply e-mail and then delete this message.
`
`
`1
`
`
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