` PATENT 10,484,511
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _________________________
`TESO LT, UAB; CODE200, UAB; METACLUSTER LT, UAB; AND
`OXYSALES, UAB,
`Petitioners
`v.
`LUMINATI NETWORKS LTD.,
`Patent Owner
`_________________________
`
`Case IPR2021-00122
`Patent 10,484,511
`
`______________________
`
`
`STIPULATION
`
`
`
`
`
`
`
`
`
`
`Patent Owner Luminati Networks LTD (“Patent Owner”) and Petitioners
`
`IPR2021-00122
` PATENT 10,484,511
`
`
`
`Teso LT, UAB; Code200, 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. 10,484,511 in IPR 2021-00122, 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 6,389,462 to Cohen (hereinafter
`
`“Cohen”); (iii) United States Patent 6,785,705 to Kocherlakota
`
`(hereinafter “Kocherlakota”); and (iv) Network Working Group 2616)
`
`(hereinafter “RFC 2616”).
`
`2. Petitioners, excluding Teso LT which is not a defendant in the case,
`
`have asserted, among other references, Crowds, Cohen, Kocherlakota
`
`and RFC 2616, against certain claims of U.S. Patent No. 10,484,511 in
`
`Luminati Networks Ltd. v. Teso LT, UAB et al., 2:19-cv-00396-JRG
`
`(E.D.Tex.) and included those references as items 1, 7, 6 and 4,
`
`respectively, in their Invalidity Contentions.
`
`3. Petitioners have asserted three references against certain claims of U.S.
`
`Patent No. 10,637,968 in IPR 2021-00249, namely: (i) MorphMix – A
`
`Peer-to-Peer-based System for Anonymous Internet Access (2004)
`
`
`
`
`
`IPR2021-00122
` PATENT 10,484,511
`
`(Doctoral Thesis) (hereinafter “MorphMix”); (ii) U.S. Patent Publication
`
`2008/0196098 to Cottrell (hereinafter “Cottrell”); and (iii) Network
`
`Working Group 2616 (hereinafter “RFC 2616”).
`
`4. Petitioners, excluding Teso LT which is not a defendant in the case,
`
`have asserted, among other references, MorphMix, Cottrell and RFC
`
`2616 against certain claims of U.S. Patent No. 10,637,968 in Luminati
`
`Networks Ltd. v. Teso LT, UAB et al., 2:19-cv-00396-JRG (E.D.Tex.)
`
`and included those references as items 2, 3 and 4, respectively, in their
`
`Invalidity Contentions.
`
`
`SO STIPULATED:
`
`Date: February 17, 2021
` /s/ Craig Tolliver
`
`
`
`Craig Tolliver
`
`Registration Number 44,975
`COUNSEL FOR PETITIONER S
`
`
`Date: February 17, 2021
` /s/ Thomas M. Dunham
`
`
`
`Thomas M. Dunham
`
`
`Registration Number 39,965
`COUNSEL FOR PATENT OWNER
`
`
`
`
`
`
`
`
`
`
`
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`
`
`
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