`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`SAMSUNG ELECTRONICS CO. LTD., SAMSUNG ELECTRONICS
`AMERICA, INC., AND APPLE INC.,
`Petitioner,
`
`v.
`
`NEONODE SMARTPHONE LLC,
`Patent Owner,
`____________
`
`Case IPR2021-00144
`Patent 8,095,879
`____________
`
`STIPULATION TO LIMIT THE PETITION
`
`
`
`
`Patent Owner Neonode Smartphone LLC (hereinafter, “Patent Owner”), and
`
`Petitioners Samsung Electronics Co. Ltd., Samsung Electronics America, Inc., and
`
`Apple Inc., (hereinafter, collectively “Petitioners”) enter into this stipulation to
`
`memorialize their agreement to limit the Petition as stated below. This stipulation
`
`is filed pursuant to the Board’s authorization via email dated February 25, 2022
`
`(Exhibit 2037), and is filed by Patent Owner on behalf of both parties.
`
`The Parties have stipulated as follows:
`
`(1) The Petition will be limited to grounds 2A, 2B, 2C and 2D as stated in
`
`the Petition, and grounds 1A-1E, and 3 shall be excluded from this proceeding
`
`(“Excluded Grounds”);
`
`(2) Patent Owner shall not pursue any decision by the Board on the
`
`Excluded Grounds;
`
`(3) Any question by Patent Owner for Petitioner’s expert at deposition that is
`
`unrelated to grounds 2A-2D shall be subject to a relevance/scope objection, and the
`
`proper motion to exclude, if necessary; and
`
`(4) Patent Owner shall not otherwise present arguments in this proceeding as
`
`to the Excluded Grounds for any reason unrelated to grounds 2A-2D.
`
`
`
`1
`
`
`
`Respectfully submitted,
`
`
`______/ Tiffany Miller /______________
`Tiffany Miller, Reg. No. 52,032
`DLA PIPER LLP
`Counsel for Petitioners
`
`
`____/ Kenneth J. Weatherwax /_______
`Kenneth J. Weatherwax, Reg. No. 54,528
`LOWENSTEIN & WEATHERWAX LLP
`Counsel for Patent Owner
`
`Date: August 8, 2022
`
`2
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the following documents were served
`
`by electronic service on the date signed below:
`
`STIPULATION TO LIMIT THE PETITION
`
`
`The names and address of the parties being served are as follows:
`
`W. Karl Renner
`David Holt
`Tiffany C. Miller
`James M. Heintz
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`IPR50095-0015IP1@fr.com
`holt@fr.com
`tiffany.miller@dlapiper.com
`jim.heintz@dlapiper.com
`axf-ptab@fr.com
`PTABInbound@fr.com
`
`Respectfully submitted,
`
` / Keith Moore /
`
`Date: August 8, 2022
`
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
