`
`Kirstin L. Stoll-DeBell
`Partner
`kirstin.stolldebell@faegredrinker.com
`+1 303 927 5212 direct
`
`
`December 3, 2020
`
`
`VIA E-MAIL
`
`Faegre Drinker Biddle & Reath LLP
`1144 15th Street, Suite 3400
`Denver, Colorado 80202
`+1 303 607 3500 main
`+1 303 607 3600 fax
`
`Wayne M. Helge
`Davidson Berquist Jackson & Gowdey L.L.P.
`8300 Greensboro Drive, Suite 500
`McLean, VA 22102
`Email: whelge@dbjg.com
`
`Re: Worlds Inc. v. Microsoft Corporation, Case No. 6:20-cv-872 (W.D. Tex.)
`
`Dear Mr. Helge:
`
`We write regarding the petition for inter partes review (IPR) filed against the patent-in-suit, U.S.
`Patent No. 8,082,501, in the captioned litigation. Microsoft Corporation hereby stipulates that,
`unless the Patent Trial and Appeal Board (PTAB) denies or later vacates institution of the IPR
`petition, Microsoft Corporation will not seek resolution in the trial for the above-captioned
`litigation of invalidity based on the grounds presented in the IPR petition (a table of which is
`reproduced below) or grounds that would otherwise be estopped under 35 U.S.C. § 315(e) under
`a later final written decision.
`
`Claims
`
`Prior Art Basis of Ground
`
`1-6, 12, 14, 15
`7, 16
`8, 10
`1-6, 12, 14, 15
`7, 16
`8, 10
`
`Funkhouser, Sitrick
`Funkhouser, Sitrick, Wexelblat
`Funkhouser, Sitrick, Funkhouser ’93
`Funkhouser, Sitrick, Durward
`Funkhouser, Sitrick, Durward, Wexelblat
`Funkhouser, Sitrick, Durward, Funkhouser ’93
`
`
`
`
`
`
`
`MS 1041
`
`1
`
`
`
`
`
`
`
`December 3, 2020
`Page 2
`
`
`
`In so stipulating, Microsoft seeks to avoid multiple proceedings addressing the validity of the
`patents in suit based on the above-noted grounds. Rather, consistent with Congressional intent,
`Microsoft wishes the patentability of these patents over those grounds to be addressed at the Board.
`But, for the sake of clarity and to avoid any doubt, if the PTAB declines or later vacates institution
`of the IPR, Microsoft reserves the right to pursue the grounds of the IPR in this litigation.
`
`
`
`
`
`
`
`
`
`
`Sincerely,
`
`
`
`____________________________________
`Kirstin L. Stoll-DeBell
`Faegre Drinker Biddle & Reath LLP
`
`2
`
`
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