`5030 Sugarloaf Parkway
`Lawrenceville, GA 30044
`Direct: 770-236-5212
`btoliver@cisco.com
`
`May 11, 2021
`
`VIA EMAIL
`Todd E. Landis
`
`WILLIAMS SIMONS & LANDIS PLLC - AUSTIN
`327 Congress Ave., Suite 490
`Austin, TX 78701
`EstechCounsel@wsltrial.com
`
`Re: Estech Systems, Inc. v. Target Corp. et al., Case No. 2:20-cv-00123-JRG-RSP (Lead
`Case) (the “EDTX Litigations”) and Estech Systems, Inc. v. Regions Financial
`Corp., Case No. 6:20-cv-00322 (the “WDTX Litigation”) - Stipulations Regarding
`Challenged Patents
`
`Dear Counsel:
`
`I write on behalf of Cisco Systems, Inc. (“Cisco”), who has filed petitions for Inter Partes
`review (“IPR”) challenging the patentability of U.S. Patent Nos. 8,391,298, 7,068,684, 6,067,349,
`and 7,123,699 (collectively, the “Challenged Patents”) in IPR2021-00329, IPR2021-00331,
`IPR2021-00332, or IPR2021-00333 (collectively the “IPR Proceedings”).
`
`Cisco is currently a non-party to any litigation filed by Estech Systems, Inc. However, for
`the avoidance of doubt, and in support of Cisco’s Petitions in the IPR Proceedings, Cisco stipulates
`that if Cisco should be sued for infringement of a challenged claim of a Challenged Patent in a
`district court in the United States or before the International Trade Commission at some point in
`the future, and an IPR Proceeding challenging that patent is instituted, Cisco will not seek
`resolution in such future litigation of any ground of invalidity with respect to the challenged claim
`of the Challenged Patent based on any reference used in the above referenced proceedings or that
`reasonably could have been raised in the above referenced proceedings. For the avoidance of
`doubt, if one or more of the IPR Proceedings are not instituted, Cisco reserves its right to raise any
`invalidity theories against the patent that the non-instituted IPR challenged.
`
`Regards,
`
`Buddy Toliver
`Senior Counsel, IP Litigation
`
`
`
`Page 1 of 1
`
`CISCO EXHIBIT 1026
`Cisco Systems v. Estech
`IPR2021-00329
`
`
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