`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`UNM RAINFOREST INNOVATIONS,
`F/K/A STC.UNM,
`
`vs.
`
`APPLE INC.,
`
`Plaintiff,
`
`Defendant.
`
`NO. 1:20–CV–351–ADA
`
`JURY TRIAL DEMANDED
`
`JOINT MOTION TO DISMISS WITH PREJUDICE
`
`WHEREAS, Plaintiff UNM Rainforest Innovations, f/k/a STC.UNM and Defendant Apple
`
`Inc. have resolved Plaintiff’s claims for relief against Defendant in this case.
`
`NOW THEREFORE, Plaintiff and Defendant, through their undersigned attorneys of
`
`record, jointly move the Court to dismiss with prejudice all claims asserted by Plaintiff against
`
`Defendant in this action. The parties further move this Court to order that each party shall bear its
`
`own costs, expenses, and attorneys’ fees incurred herein.
`
`Ex. 2009 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`
`
`Case 1:20-cv-00351-ADA Document 79 Filed 09/03/20 Page 2 of 2
`
`Respectfully submitted,
`
`Respectfully submitted,
`
`/s/ Michael W. Shore
`Charles L. Ainsworth (Texas 00783521)
`Robert Christopher Bunt (Texas 00787165)
` (application pending)
`PARKER, BUNT & AINSWORTH, P.C.
`1000 East Ferguson, Suite 418
`Tyler, TX 75702
`Tel: (903) 531-3535
`charley@pbatyler.com
`rcbunt@pbatyler.com
`
`Michael W. Shore (Texas 18294915)
`Alfonso G. Chan (Texas 24012408)
`William D. Ellerman (Texas 24007151)
`SHORE CHAN DEPUMPO LLP
`901 Main Street, Suite 3300
`Dallas, Texas 75202
`Tel: (214) 593-9110
`Fax: (214) 593-9111
`mshore@shorechan.com
`achan@shorechan.com
`wellerman@shorechan.com
`
`COUNSEL FOR PLAINTIFF STC.UNM
`
`/s/ Richard L. Wynne, Jr.
`Bruce S. Sostek
` State Bar No. 18855700
` bruce.sostek@tklaw.com
`Richard L. Wynne, Jr.
` State Bar No. 24003214
` richard.wynne@tklaw.com
`Max Ciccarelli
` State Bar No. 00787242
` max.ciccarelli@tklaw.com
`Adrienne Dominguez
` State Bar No. 00793630
` adrienne.dominguez@tklaw.com
`THOMPSON & KNIGHT LLP
`1722 Routh Street, Suite 1500
`Dallas, Texas 75201
`214.969.1700 (telephone)
`214.969.1751 (facsimile)
`
`John M. Guaragna
` State Bar No. 24043308
` John.Guaragna@dlapiper.com
`DLA PIPER LLP (US)
`401 Congress Avenue, Suite 2500
`Austin, Texas 78701
`512.457.7125 (telephone)
`
`COUNSEL FOR DEFENDANT APPLE INC.
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on September 3, 2020, the foregoing Joint Motion
`was served on all counsel via the court’s electronic filing system pursuant to Local Rule CV-5.
`
`/s/ Michael W. Shore
`Michael W. Shore
`
`Ex. 2009 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
`
`
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