`Patent 8,391,298
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`RINGCENTRAL, INC.,
`
`Petitioner,
`v.
`ESTECH SYSTEMS, INC.,
`
`Patent Owner
`__________________
`Inter Partes Review No. IPR2021-00574
`Patent No. 8,391,298
`
`JOINT STATEMENT REGARDING PRIOR ART
`
`
`
`IPR2021-00574
`Patent No. 8,391,298
`
`Estech Systems, Inc. (“Estech” or “Patent Owner”) and RingCentral, Inc.
`
`(“RingCentral” or “Petitioner”) hereby submit this joint statement regarding the
`
`extent to which the prior art cited in the Petition in this proceeding will be relied on
`
`in the parallel litigations in the Eastern and Western Districts of Texas. See Paper
`
`9, p. 4.
`
`The prior art asserted in the Petition does not overlap with the prior art at issue
`
`in the Eastern District of Texas Litigation.1
`
`In the Western District of Texas Litigation, 2 the same primary reference (U.S.
`
`Patent No. 6,240,558 to Chang) used in both Grounds of the Petition is currently
`
`asserted. Petitioner is not a party to any of the pending litigations. But, if inter
`
`partes review is granted, Petitioner represents that no Real Party-in-Interest with
`
`respect to the above proceeding will rely upon the Grounds or prior art presented in
`
`the Petition in the Western District of Texas Litigation. Thus, there would be no
`
`overlap between this proceeding and the Western District of Texas Litigation.
`
`1 Estech Systems, Inc. v. Target Corporation, et al., No. 2:20-cv-00123-JRG-RSP
`
`(E.D. Tex.).
`
`2 Estech Systems, Inc. v. Howard Midstream Energy Partners, LLC, No. 6:20-cv-
`
`777-ADA (W.D. Tex.).
`
`2
`
`
`
`IPR2021-00574
`Patent No. 8,391,298
`
`Dated: September 10, 2021
`
`Respectfully submitted,
`
`By: /Todd E. Landis/
` Todd E. Landis
`Registration No. 44,200
`WILLIAMS SIMONS & LANDIS
`PLLC
`2633 McKinney Avenue, Suite 130
`#366
`Dallas, TX 75204
`Telephone: (512) 541-1357
`Email: tlandis@wsltrial.com
`
`Counsel for Patent Owner
`
`By: /K. Patrick Herman/
` K. Patrick Herman
`Registration No. 75,108
`ORRICK, HERRINGTON, &
`SUTCLIFFE LLP
`51 West 52nd Street
`New York, NY 10019
`Telephone: (212) 506-3596
`Email: pherman@orrick.com
`
`Counsel for Petitioner
`
`3
`
`
`
`IPR2021-00574
`Patent No. 8,391,298
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6, the undersigned certifies that on September 10,
`
`2021, the foregoing document was served on counsel of record for Petitioner by
`
`filing this document through the End-to-End System, as well as via electronic mail
`
`to counsel of record for Petitioner at the following addresses:
`
`K. Patrick Herman (P52PTABDocket@orrick.com)
`Alyssa Caridis (A8CPTABDocket@orrick.com)
`Clem Roberts (croberts@orrick.com)
`Robert L. Uriarte (ruriarte@orrick.com)
`Li Shen (lshen@orrick.com)
`
`Respectfully submitted,
`
`By: //Todd E. Landis//
`Todd E. Landis
`Registration No. 44,200
`Counsel for Patent Owner
`Estech Systems, Inc.
`
`4
`
`
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