`
`AND AFFILIATED PARTNERSHIPS
`
`601 Lexington Avenue
`New York, NY 10022
`United States
`
`+1 212 446 4800
`
`www.kirkland.com
`
`March 26, 2021
`
`Facsimile:
`+1 212 446 4900
`
`Greg Arovas, P.C.
`To Call Writer Directly:
`+1 212 446 4766
`greg.arovas@kir1<land.com
`
`Via E-mail
`
`Theodore Stevenson, III
`tstevenson@mckoolsmith.com
`McKool Smith, P.C.
`300 Crescent Comt, Suite 1500
`Dallas, TX 75201
`
`Re: Ericsson Inc. et al. v. Samsung Electronics Co., Ltd., et. al., Civil Action No. 2:20-
`cv-00380-JRG (E.D. Tex.)
`
`Dear Counsel:
`
`We write regarding a petition for inter partes review (IPR) being filed with the Patent Trial
`and Appeal Board (PTAB) to address claims of U.S. Patent No. 10,193,600. We write to info1m
`you that Samsung Electronics Co., Ltd. ("Samsung") hereby stipulates that, if the PTAB institutes
`the IPR petition on the grounds presented (a table of which is reproduced below), then Samsung
`and its Samsung co-defendants will not pm-sue those same instituted grounds or grounds based on
`the same primary reference in the above-captioned litigation, 2:20-cv-00380-JRG (E.D. Tex.).
`
`1
`
`§ 103
`
`1-28
`
`Novlan, or alternatively Novlan in view of
`36.213
`
`In so stipulating, Samsung seeks to avoid multiple proceedings addressing the validity of
`the challenged claims of the patent based on the same grounds. Rather, consistent with
`Congressional intent, Samsung wishes the patentability of this patent over those grounds to be
`addressed at the Board. But, for the sake of clarity and to avoid any doubt, if the PTAB declines
`institution, Samsung reserves the right to pm-sue the grounds of the IPR in this litigation.
`
`II
`
`See Appendix for abbreviations.
`
`Bay Area
`
`Beijing
`
`Boston
`
`Chicago
`
`Dallas
`
`Hong Kong
`
`Houston
`
`London
`
`Los Angeles Munich
`
`Paris
`
`Shanghai Washington, D.C.
`
`Samsung Ex. 1014
`1 of 3
`
`
`
`KIRKLAND&. ELLIS LLP
`
`
`
`
`Sincerely,
`
`/s/ Greg Arovas
`
`Greg Arovas, P.C.
`Kirkland & Ellis LLP
`
`
`
`Theodore Stevenson, II
`March 26, 2021
`Page 2
`
`
`//
`
`cc:
`
`Counsel of record
`
`
`
`
`
`Samsung Ex. 1014
`2 of 3
`
`
`
`KIRKLAND&. ELLIS LLP
`
`Theodore Stevenson, II
`March 26, 2021
`Page 3
`
`Appendix - Prior Art References Used in the Listed Grounds
`
`l ~ .... -: .. - :. I • - :. ~ril'iinl
`Novlan
`
`36.213
`
`nnfmt=:i
`U.S. Patent Application Publication No. 2014/0016549 to Novlan et al.
`3GPP TS 36.213, v12.3.0
`
`Samsung Ex. 1014
`3 of 3
`
`
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