`
`
`
`VIA ELECTRONIC MAIL
`
`June 14, 2021
`
`Attn: Alan Kossoff (#150932)
`
`akossoff@kwikalaw.com
`
`Jonathan Steinsapir (#226281)
`
`jsteinsapir@kwikalaw.com
`
`808 Wilshire Boulevard, 3rd Floor
`Santa Monica, California 90401
`Kinsella Weitzman Iser Kump LLP
`
`Fish & Richardson P.C.
`111 Congress Avenue
`Suite 810
`Austin, TX 78701
`512 472 5070 main
`512 320 8935 fax
`
`
`David M Hoffman
`Principal
`hoffman@fr.com
`512 226 8154 direct
`
`
`
`
`
`
`
`
`
`
`Re:
`
`Conor M. Civins (#24040693)
`conor.civins@bracewell.com
`Michael Chibib (#00793497)
`michael.chibib@bracewell.com
`111 Congress Avenue, Suite 2300
`Austin, Texas 78701
`Bracewell LLP
`
`Versata Software, Inc. v. Configit A/S, Case No. 2:20-cv-09019 in the United States
`District Court for the Central District of California
`
`
`Dear Counsel:
`I write regarding the pending petition for inter partes review (IPR) filed against U.S. Patent No.
`6,836,766 (“the ’766 patent”). Specifically, I write to state, and inform you of, Configit’s
`stipulation that, if the Patent Trial and Appeal Board (PTAB) institutes the IPR petition filed on
`this day against United States Patent No. 6,836,766, then Configit will not pursue those same
`instituted grounds, or grounds sharing the same prior art references that could have been asserted
`in IPR, in the above-captioned litigation with respect to the claims subject to IPR.
`
`The prior art references are:
`
`[1] Oracle Configurator Developer 11i User’s Guide, Release 11i for Windows 95/98 and
`Windows NT 4.0, April 2000
`
`
`[2] Oracle Configurator Configuration Interface Object (CIO) Developer’s Guide, Release
`11i, March 2000
`
`
`[3] Beologic A/S Reference Guide for the beologic salesPLUS Product Configurator, C
`language API, Version 2.0, 1995
`
`
`
`
`
`CONFIGIT 1021
`
`1
`
`
`
`
`
`
`
`
`June 14, 2021
`Page 2
`
`[4] Bei Yu and H. J. Skovgaard, “A configuration tool to increase product
`competitiveness,” in IEEE Intelligent Systems and their Applications, vol. 13, no. 4, pp.
`34-41, July-Aug. 1998
`
`
`[5] Atif M. Memon, Martha E. Pollack, Mary Lou Soffa, “Automated Test Oracles for
`GUIs”, Proceedings of the Eighth International Symposium on the Foundation of
`Software Engineering (FSE-8), San Diego, CA, Nov. 6, 2000
`
`
`The grounds are:
`
`
`Ground
`Ground 1
`
`Ground 2
`Ground 3
`Ground 4
`
`Basis
`§ 103
`
`§ 103
`§ 103
`§ 103
`
`Claims
`1, 9-10, 14,
`19
`15-17
`11-13
`2, 18
`
`Ground 5
`
`§ 103
`
`3-5
`
`Prior Art References Used in Challenge
`[1], [2]
`
`[1], [2], [3]
`[1], [2], [3], [4]
`[1], [2], [5]
`
`[1], [2], [3], [5]
`
`
`For sake of clarity and to avoid any doubt, if the PTAB declines IPR institution, Configit reserves
`the right to pursue the grounds of the IPR in this litigation. Further, Configit reserves the right to
`pursue in this litigation any ground or basis of invalidity that could not have been raised under the
`IPR procedure, or against any claim not challenged in IPR.
`
`Sincerely,
`
`
`
`David M. Hoffman
`Counsel for Configit
`
`
`
`
`
`2
`
`
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