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`U.S. Patent No. 6,807,505
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`IPR2022-01488
` Joint Motion to Terminate
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________
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`APPLE INC.,
`Petitioner
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`v.
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`FUTURE LINK SYSTEMS, LLC,
`Patent Owner.
`______________________________________________
`Case No. IPR2022-01488
`U.S. Patent No. 6,807,505
`______________________________________________
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`JOINT MOTION TO TERMINATE INTER PARTES REVIEW
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`U.S. Patent No. 6,807,505
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`IPR2022-01488
` Joint Motion to Terminate
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`Patent Owner Future Link Systems, LLC (“FLS”) and Petitioner Apple Inc.
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`(“Apple”) have reached a settlement. Pursuant to 35 U.S.C. § 317(a) and 37
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`C.F.R. §§ 42.72 and 42.74, the parties jointly request termination of the inter
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`partes review of U.S. Patent No. 6,807,505 (“Patent-in-Suit”), Case IPR2022-
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`01488. As set forth in an e-mail dated June 9, 2022, the Board authorized the
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`filing of the requested Joint Motion to Terminate this Petition.
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`As required under 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(b), a true copy
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`of the release agreement that resolves the disputes in the above-captioned inter
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`partes review relating to the Patent-in-Suit as between FLS and Apple is filed
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`herewith as an exhibit. There are no other collateral agreements between the parties
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`made in connection with, or in contemplation of, the termination sought.
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`Pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c), FLS and Apple are
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`concurrently filing a Joint Request to Keep Separate, which asks the Board to treat
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`the release agreement as business confidential information, and to keep it separate
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`from the files of this proceeding and the files of the Patent-in-Suit.
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`I.
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`STATEMENT OF PRECISE RELIEF REQUESTED
`The parties jointly request that the Board terminate the inter partes review of
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`the Patent-in-Suit, IPR2022-01488.
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`U.S. Patent No. 6,807,505
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`IPR2022-01488
` Joint Motion to Terminate
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`II. TERMINATION IS APPROPRIATE
`Termination of this proceeding with respect to all parties is proper. This
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`inter partes review is still in an early stage. This Petition was filed on September
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`28, 2021.
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`Under 35 U.S.C. § 317(a), “[a]n inter partes review instituted under this
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`chapter shall be terminated with respect to any petitioner upon the joint request of
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`the petitioner and the patent owner, unless the Office has decided the merits of the
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`proceeding before the request for termination is filed.” Because all parties request
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`termination and the Board has not yet decided the merits of the proceeding, the
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`Board should terminate the proceeding with respect to Apple.
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`When there are no petitioners remaining in an inter partes review, the Board
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`may terminate the proceeding entirely. 35 U.S.C. § 317(a); 37 C.F.R. § 42.72.
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`Apple is the only petitioner in this inter partes review. All parties support
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`termination of this proceeding. With no petitioners remaining in the proceeding
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`and no final written decision on the merits, termination of this proceeding entirely
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`is appropriate.
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`The lawsuits involving the Patent-in-Suit between FLS and Apple have been
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`dismissed, and FLS and Apple do not contemplate any litigation or proceeding
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`involving the Patent-in-Suit in the foreseeable future.
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`U.S. Patent No. 6,807,505
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`IPR2022-01488
` Joint Motion to Terminate
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`III. CONCLUSION
`FLS and Apple have settled all disputes relating to the Patent-in-Suit. The
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`USPTO can conserve its resources through terminating now, removing the need for
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`the Board to further consider the arguments and to issue a Final Written Decision.
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`Accordingly, the parties respectfully request that the Board terminate this
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`proceeding.
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`Dated: June 10, 2022
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`Respectfully submitted,
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`/s/ Adam P. Seitz
`Adam P. Seitz, Reg. No. 52,206
`ERISE IP, P.A.
`7015 College Boulevard, Suite 700
`Overland Park, KS 66211
`COUNSEL FOR PETITIONER
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`/Reza Mirzaie /__________________
`Reza Mirzaie (Reg. No. 69,138)
`Russ, August & Kabat
`12424 Wilshire Blvd., 12th Floor
`Los Angeles, CA 90025
`Attorney for Patent Owner
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`CERTIFICATE OF SERVICE
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`U.S. Patent No. 6,807,505
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`IPR2022-01488
` Joint Motion to Terminate
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`The undersigned certifies to 37 C.F.R. §42.6(e) and §42.105 that the above
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`document was served on June 10, 2022, by filing this document through the Patent
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`Trial and Appeal Board End to End system as well as by delivering a copy via
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`electronic mail to the following attorneys of record for the Patent Owner:
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`BY: /s/ Adam P. Seitz
`Adam P. Seitz, Reg. No. 52,206
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`COUNSEL FOR PETITIONER
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