`
`NetNut Ltd. v. Bright Data Ltd.
`IPR2021-01492, EX. 2002
`Page 1 of 3
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`
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`Bright Data proposesthat, similar to the parties’ agreementin their prior case, the parties
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`adopt this Court’s claim constructions for the asserted °510 and °319 Patents from the Claim
`
`Construction Opinion and Order in Luminati Networks, Ltd. V. Teso LT, UAB et al., Case No. 2:19-
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`cv-00395, Dkt. No. 191, dated December 7, 2020 (attached as Exhibit 1).
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`In adopting the claim
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`constructions from the 7eso litigation the parties would preserve and not waive their rights to
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`appeal, including to the U.S. Court of Appeals for the Federal Circuit, any claim construction that
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`departs from their proposed constructions and positions. Should Defendants not agree to adopting
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`these prior constructions, Bright Data also reserves the right to identify additional claim terms for
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`construction for the *510 and *319 Patents.
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`Bright Data provides below proposed claims terms for construction for the asserted ’713,
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`°852, and °346 Patents.
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`Claim Term
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`Relevant Claims
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`
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`All asserted claims of the ’713, 852, and °346 Patents
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`All asserted claims of the ’713 and °852 Patents
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`All asserted claims of the ’713 and ’852 Patents
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`All asserted claims of the ’346 Patent
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`Dated: December8, 2021
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`By: /s/ J. Michael Woods
`
`Elizabeth L. DeRieux
`State Bar No. 05770585
`Capshaw DeRieux, LLP
`114 E. Commerce Ave.
`Gladewater, TX 75647
`Telephone: 903-845-5770
`ederieux@capshawlaw.com
`
`J. Mark Mann
`G. Blake Thompson
`
`NetNutLtd. v. Bright Data Ltd.
`IPR2021-01492, EX. 2002
`Page 2 of 3
`
`
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`Attorneys for Plaintiff
`Bright Data Ltd.
`
` /s/ J. Michael Woods
`
`NetNut Ltd. v. Bright Data Ltd.
`IPR2021-01492, EX. 2002
`Page 3 of 3
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