`12860 El Camino Real, Ste. 400
`San Diego, CA 92130
`858 678 5070 main
`858 678 5099 fax
`
`Christopher S. Marchese
`Principal
`marchese@fr.com
`858 678 4314 direct
`
`VIA EMAIL
`
`October 21, 2021
`
`Gavin Snyder
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`50 California Street, 22nd Floor
`San Francisco, CA 94111
`gavinsnyder@quinnemanuel.com
`
`Re:
`
`Taction Technology, Inc. v. Apple Inc.
`Case No. 21-cv-00812-TWR-JLB
`
`Dear Counsel:
`
`I write regarding the petitions for inter partes review (IPR) that are being filed today against U.S.
`Patent Nos. 10,659,885 (“the ’885 patent”) and 10,820,117 (“the ’117 patent”) in the above-
`captioned litigation. I write to inform you that Apple Inc. hereby stipulates that if the Patent Trial
`and Appeal Board institutes any of these petitions, then Apple will not seek resolution in the district
`court of any ground of invalidity pursued in the instituted petition.
`
`In so stipulating, Apple seeks to avoid multiple proceedings addressing the validity of the ’885
`patent or the ’117 patent based on the same grounds. Rather, consistent with Congressional intent,
`Apple wishes the patentability of these patents over the grounds presented in the IPR petitions to
`be addressed at the PTAB. For the sake of clarity and to avoid any doubt, if the PTAB denies
`institution of any of Apple’s IPR petitions relating to the ’885 patent or the ’117 patent for any
`reason, Apple reserves the right to pursue the non-instituted grounds from any such denied petition
`in this litigation.
`
`Very truly yours,
`
`Christopher S. Marchese
`
`IPR2022-00059
`Apple EX1046 Page 1
`
`
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