`Tel 212.801.2157
`kassenoffa@gtlaw.com
`
`December 3, 2021
`
`VIA EMAIL
`Daniel J. Schwartz
`Nixon Peabody LLP
`70 West Madison, Suite 3500
`Chicago, IL 60602-4224
`djschwartz@nixonpeabody.com
`
`Re: MemoryWeb, LLC v. Samsung Elecs. Co. Ltd. et al, No. 21-cv-411 (W.D. Tex.)
`
`Counsel:
`We write regarding the petition for inter partes review (“IPR”) filed against one of the
`patents in suit, U.S. Patent No. 10,621,228 (“the ’228 patent”) in the above-captioned
`litigation. We write to inform you that Samsung Electronics Co., Ltd. and Samsung
`Electronics America, Inc. (collectively, “Samsung”) hereby stipulate that, if the Patent
`Trial and Appeal Board (“PTAB”) institutes this petition on the ground presented, then
`Samsung will not seek resolution in the district court of any ground of invalidity as to
`the ’228 patent that utilizes U.S. Patent App. Pub. No. 2011/0122153 A1 (“Okamura”),
`the primary reference asserted in the IPR proceeding.
`In so stipulating, Samsung seeks to avoid multiple proceedings addressing the validity
`of the ’228 patent based on the same primary reference. Rather, consistent with
`Congressional intent, Samsung wishes the patentability of this patent over grounds
`based on Okamura to be addressed at the PTAB. But, for the sake of clarity and to
`avoid any doubt, if the PTAB declines institution of Samsung’s IPR petition relating to
`the ’228 patent, Samsung reserves the right to pursue this prior art in the litigation.
`
`Sincerely,
`
`/Allan A. Kassenoff /
`Allan A. Kassenoff
`
`1
`
`SAMSUNG 1037
`
`
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