`
`O’Melveny & Myers LLP
`610 Newport Center Drive
`17ᵗʰ Floor
`Newport Beach, CA 92660-6429
`
`T: +1 949 823 6900
`F: +1 949 823 6994
`omm.com
`
`April 18, 2022
`
`
`
`John Kappos
`D: +1 949 823 6954
`jkappos@omm.com
`
`VIA EMAIL
`
`RE: Scramoge Technology Ltd. v. Samsung Electronics Co., Ltd. and Samsung Electronics
`America, Inc., Case No. 6:21-cv-00454-ADA (W.D. Tex.) and IPR2022-00284.
`
`
`Counsel for Scramoge:
`
`We represent Samsung in the above referenced matters. We write to inform you that Samsung
`Electronics Co., Ltd. and Samsung Electronics America, Inc. (collectively “Samsung” or
`“Petitioner”), hereby stipulates that if the PTAB institutes inter partes review no. IPR2022-
`00284 challenging U.S. Patent No. 9,997,962 (“’962 patent”), then Petitioner will not pursue
`invalidity against the asserted claims of the ’962 patent in the District Court proceeding
`captioned above using any obvious ground that includes the primary reference in that IPR
`petition referred to therein as “Suzuki.” Petitioner reserves the right to present invalidity in the
`District Court on other bases.
`
`To be clear, this stipulation does not encompass any arguments regarding the proper priority date
`or dates of alleged invention of the ’962 patent claims. Accordingly, Petitioner reserves the right
`to make arguments regarding the priority date of the ’962 patent. This stipulation does not apply
`to any claims other than the claims challenged in the above-captioned IPR, nor does it apply to
`any claims of any other patent. Additionally, the primary references identified above may be
`included in Samsung’s invalidity contentions to preserve its rights in the event that the above-
`captioned IPR does not go forward.
`
`Thank you for your attention to these matters.
`
`Sincerely,
`
`/s/ John Kappos
`John Kappos, Counsel for Samsung
`
`
`
`
`
`Austin • Century City • Dallas • Los Angeles • Newport Beach • New York • San Francisco • Silicon Valley • Washington, DC
`Beijing • Brussels • Hong Kong • London • Seoul • Shanghai • Singapore • Tokyo
`
`Petitioner Samsung and Google Ex-1022, 0001
`
`
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