`2000 University Avenue
`East Palo Alto, California 94303-2250
`www.dlapiper.com
`
`Erik R. Fuehrer
`Erik.Fuehrer@dlapiper.com
`T 650.833.2045
`F 650.687.1243
`
`January 14, 2022
`ATTORNEY-CLIENT PRIVILEGE
`VIA E-MAIL BRIAN.MICHALEK@SAUL.COM
`
`Saul Ewing Arnstein & Lehr LLP
`Brian R. Michalek
`161 N. Clark St., Suite 4200
`Chicago, IL 60601
`
`Re:
`
`BillJCo LLC v. Cisco Systems Inc., Case No. 2:21-cv-00181-JRG (E.D. Tex.) (Lead Case);
`BillJCo, LLC v. Hewlett Packard Enterprise Company et al.,
`Case No. 2:21-cv-002183-JRG (E.D. Tex.) (Member Case);
`BillJCo, LLC v. Apple Inc., Case No. 6:21-cv-00528 (W.D. Tex.)
`
`Dear Counsel:
`
`On behalf of Defendants Cisco Systems, Inc., Apple Inc, Hewlett Packard Enterprise Company,
`
`and Aruba Networks, LLC (collectively “Defendants”) in the above-referenced cases (“the Litigation”), we
`write regarding a petition for inter partes review (“IPR”) that Defendants intend to file with the Patent Trial
`and Appeal Board (“PTAB”) to address claims 1-3, 9, 11-13, and 19-20 of U.S. Patent No. 10,292,011
`
`(the “Petition”).
`
`We write to inform you that Defendants, as real parties-in-interest (“RPIs”) in the Petition, hereby
`
`stipulate that in the event the PTAB institutes an IPR based on the Petition, Defendants will not seek
`
`resolution in the Litigation of any ground of invalidity pursued in the instituted Petition.
`
`By so stipulating, Defendants seek to avoid multiple proceedings addressing the validity of claims
`
`1-3, 9, 11-13, and 19-20 of U.S. Patent No. 10,292,011 based on the instituted grounds in the Petition.
`
`Defendants request that the patentability of these claims over the grounds presented in the Petition to be
`addressed at the PTAB. For the sake of clarity and to avoid any doubt, if the PTAB declines to institute an
`
`IPR based on the Petition, Defendants reserve the right to pursue the non-instituted grounds from the
`
`denied Petition in this litigation. Additionally, even in the event of institution, each Defendant reserves its
`right in the Litigation to rely on any prior art and prior art combinations other than the instituted grounds in
`
`the Petition.
`
`Best regards,
`
`Erik R. Fuehrer
`
`ERF:
`
`WEST\297221262.1
`
`Exhibit 1024
`IPR2022-0427
`Page 1 of 1
`
`
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