`To Call Writer Directly:
`+1 312 862 3169
`david.rokach@kirkland.com
`
`
`
`
`
`300 North LaSalle
`Chicago, IL 60654
`United States
`
`+1 312 862 2000
`
`www.kirkland.com
`
`June 9, 2022
`
`VIA ELECTRONIC MAIL
`
`Jacob A. Snodgrass
`PV LAW LLP
`5335 Wisconsin Avenue, N.W., Suite 440
`Washington, D.C. 20015
`jacob.snodgrass@pvuslaw.com
`
`
`
`
`
`
`
`
`
`
`Facsimile:
`+1 312 862 2200
`
`
`
`Re: Staton Techiya, LLC and Synergy IP Corp. v. Samsung Elecs. Co. et al., Case.
`Nos. 2:21-cv-413-JRG (E.D. Tex. 2021), 2:22-cv-00053-JRG-RSP (E.D. Tex. 2022)
`
`Dear Jacob:
`
`We write regarding petitions for inter partes review (IPR) that will be filed imminently
`against certain claims of U.S. Patent Nos. 11,039,259, 11,057,701, 11,217,237, and 11,244,666.
`Samsung hereby stipulates that:
`
`•
`
`•
`
`•
`
`If the Patent Trial and Appeal Board (PTAB) institutes trial in IPR2022-01078, then
`Samsung Electronics Co., Ltd. and Samsung Electronics, America, Inc. (collectively,
`“Samsung”) will not pursue, with respect to the ’701 patent in Case No. 2:22-cv-00053-
`JRG-RSP (the “Parallel Litigation”), invalidity of the challenged claims either based
`on the grounds instituted in IPR2022-01078, or based on any ground using EP
`1,385,324 (“Pederson”) as the primary reference.
`
`If the PTAB institutes trial in IPR2022-01098, then Samsung will not pursue, with
`respect to the ’237 patent in the Parallel Litigation, invalidity of the challenged claims
`either based on the grounds instituted in IPR2022-01098, or based on any ground
`using U.S. Patent Publication 2010/0119077 (“Platz”) or EP 1,640,972 A1
`(“Dijkstra”) as the primary reference.
`
`If the PTAB institutes trial in IPR2022-01099, then Samsung will not pursue, with
`respect to the ’666 patent in the Parallel Litigation, invalidity of the challenged claims
`either based on the grounds instituted in IPR2022-01099, or based on any ground
`
`Austin Bay Area Beijing Boston Brussels Chicago Dallas Hong Kong Houston
`
`
`
`
`London
`
`Los Angeles Munich Paris Salt Lake City Shanghai Washington, D.C.
`
`Exhibit 1029
`Page 01 of 02
`
`
`
`Jacob Snodgrass
`June 9, 2022
`Page 2
`
`
`
`
`
`
`
`using U.S. Patent Publication 2010/0119077 (“Platz”), EP 1,519,625 A2
`(“Victorian”), or U.S. 5,276,740 (“Inanaga”) as the primary reference.
`
`•
`
`If the PTAB institutes trial in IPR2022-01106, then Samsung will not pursue, with
`respect to the ’259 patent in the Parallel Litigation, invalidity of the challenged claims
`either based on the grounds instituted in IPR2022-01106, or based on any ground
`using U.S. 9,135,797 (“Couper”) or U.S. 6,408,272 (“White”) as the primary
`reference.
`
`
`
`Sincerely,
`
`/s/ David Rokach
`
`David Rokach
`
`
`CC: Counsel of record
`
`
`
`
`
`Exhibit 1029
`Page 02 of 02
`
`
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