`
`
`
`
`
`
`
`SENT VIA E-MAIL
`
`May 19, 2022
`
`
`
`
`
`Michael Pieja
`312.881.5954
`mpieja@goldmanismail.com
`
`
`XR Communications, LLC v. Apple Inc., Case No. 6:21-cv-00620 (W.D. Tex.)
`
`Reza Mirzaie, Paul A. Kroeger, Philip X. Wang, James N. Pickens, Minna Chan, Christian Conkle
`Russ August & Kabat
`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`
`Re:
`
`Dear Counsel:
`
`Apple Inc. (“Apple”) has filed an inter partes review (IPR) petition (IPR2022-00367) with the Patent Trial
`and Appeal Board (PTAB) to address the validity of claims 8-14 of U.S. Patent No. 10,715,235. The
`tables in attached Appendix A list all the grounds, challenged claims, and references asserted in
`IPR2022-00367.
`
` I
`
` write to inform you that Apple hereby stipulates that:
`if the PTAB institutes IPR2022-00367 based on the grounds and claims listed in the tables in
`•
`Appendix A, Apple will not pursue in the District Court the specific grounds raised in IPR2022-
`00367 against claims 8-14.
`
`
`In so stipulating, Apple seeks to avoid multiple proceedings addressing the validity of the challenged
`claims based on the same grounds. Rather, through this stipulation, Apple expresses its intention to
`have only the PTAB address the Instituted Grounds of invalidity of these claims. But, for the sake of
`clarity and to avoid any doubt, if the PTAB declines to institute any of the grounds identified herein, Apple
`reserves the right to assert the denied grounds in the litigation. Apple also reserves its rights to continue
`to assert grounds other than the Instituted Grounds.
`
`
`
`Sincerely,
`
`
`
`
`
`
`Michael Pieja
`Attorney for Apple Inc.
`
`
`
`
`Chicago 200 South Wacker, 22nd Floor, Chicago, IL 60606
`Dallas 7557 Rambler Road, Suite 1450, Dallas, TX 75231
`Santa Monica 100 Wilshire Boulevard, Suite 1760, Santa Monica, CA 90401 goldmanismail.com
`
`
`
`APPLE ET AL. 1033
`
`1
`
`
`
`May 19, 2022
`Page 2
`
`Appendix A – Grounds and Prior Art References Used in IPR2022-00367
`
`
`Ground
`
`1
`
`2
`
`Claim(s)
`
`8-12
`
`13, 14
`
`35 U.S.C. § 103
`
`Burke
`
`Burke in view of Shull
`
`List of References
`
`
`Reference Name Details
`Burke
`U.S. Patent No. 7,155,231
`Shull
`U.S. Patent No. 6,006,077
`
`
`
`
`
`
`
`
`2
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
