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Subject: Hafeman v. LG Electronics Inc., No. 6:21-cv-696-ADA-DTG (W.D. Tex.) - Sotera SEpulaEon
`Date: Wednesday, November 30, 2022 at 11:16:50 AM Eastern Standard Time
`From:
`Singh, Tej
`To:
`Lawrence Hadley, Jason Linger, Genevieve Vose Wallace, Max Tribble, Krisina Zuniga, Tom
`DelRosario, Kalpana Srinivasan, Dan Duhaime, cmcandrew@glaserweil.com
`Crowson, Celine J., Gambhir, NiEn, Stoll-DeBell, KirsEn L., Beyer, Carrie, Silverstein, Brianna L.,
`Brzezynski, Lora A., Kirsten Elfstrand, J. Stephen Ravel, Michael Jones, Shaun Hasse]
`
`CC:
`
`Counsel -
`
`Google and Microsoft have filed petitions for inter partes review against the three Hafeman patents
`asserted in this case and identified LG Electronics Inc. as a real party-in-interest.
`
`As you know, LG Electronics Inc. is the only defendant in Hafeman v. LG Electronics, Inc. (Case No.
`6:21-cv-00696-ADA-DTG), and the deadline to add parties was on June 8, 2022. In accordance with
`the Board’s precedential decision in Sotera Wireless, Inc. v. Masimo Corp., IPR2020-01019, Paper 12 at
`18-19 (PTAB Dec. 1, 2020), LG Electronics Inc. agrees that if any of IPR Nos. IPR2022-01188,
`IPR2022-01189, IPR2022-01190, IPR2022-01191, IPR2022-01192, and IPR2022-01193 is instituted,
`LG Electronics Inc. will not pursue in the related district court proceeding “any ground that [Google or
`Microsoft] raised or reasonably could have raised” during the instituted IPRs. 35 U.S.C. § 315(e).
`
`Best regards,
`Tej
`_______________________________________________________________________________
`Tej Singh | Counsel | Hogan Lovells US LLP | tej.singh@hoganlovells.com | + 1 650 463 4152
`
`EX-1029
`
`

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