`
`VIA E-MAIL
`
`
`
`Raymond W. Mort, III
`raymort@austinlaw.com
`THE MORT LAW FIRM, PLLC
`100 Congress Avenue, Suite 2000
`Austin, Texas 78701
`
`Re:
`
`
`
`Jawbone Innovations, LLC v. Apple Inc., Case No. 6:21-cv-00984
`
`Counsel:
`
`We write regarding a petition for inter partes review (IPR) being filed with the Patent
`Trial and Appeal Board (PTAB) to address claims of U.S. Patent No. 11,122,357 (“the
`’357 patent”). The table below lists grounds asserted by Apple Inc. (“Apple”) in the
`IPR2022-01321 petition challenging claims of this patent, along with the implicated
`claims against which the grounds are asserted.
`
`We write to inform you that Apple hereby stipulates that in the event the PTAB
`institutes an inter partes review based on the IPR2022-01321 petition and including
`the grounds listed in the table below against the corresponding claims listed in the
`table for those grounds (“Instituted Grounds”), then Apple will not seek resolution in
`the above-captioned district court litigation (6:21-cv-00984) of the Instituted Grounds
`against the corresponding claims listed in the table for those same grounds.
`
`
`
`Patent No. Proceeding No.
`
`Claim(s)
`
`Ground
`
`11,122,357
`
`IPR2022-01321 1-20
`
`Obvious (§ 103) over Kanamori,
`McCowen, and Elko
`
`
`
`In so stipulating, Apple seeks to avoid multiple proceedings addressing the validity of
`the ’357 patent based on the same grounds. Rather, Apple wishes the patentability of
`this patent over the above-identified Grounds to be addressed at the PTAB. But, for
`the sake of clarity and to avoid any doubt, if the PTAB declines institution of Apple’s
`IPR petitions relating to the ’357 patent, Apple reserves the right to seek resolution of
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`Page 1 of 3
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`July 27, 2022
`Page 2
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`the above-identified Grounds in the above-captioned district court litigation (6:21-cv-
`00984).
`
`
`
`
`
`
`Sincerely,
`
`/s/ Ricardo Bonilla
`
`Ricardo Bonilla
`Fish & Richardson P.C.
`Counsel for Apple Inc.
`
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`Page 2 of 3
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`Reference
`Name
`
`Kanamori
`
`McCowan
`
`Elko
`
`July 27, 2022
`Page 3
`
`List of Prior Art References
`
`
`Details
`
`U.S. Patent Publication No. 2004/0185804 to Kanamori et al.,
`filed November 18, 2003, and published September 23, 2004
`
`Iain A. McCowan et al., Near-field Adaptive Beamformer for
`Robust Speech Recognition, 12 Digital Signal Processing 87-
`106 (2002); published in January 2002
`
`U.S. Patent No. 8,942,387 to Elko et al., claims priority to
`international application PCT/US2007/006093, filed March 9,
`2007
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`Page 3 of 3
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