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`________________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`________________________________
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`ROKU, INC.,
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`Petitioner,
`
`v.
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`IOENGINE, LLC,
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`Patent Owner.
`
`________________________________
`
`Case IPR2022-01551
`U.S. Patent No. 10,972,584
`________________________________
`
`PETITIONER’S STIPULATION
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`
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`
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`Pursuant to the Board’s authorization on March 28, 2023, Petitioner Roku,
`
`Case IPR2022-01551
`U.S. Patent No. 10,972,584
`
`
`
`Inc. submits the following stipulation.
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`Petitioner stipulates that, if (and only if) the Patent Trial and Appeal Board
`
`institutes an IPR in this proceeding on the grounds presented in the Petition,
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`Petitioner will not pursue an invalidity defense in the district court action (C.A.
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`No. 21-cv-01296-ADA-DTG) that the patent claims subject to the instituted IPR
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`are invalid based on the same grounds as in the Petition or that the patent claims
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`subject to the instituted IPR are invalid in view of the references that form the
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`stated bases for those grounds (U.S. Patent Application Publication No.
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`2001/0030959 (Ozawa), U.S. Patent Application Publication No. 2002/0104091
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`(Prabhu), and U.S. Patent No. 7,242,766 (Lyle)).
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`
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`Dated: March 29, 2023
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`
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`
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`Respectfully submitted,
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`
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`By: /James L. Lovsin/
`James L. Lovsin, Reg. No. 69,550
`
`Email: lovsin@mbhb.com
`McDonnell Boehnen Hulbert &
`Berghoff LLP
`300 S. Wacker Drive
`Chicago, IL 60606
`Ph: 312-913-0001
`Fax: 312-913-0002
`
`Counsel for Roku, Inc.
`
`
`
`1
`
`
`
`
`
`Case IPR2022-01551
`U.S. Patent No. 10,972,584
`
`CERTIFICATE OF SERVICE
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`I hereby certify that on March 29, 2023, a copy of the foregoing Petitioner’s
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`Stipulation was served by electronic mail upon the following counsel for Patent
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`Owner:
`
`
`derek.brader@dechert.com
`
`michael.fisher@dechert.com
`
`noah.leibowitz@dechert.com
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`greg.chuebon@dechert.com
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`michael.joshi@dechert.com
`
`
` Respectfully submitted,
`
`By: /James L. Lovsin/
` James L. Lovsin
` Reg. No. 69,550
`
`Counsel for Roku, Inc.
`
`
`
`2
`
`
`
`Dated: March 29, 2023
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`
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`
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