`
`O’Melveny & Myers LLP
`400 South Hope Street
`18th Floor
`
`Los Angeles, CA 90071
`
`T: +1 213 430 6000
`F: +1 212 430 6407
`omm.com
`
`October 25, 2022
`
`VIA E-MAIL
`
`File Number: 0409095-00070
`
`Clarence A. Rowland
`D: +1 213 430 7245
`crowland@omm.com
`
`Jamie H. McDole
`jmcdole@winstead.com
`Winstead PC
`Dallas, Texas 75201
`
`Re:
`
`Image Processing Techs., LLC v. LG Electronics Inc., Case No. 2:22-cv-00077-JRG-
`RSP
`
`Dear Jamie:
`
`We write to inform you that LG Electronics Inc. and LG Electronics USA, Inc. (collectively, “LG”)
`hereby stipulate that if the PTAB institutes inter partes review for LG’s concurrently filed IPR
`petition challenging U.S. Patent 6,959,293 (the “’293 Patent”), then LG will not pursue invalidity
`against Image Processing Techs., LLC’s (“IPT”) Claim 1 of the ’293 Patent in the District Court
`proceeding captioned above using any anticipation or obviousness ground which includes the
`primary reference in that petition, referred to therein as “Pirim” (including its incorporated
`documents), and will not present any anticipation or obviousness ground that includes the
`secondary reference used in that Petition, referred to therein as “Bolle.” LG reserves the right to
`present invalidity in the District Court proceeding on other bases.
`
`To be clear, this stipulation does not encompass any arguments regarding the proper priority
`date or dates of alleged invention of the ’293 Patent’s Claim 1. Accordingly, LG reserves the
`right to make arguments regarding the priority date of the ’293 Patent. This stipulation does not
`apply to any claims other than Claim 1 of the ’293 Patent, nor does it apply to any claims of any
`other patent. Additionally, the references and invalidity grounds identified above may be
`included in LG’s invalidity contentions to preserve its rights in the event that, for example, the
`above-captioned IPR is not instituted.
`
`Sincerely,
`
`
`
`
`Clarence A. Rowland
`O’MELVENY & MYERS LLP
`
`Century City • Los Angeles • Newport Beach • New York • San Francisco • Silicon Valley • Washington, DC
`Beijing • Brussels • Hong Kong • London • Seoul • Shanghai • Singapore • Tokyo
`
`Petitioner LG Ex-1020, 0001
`
`
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