`500 Arguello St., Suite 400
`Redwood City, CA 94063
`650 839 5070 main
`
`Katherine D. Prescott
`Principal
`prescott@fr.com
`650 839 5180 direct
`
`November 22, 2022
`
`VIA E-MAIL
`
`John L. North
`Steven G. Hill
`David K. Ludwig
`Martha L. Decker
`Hill, Kertscher & Wharton
`3625 Cumberland Blvd. Suite 1050
`Atlanta, GA 30339
`
`Korula T. Cherian
`Robert M. Harkins, Jr.
`Cherian LLP
`1936 University Avenue, Suite 350
`Berkeley, CA 94704
`
`Re:
`
`R.N Nehushtan Trust Ltd., v. Apple Inc. Case No. 3:22-cv-01832-WHO
`
`Dear Counsel:
`
`We write regarding the petition for inter partes review (IPR) filed against the patent in suit, U.S.
`Patent No. 9,642,002, in the captioned litigation. We write to inform you that Apple Inc.
`(“Apple”) hereby stipulates that if the Patent Trial and Appeal Board (PTAB) institutes this
`petition on the grounds presented, then the Defendant, Apple, will not seek resolution in the
`district court of any ground of invalidity that utilizes U.S. Patent No. 8,635,661 (“Shahbazi”) or
`U.S. Patent No. 7,181,726 (“Fam”).
`
`In so stipulating, Apple seeks to avoid multiple proceedings addressing the validity of the ’002
`patent based on any of the same prior art references. Rather, consistent with Congressional
`intent, Apple wishes the patentability of this patent over Shahbazi or Fam 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 petition relating to the ’002 patent, Apple reserves the right to pursue this prior art
`in the litigations.
`
`Sincerely,
`
`Katherine D. Prescott
`Fish & Richardson P.C.
`
`1
`
`APPLE 1025
`
`
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