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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`CLOVER NETWORK, LLC
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`Petitioner
`v.
`CLOUDOFCHANGE, LLC
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`Patent Owner
`____________________________________________
`IPR2023-00287
`U.S. Patent No. 11,226,793
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`PETITIONER’S STIPULATION
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`IPR2023-00287
` Patent No. 11,226,793
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`Pursuant to the Board’s authorization, given during the Conference Call on
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`March 27, 2023, Defendant Clover Network, LLC (“Clover”) stipulates that if this
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`IPR is instituted and Fintiv remains precedential at the time of institution, Clover
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`stipulates not to pursue in the district court any ground raised or that could have
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`reasonably been raised in this IPR (i.e., under §§ 102 or 103 based on prior art
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`patents or printed publications alone). The stipulation provided herein is identical
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`to the stipulation provided in the corresponding Lightspeed IPR (IPR2022-01143).
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`Further pursuant to the Board’s authorization, Clover stipulates that if this
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`IPR is instituted and Clover’s Motion for Joinder of IPR2022-01143 is granted,
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`Clover stipulates to be bound by the opinions and testimony of Lightspeed’s
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`declarant, Stephen Gray, including the deposition testimony given on December
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`21, 2022, and any subsequent declarations or depositions provided by Mr. Gray in
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`the corresponding Lightspeed IPR (IPR2022-01143).
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`IPR2023-00287
` Patent No. 11,226,793
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`Respectfully submitted,
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`Dated: March 29, 2023
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`By: /Jason Kipnis/
`Jason D. Kipnis
`Reg. No. 40,680
`WILMER, CUTLER, PICKERING, HALE AND
`DORR, LLP
`2600 El Camino Real
`Suite 400
`Palo Alto, CA 94306
`(650) 600-5036
`jason.kipnis@wilmerhale.com
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`3
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`IPR2023-00287
` Patent No. 11,226,793
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`CERTIFICATE OF SERVICE
`I hereby certify that on March 29, 2023, I caused a true and correct copy of
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`the foregoing “PETITIONER’S STIPULATION” to be served via electronic
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`service by email to the email addresses provided below:
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`tpatterson@pattersonsheridan.com
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`jyates@pattersonsheridan.com
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`kcameron@pattersonsheridan.com
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`egonzalez@pattersonsheridan.com
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`By:
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`/Amy L. Mahan/
`Amy L. Mahan
`Reg. No. 75,997
`WILMER, CUTLER, PICKERING, HALE AND
`DORR, LLP
`60 State Street
`Boston, MA 02109
`(617) 526-6182
`amy.mahan@wilmerhale.com
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`4
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