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UNITED STATES PATENT AND TRADEMARK OFFICE
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`________________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`________________________________
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`SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS
`AMERICA, INC., AND QUALCOMM INCORPORATED,
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`Petitioner,
`
`v.
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`DAEDALUS PRIME LLC,
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`Patent Owner.
`
`____________________________
`
`Case IPR2023-00567
`U.S. Patent No. 10,049,080 B2
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`DAEDALUS AND SAMSUNG’S
`JOINT REQUEST TO TREAT EXHIBIT 1034
`AS BUSINESS CONFIDENTIAL INFORMATION
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`

`

`Case IPR2023-00567
`U.S. Patent No. 10,049,080 B2
`
`
`
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`Daedalus and Samsung have jointly filed a motion to terminate this
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`proceeding as to Samsung, pursuant to a settlement agreement between them.
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`Pursuant to the Board’s request as set forth in its email of May 24, 2023 and in
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`accordance with 35 U.S.C. § 317(b), the Daedalus and Samsung have filed the
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`settlement agreement as Exhibit 1034. The settlement agreement provides that the
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`terms of the agreement are to be maintained as confidential by Daedalus and
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`Samsung and, subject to certain exceptions, may not be disclosed to any third
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`parties without the express written consent of the non-disclosing party.
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`
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`The Board has granted Daedalus and Samsung leave to file this motion to
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`treat the settlement agreement as business confidential information. Daedalus and
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`Samsung therefore jointly move pursuant to 37 C.F.R. § 42.74(c) that the
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`settlement agreement submitted as Exhibit 1034, be treated as business
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`confidential information and be kept separate from the files of the patent at issue in
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`this proceeding. Qualcomm does not oppose.
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`

`

`Case IPR2023-00567
`U.S. Patent No. 10,049,080 B2
`
`
`Respectfully submitted,
`
`
`By: Ben Haber
`Benjamin Haber (Reg. No. 67,129)
`O’Melveny & Myers LLP
`400 South Hope Street, 18th Floor
`Los Angeles, CA 90071
`Telephone: (213) 430-6000
`Fax: (213) 430-6407
`E-Mail: bhaber@omm.com
`
`
`Counsel for Petitioner,
`Samsung Electronics Co., Ltd., and
`Samsung Electronics America, Inc.
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` Peter F. Snell
`Peter F. Snell (Reg. No. 52,235)
`MINTZ, LEVIN, COHN, FERRIS
`GLOVSKY AND POPEO, P.C.
`919 Third Avenue
`New York, New York 10022
`Telephone: 212-692-6850
`Facsimile: 212-983-3115
`E-mail: PFSnell@mintz.com
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` Counsel for Patent Owner,
`Daedalus Prime LLC
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`Date: June 2, 2023
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`Case IPR2023-00567
`U.S. Patent No. 10,049,080 B2
`
`
`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e)(1))
`
`The undersigned hereby certifies that the above document was served on
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`June 2, 2023, by filing this document through the Patent Trial and Appeal
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`Board P-TACTS System, as well as delivering a copy via electronic mail to the
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`attorneys of record for the Patent Owner:
`
`Peter F. Snell (Reg. No. 52,235)
`MINTZ, LEVIN, COHN, FERRIS,
`GLOVSKY AND POPEO, P.C.
`919 Third Avenue
`New York, New York 10022
`Tel.: (212) 692-6850
`Email: PFSnell@mintz.com
`
`
`Brian E. Farnan
`Michael J. Farnan
`Farnan LLP
`919 North Market Street, 12th Floor
`Wilmington, DE 19801
`Tel.: (302) 777-0300
`Email: bfarnan@farnanlaw.com
`Email: mfarnan@farnanlaw.com
`
`Adam Rizk (Reg. No. 66,867)
`Michael T. Renaud (Reg. No. 44,299)
`Serge Subach (Reg. No. 74,652)
`MINTZ, LEVIN, COHN, FERRIS,
`GLOVSKY AND POPEO, P.C.
`One Financial Center
`Tel.: (617) 348-4709
`Email: ARizk@mintz.com
`Email: MYRenaud@mintz.com
`Email: SSubach@mintz.com
`
`Deanna Tanner Okun
`AMS Trade LLP
`1133 Connecticut Avenue NW, Suite
`1200
`Washington, DC 20036
`Tel.: (202) 467-6300
`Email: okun@adduci.com
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`Date: June 2, 2023
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`Case IPR2023-00567
`U.S. Patent No. 10,049,080 B2
`
`
`Respectfully submitted,
`
`
`By: Ben Haber
`Benjamin Haber (Reg. No. 67,129)
`O’Melveny & Myers LLP
`400 South Hope Street, 18th Floor
`Los Angeles, CA 90071
`Telephone: (213) 430-6000
`Fax: (213) 430-6407
`E-Mail: bhaber@omm.com
`
`
`Counsel for Petitioner,
`Samsung Electronics Co., Ltd., and
`Samsung Electronics America, Inc.
`
`
`1
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`
`

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