`
`
`
`
`
`November 17, 2023
`
`VIA E-MAIL
`
`Russ August & Kabat
`12424 Wilshire Boulevard
`12th Floor
`Los Angeles, CA 90025
`Phone: 310-826-7474
`
`Parker Bunt & Ainsworth
`100 E Ferguson
`Suite 418
`Tyler, TX 75702
`Phone: 903-531-3535
`
`
`Fish & Richardson P.C.
`1180 Peachtree Street, NE
`21st Floor
`Atlanta, GA 30309
`
`404 892 5005 main
`404 892 5002 fax
`
`
`Thad C. Kodish
`Managing Principal
`TKodish@fr.com
`404 724 2792 direct
`
`Re:
`
`Headwater Research LLC v. Samsung Electronics Co., Ltd. et al., Case No. 2:23-cv-
`00103 (E.D. Tex.)
`
`
`Dear Counsel:
`
`Samsung Electronics Co., Ltd. (“Samsung”) has filed an inter partes review (IPR) petition
`(IPR2024-00010) with the Patent Trial and Appeal Board (PTAB) to address the validity of
`claims 1-9, 11-13, and 15 of U.S. Patent No. 9,615,192 (“the ’192 Patent”). The tables in
`attached Appendix A list all grounds, challenged claims, and references asserted in IPR2024-
`00010.
`
` I
`
` write to inform you that Samsung hereby stipulates that, if the PTAB institutes IPR2024-00010,
`Samsung agrees not to pursue the same grounds (listed in Appendix A below) in the district court
`litigation. Apple, Inc. v. SEVEN Networks, LLC, IPR2020-00156, Paper 10 at 19 (PTAB June
`15, 2020); see Sand Revolution II, LLC v. Continental Intermodal Group-Trucking LLC,
`IPR2019-01393, Paper 24 at 12 (PTAB June 16, 2020).
`
`
`
`Sincerely,
`
`
`
`
`
`Thad Kodish
`
`Attorney for Samsung Electronics Co., Ltd.
`
`
`
`
`
`
`
`SAMSUNG 1023
`
`1
`
`
`
`
`
`
`
`
`November 17, 2023
`Page 2
`
`
`Appendix A – Grounds and Prior Art References Used in IPR2024-00010
`
`
`Ground
`
`Claim(s)
`
`35 U.S.C. §103
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`1, 5-7, 9, 11-13, 15
`
`TS-23.140
`
`2-3
`
`4
`
`8
`
`TS-23.140 and Shen
`
`TS-23.140 and Ellison
`
`TS-23.140 and Rakic
`
`1, 5-7, 9, 11-13, 15
`
`Houghton and Munson
`
`2-3
`
`4
`
`8
`
`Houghton, Munson, and Shen
`
`Houghton, Munson, and Ellison
`
`Houghton, Munson, and Rakic
`
`
`
`List of References
`
`
`Reference Name Details
`
`TS-23.140
`
`Shen
`
`Ellison
`
`Rakic
`
`3GPP TS 23.140 v6.9.0 (2005-03); 3rd Generation Partnership Project;
`Technical Specification Group Terminals; Multimedia Messaging
`Service (MMS); Functional Description; Stage 2
`
`U.S. Patent Pub. No. 2005/0207379
`
`U.S. Patent No. 7,082,615
`
`U.S. Patent Pub. No. 2009/0282256
`
`Munson
`
`U.S. Patent Publication No. 2009/0240807
`
`Houghton
`
`International Patent Publication. No. WO 2006/077283 Al
`
`
`
`
`
`
`
`2
`
`
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