`________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`AMAZON.COM, INC.,
`Petitioner,
`
`v.
`
`DYNAPASS IP HOLDINGS LLC,
`Patent Owner.
`________________
`Case No. IPR2024-00283
`Patent 6,993,658
`________________
`
`JOINT MOTION TO TERMINATE
`
`
`
`Joint Motion to Terminate
`IPR2024-00283
`
`As authorized by the Board in an email sent on June 21, 2024 (see Ex.
`
`1015), pursuant to 37 C.F.R. §§ 42.71 and 42.74, Petitioner and Patent Owner
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`jointly request termination of the proceeding related to the petition for inter
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`partes review of U.S. Patent No. 6,993,658 (Case. No. IPR2024-00283).
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`The parties have settled their dispute and executed a settlement
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`agreement to terminate this proceeding.
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`The parties’ settlement agreement is in writing, and a true and correct
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`copy is being filed under 37 C.F.R. § 42.74(b). The parties hereby represent
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`that there are no other agreements, oral or written, between the parties made in
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`connection with, or in contemplation of, the termination of this proceeding.
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`The parties are also concurrently filing a joint request to treat the
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`settlement agreement as business confidential information and keep it separate
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`from the files of this proceeding and the involved patent under 35 U.S.C. §
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`317(b) and 37 C.F.R. § 42.74(c).
`
`Dismissal of this proceeding under 35 U.S.C. § 317(a) and 37 C.F.R. §
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`42.71(a) is proper because the Board has yet to issue an institution decision,
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`1
`
`
`
`Joint Motion to Terminate
`IPR2024-00283
`and these proceedings are still at an early stage. See Samsung Elecs. Co. v.
`
`Fundamental Innovation Sys. Int’l, Ltd., IPR2018-00605 (PTAB July 16,
`
`2018) (Paper No. 10).
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`Accordingly, the parties respectfully request termination of this
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`proceeding.
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`DATED this 26th day of June, 2024.
`
`Respectfully submitted,
`
` / Alexander B. Stein /
`Alexander B Stein, Reg. No. 71,397
`Ahren C. Hsu-Hoffman, Reg. No. 50,862
`Austin L. Zuck, Reg. No. 81,341
`Morgan, Lewis & Bockius LLP
`1400 Page Mill Road
`Palo Alto, CA, 94304
`
`Attorneys for Petitioner, Amazon.com, Inc.
`
` / John Wittenzellner /
`John Wittenzellner, Reg. No. 61,662
`Williams Simons & Landis PLLC
`1735 Market Street, Suite 125, #453
`Philadelphia, PA 19103
`
`Michael J. Fagan Jr., Reg. No. 71,654
`Williams Simons & Landis PLLC
`2633 McKinney Ave., Suite 130
`Dallas, TX 75204
`
`Mark McCarthy, Reg. No. 69,575
`Williams Simons & Landis PLLC
`The Littlefield Building
`601 Congress Ave., Suite 600
`Austin, TX 78701
`
`Counsel for Patent Owner, Dynapass IP
`Holdings LLC
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`2
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`
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`Joint Motion to Terminate
`IPR2024-00283
`
`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), it is hereby certified that on June 26, 2024, a
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`copy of this JOINT MOTION TO TERMINATE was sent via email to Patent
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`Owner’s counsel of record:
`
`John Wittenzellner
`(johnw@wsltrial.com)
`Michael J. Fagan, Jr.
`(mfagan@wsltrial.com)
`Mark McCarthy
`(mmccarthy@wsltrial.com)
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`Dated: June 26, 2024
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`Respectfully Submitted,
`
` / Marilyn Doris /
`Marilyn Doris
`Legal Secretary at Morgan, Lewis &
`Bockius LLP
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`3
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