`SPiepmeier@perkinscoie.com
`D. +1.415.344.7150
`F. +1.415.344.7350
`
`January 11, 2024
`
`VIA EMAIL
`
`Kevin C. Wheeler
`LATHAM & WATKINS LLP
`555 Eleventh Street, NW, Suite 1000
`Washington DC 20004
`kevin.wheeler@lw.com
`
`Re: AX Wireless v. Dell Inc., et al., Case No. 22-cv-00277-RWS-RSP (E.D. Tex.)
`
`Dear Counsel:
`
`Dell Technologies and Dell Inc. (collectively “Dell”) hereby stipulate, consistent with the
`stipulation made by the Petitioner in Sotera Wireless Inc. v. Masimo Corp., IPR2020-01019, that if the
`Patent Trial and Appeal Board (“PTAB”) institutes an inter partes review (“IPR”) in response to Intel’s
`petition against AX Wireless, U.S. Patent No. 9,584,262 (IPR2023-01143), then Dell will not pursue
`in this litigation the grounds raised or any other grounds that could have reasonably been raised before
`the PTAB in that instituted proceeding.
`
`Sincerely,
`
`Sarah E. Piepmeier
`
`DELL-1041
`10,079,707
`
`
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