`Plaintiff,
`
`v.
`ALTICE USA, INC., et al.,
`
`Defendants.
`TOUCHSTREAM TECHNOLOGIES, INC.,
`Plaintiff,
`
`Lead Case No. 2:23-cv-00060-JRG
`Member Case No. 2:23-cv-00059-JRG
`Member Case No. 2:23-cv-00062-JRG
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`v.
`CHARTER COMMUNICATIONS, INC. et
`al.,
`
`Defendants.
`
`TOUCHSTREAM TECHNOLOGIES, INC.,
`Plaintiff,
`
`v.
`COMCAST CABLE COMMUNICATIONS,
`LLC, d/b/a XFINITY, et al.,
`
`Defendants.
`
`COMCAST DEFENDANTS’ STIPULATION REGARDING INVALIDITY DEFENSES
`
`On December 27, 2023, Defendants Comcast Cable Communications, LLC, d/b/a
`
`Xfinity; Comcast Cable Communications Management, LLC; and Comcast of Houston, LLC,
`
`(collectively “Comcast Defendants”), filed petition nos. IPR2024-00321, IPR2024-00322,
`
`IPR2024-00323, IPR2024-00324, IPR2024-00325, and IPR2024-00326 with the Patent Trial and
`
`Appeal Board, requesting inter partes review of U.S. Patent Nos. 8,356,251, 11,048,751, and
`
`11,086,934.
`
`The Comcast Defendants hereby stipulate that if the Patent Trial and Appeal Board
`
`institutes inter partes review (that are not reconsidered, withdrawn or otherwise terminated so as
`
`to prevent a final written decision from being issued) on U.S. Patent Nos. 8,356,251, 11,048,751,
`
`1
`
`Comcast, Ex. 1182
`
`
`
`and/or 11,086,934, pursuant to the Comcast Defendants’ petitions for IPR, then the Comcast
`
`Defendants will not pursue in this case the specific grounds against the instituted patent(s) as set
`
`forth in the respective instituted inter partes review petition(s).
`
`
`
`2
`
`
`
`Dated:
`
`
`
`
`
`COUNSEL FOR COMCAST DEFENDANTS,
`
`/s/ Draft
`Deron Dacus (State Bar No. 00790553)
`THE DACUS FIRM, P.C.
`821 ESE Loop 323, Suite 430
`Tyler, TX 75701
`Tel: (903) 705-1117
`Fax: (903) 581-2543
`ddacus@dacusfirm.com
`
`Ashok Ramani (CA Bar No. 200020)
`David J. Lisson (CA Bar No. 250994)
`James Y. Park (CA Bar No. 343659)
`Micayla Hardisty (CA Bar No. 333246)
`DAVIS POLK & WARDWELL LLP
`1600 El Camino Real
`Menlo Park, CA 94025
`ashok.ramani@davispolk.com
`david.lisson@davispolk.com
`james.park@davispolk.com
`micayla.hardisty@davispolk.com
`
`Alena Farber (NY Bar No. 5896170)
`DAVIS POLK & WARDWELL LLP
`450 Lexington Avenue
`New York, NY 10017
`alena.farber@davispolk.com
`
`
`3
`
`
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