`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`SPORTSCASTR INC.
`(d/b/a PANDA INTERACTIVE),
`
`Plaintiff,
`
`v.
`GENIUS SPORTS LTD.,
`
`Defendant.
`
`Civil Action No. 2:23-cv-471-JRG
`
`GENIUS SPORTS’ STIPULATION RE INTER PARTES REVIEW
`On [Date], the Patent Trial and Appeal Board instituted inter partes review
`
`(“IPR”) of U.S. Patent No[s]. _______. Defendant Genius Sports hereby stipulates
`
`that, from and after the date of this stipulation, it will not pursue a defense in this
`
`Action that the aforementioned asserted patent[s] [is/are] invalid based on grounds
`
`that were raised or reasonably could have been raised in Defendant’s IPR petitions.
`
`1
`
`Genius Sports Ex. 1021
`p. 1
`
`
`
`Dated:__________________
`
` _______________________
`Jeanne M. Heffernan
`James John Lomeo
`KIRKLAND & ELLIS LLP
`401 Congress Avenue
`Austin, TX 78701
`(512) 678-9100
`jheffernan@kirkland.com
`james.lomeo@kirkland.com
`
`Joshua L. Simmons (admitted pro hac vice)
`KIRKLAND & ELLIS LLP
`601 Lexington Avenue
`New York, NY 10022
`(212) 446-4800
`joshua.simmons@kirkland.com
`
`Patrick Arnett (admitted pro hac vice)
`KIRKLAND & ELLIS LLP
`1301 Pennsylvania Avenue, N.W.
`Washington, D.C. 20004
`(202) 389-5000
`patrick.arnett@kirkland.com
`
`Attorneys for Defendant Genius Sports Ltd.
`
`2
`
`Genius Sports Ex. 1021
`p. 2
`
`
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