`
`110 NORTH WACKERDRIVE * SUITE 4800 * CHICAGO, ILLINOIS 60606
`
`TELEPHONE: +1.312.782.3939 * JONESDAY.COM
`
`DIRECT NUMBER: +1.312.269.4369
`MSBLACKMAN@JONESDAY.COM
`
`August 29, 2024
`
`Re:=Optimum Imaging Techs. LLC v. Olympus Corp., et al., Civ. No. 4-23-cv-
`00924 (E.D. Tex.); Optimum Imaging Techs. LLC v. Nikon Corp., Case No. 4-
`23-cv-00923 (E.D. Tex.); Optimum Imaging Techs. LLC v. Panasonic Corp.,
`et al., Case No. 4-23-cv-00926 (E.D. Tex.); Optimum Imaging Technologies
`LLC v. FUJIFILM Corporation, Case No. 4-23-cv-00922 (E.D. Tex.)
`
`Wewrite regarding the above-captionedlitigations (the “District Court Cases”), and the
`related petition for infer partes review (IPR) in IPR2024-01372 that was filed today against
`certain claims of U.S. Patent No. 8,451,339.
`
`Petitioners Olympus Corporation (“Olympus”), OM Digital Solutions Corporation
`(““OMDS”), FUJIFILM Corporation, FUJIFILM North America Corporation (collectively
`“FUJIFILM”), Nikon Corporation (“Nikon”), and Panasonic Entertaiment & Communication
`Co., Ltd. (“Panasonic”) (collectively “Petitioners”) hereby stipulate that if the Patent Trial and
`Appeal Board (PTAB) institutes an IPR based on the grounds identified below, then each party
`respectively will (i) not pursue the grounds identified below in the respective District Court Case,
`and (11) not pursue any other ground that reasonably could have been raised during the IPR in the
`respective District Court Case.
`
`The grounds presented in the IPR petition are reproduced below for convenience:
`
`
`
`
`
`Ground Statutory Basis|Claims Challenged from U.S.Prior Art
`Patent No. 8,451,339
`
`
`
`=|(a)|Nikawa § 103 1,3,and5
`
`103s
`
`
`
`Matsutani + Shiomi
`
`§ 103
`
`4 and 16
`
` ~ Niikawa +Enomoto + Ito § 103 4 and 16
`
`
`
`1-2, 14-15 and 17
`
`Matsutani + Shiomi +
`
`§ 103
`
`3, 5 and 18
`
`>] Masten!+Shionheil|5|Matsutani +|Matsutani+
`
`Shiomi+Ito|+ Ito § 103
`
`AMSTERDAM + ATLANTA «+ BEIJING * BOSTON + BRISBANE * BRUSSELS + CHICAGO + CLEVELAND + COLUMBUS + DALLAS
`DETROIT + DUBAI
`+ DUSSELDORF * FRANKFURT * HONGKONG + HOUSTON »*
`IRVINE * LONDON + LOSANGELES + MADRID
`MELBOURNE + MEXICO CITY *= MIAMI
`* MILAN © MINNEAPOLIS = MUNICH © NEWYORK «+ PARIS * PERTH «+ PITTSBURGH
`SAN DIEGO * SAN FRANCISCO + SAO PAULO + SHANGHAI « SILICON VALLEY * SINGAPORE * SYDNEY ° TAIPEI * TOKYO + WASHINGTON
`
`Page 1
`
`
`
`
`August 29, 2024
`Page 2
`
`
`
`
`
`
`
`
`
`
`
`Sincerely,
`
`/s/ Marc S. Blackman
`
`Marc S. Blackman for Nikon
`
`/s/ Alexander B. Stein
`Alexander B. Stein for Olympus and OMDS
`
`/s/ T. Vann Pearce
`T. Vann Pearce for FUJIFILM
`
`/s/ Joseph M. Casino
`Joseph M. Casino for Panasonic
`
`
`PETITIONERS EX1024
`Page 2
`
`
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