`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`AFactor@susmangodfrey.com
`Monday, September 30, 2024 4:46 PM
`Claire Chang; External Service - Haptic Counsel
`Service - FR Apple/Haptic
`RE: Haptic, Inc. v. Apple Inc. - IPR Petitions
`
`[This email originated outside of F&R.]
`
`Claire,
`
`Haptic does not agree to Apple’s proposal. Thanks and happy to discuss.
`
`Ace Factor | Susman Godfrey LLP
`713.653.7826 | c. 817.602.1210
`1000 Louisiana St. | Suite 5100 | Houston, Texas 77002
`HOUSTON • NEW YORK • LOS ANGELES • SEATTLE
`afactor@susmangodfrey.com
`
`From: Claire Chang <cchang@fr.com>
`Sent: Wednesday, September 25, 2024 3:29 PM
`To: External Service - Haptic Counsel <ExternalServiceHapticCounsel@fr.com>; Ace Factor
`<AFactor@susmangodfrey.com>
`Cc: Service - FR Apple/Haptic <ServiceFRAppleHaptic@fr.com>
`Subject: Haptic, Inc. v. Apple Inc. - IPR Petitions
`
`EXTERNAL Email
`
`Counsel,
`
`Apple will soon be filing one or more IPR petitions to invalidate claims of the ’738 patent. Before doing so and to
`potentially streamline issues in the IPR process, please let us know if Haptic will covenant not to sue all Apple entities,
`upstream suppliers, etc., and downstream distributors, customers, etc., for any Apple product, including the accused
`products included in Haptic’s May 30 Infringement Contentions, for any claims of the ’738 patent not asserted in your
`May 30 Infringement Contentions (i.e., all claims other than claims 1, 2, 4, 5 and 9). Please let us know your response by
`September 27, 2024.
`
`Please let us know if you have any questions or want to discuss.
`
`Thanks,
`Claire
`
`Claire Chang
`Associate ■ Fish & Richardson P.C.
`
`T: 650 839 5039 | cchang@fr.com
`
`APPLE 1109
`
`1
`
`
`
`***************************************************************************************************
`*************************
`This email message is for the sole use of the intended recipient(s) and may contain confidential
`and privileged information. Any unauthorized use or disclosure is prohibited. If you are not the
`intended recipient, please contact the sender by reply email and destroy all copies of the original
`message.
`***************************************************************************************************
`*************************
`
`2
`
`
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