Case 2:15-cv-01274-JRG-RSP Document 142-3 Filed 09/01/16 Page 1 of 7 PageID #: 4466
`Case 2:15-cv—01274-JRG-RSP Document 142-3 Filed 09/01/16 Page 1 of 7 PagelD #: 4466
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`EXHIBIT B
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`EXHIBIT B
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`Case 2:15-cv—01274-JRG-RSP Document 142-3 Filed 09/01/16 Page 1 of 7 PagelD #: 4466
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`EXHIBIT B
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`EXHIBIT B
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`Case 2:15-cv-01274-JRG-RSP Document 142-3 Filed 09/01/16 Page 2 of 7 PageID #: 4467
`IPR2016-00118
`Patent 8,155,342
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`UNIFIED PATENTS INC.
`Petitioner
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`v.
`BLITZSAFE TEXAS, LLC
`Patent Owner
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`IPR2016-00118
`Patent 8,155,342
`Multimedia Device Integration System
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`PROPOSED STIPULATION
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`Case 2:15-cv-01274-JRG-RSP Document 142-3 Filed 09/01/16 Page 3 of 7 PageID #: 4468
`IPR2016-00118
`Patent 8,155,342
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`Unified Patents Inc. (“Unified”) proffers this Proposed Stipulation, as
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`suggested by the Board, to obviate the need to make reference to and thus the need
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`to include and redact otherwise confidential produced exhibits. See Order,
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`Conduct of the Proceeding, Unified Patents Inc. v. Blitzsafe Texas LLC, IPR2016-
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`00118, Paper 16 (PTAB Mar. 15, 2016). As noted, Unified has agreed that the
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`patent owner’s preliminary response no longer needs to be redacted.1 Unified,
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`having previously proffered this stipulation to Patent Owner, proposes to stipulate
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`to the following:
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`1. Unified has produced 27 membership agreements, one for each of the
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`members of the Automotive Zone as of the date of filing.
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`2. Unified has produced the 23 agreements for Pledge members (see
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`http://unifiedpatents.com/#membership) in the Automotive Zone as of the
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`date of filing; Pledge members receive membership without paying fees and
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`compensate Unified by, among other things, agreeing to give Unified notice
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`rights and license rights to their patent portfolios.
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`1 Unified regrets the inconvenience, noting that at the time the response was filed,
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`the identities of two members were confidential. Those entities have since
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`consented to become public members, and so there is no longer any need to redact
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`any portion of the response.
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`2
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`Case 2:15-cv-01274-JRG-RSP Document 142-3 Filed 09/01/16 Page 4 of 7 PageID #: 4469
`IPR2016-00118
`Patent 8,155,342
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`3. Unified has produced the 4 agreements for Enterprise members (see
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`http://unifiedpatents.com/#membership) in the Automotive Zone signed as
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`of the date of filing; Toyota Motor Corporation, Honda Patents &
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`Technologies North America LLC, Nissan Motor Co., Ltd., and DENSO
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`Corporation are the only members to have paid subscription fees to the
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`Automotive Zone as of the date of filing.
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`4. Unified is funding IPR2016-00118 from the Automotive Zone.
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`5. No subscription fees paid by a member with respect to one zone are used by
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`Unified for other zones. If a patent involves more than one zone, any
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`acquisition, licensing, or other costs (including any sale proceeds) for that
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`patent are equally allocated amongst the zones.
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`6. Unified seeks to reduce NPE litigation in each zone by, for example:
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`acquiring rights necessary to grant members licenses, sublicenses, releases,
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`and other rights; acquiring rights necessary to participate in bids or auctions,
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`or otherwise to participate in acquisition, with respect to the sale of patents
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`(including acquiring rights-of-first-offer or rights-of-first-refusal for patents
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`in a zone from small businesses in exchange for reduced or free
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`membership); filing and conducting reexaminations and review proceedings
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`on patents in a zone before the U.S. Patent and Trademark Office;
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`conducting prior art searches for patents in the zone; providing members
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`3
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`Case 2:15-cv-01274-JRG-RSP Document 142-3 Filed 09/01/16 Page 5 of 7 PageID #: 4470
`IPR2016-00118
`Patent 8,155,342
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`with opinions of counsel regarding the patentability of patents in the zone;
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`providing members and other parties in the zone with information relating to
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`non-practicing entity (NPE) business practices, NPE litigation trends, NPE
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`market data and statistics, and other information with respect to NPEs;
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`participating in legislative and judicial reform initiatives on patent law
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`(including, but not limited to, filing or joining amicus briefs and/or
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`providing data to governmental agencies and/or legislators); and providing
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`additional related services.
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`7. For each zone, among other things, Unified: analyzes issued patents and
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`published applications
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`in each zone; monitors patents, published
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`applications, assignment records, and patent owners in each zone for NPE
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`activity; monitors patent owners in each zone for performance and other
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`market data; provides members with an annual report on the NPE activity in
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`their zones, including information derived from Unified’s activities; and
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`performs other additional services.
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`8. Unified provides members with an annual report that includes the following
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`information: a list of all licensed patents and rights acquired; the amount
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`spent for the assets and rights acquired, the date of each acquisition, and the
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`identity of sellers; a list of all proceedings and the amount spent for each
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`proceeding; estimated administrative and other costs; and a list of all zone
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`4
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`Case 2:15-cv-01274-JRG-RSP Document 142-3 Filed 09/01/16 Page 6 of 7 PageID #: 4471
`IPR2016-00118
`Patent 8,155,342
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`patents sold, the amount received for each, the date of the sales, and the
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`identity of the purchasers.
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`Dated: March 15, 2016
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`Respectfully submitted,
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`By:
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`/Paul C. Haughey/
`Paul C. Haughey
`Registration No. 31,836
`Lead Counsel for Petitioners
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`5
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`Case 2:15-cv-01274-JRG-RSP Document 142-3 Filed 09/01/16 Page 7 of 7 PageID #: 4472
`IPR2016-00118
`Patent 8,155,342
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies
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`that
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`the
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`foregoing PROPOSED
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`STIPULATION is being served on March 15, 2016, by e-mail at the following
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`agreed address for service:
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`Peter Lambrianakos (Reg. No. 58,279)
`Brown Rudnick LLP
`7 Times Square
`New York, NY 10036
`plambrianakos@brownrudnick.com
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`By: /Paul C. Haughey/
`Paul C. Haughey
`Registration No. 31,836
`Counsel for Petitioner
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`
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`6
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`Dated: March 15, 2016
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`
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