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Case 6:20-cv-00272-ADA Document 104 Filed 11/15/23 Page 1 of 3
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`CIV. ACTION NO. 6:20-cv-00272-ADA
`
`
`
`
`
`
`VOIP-PAL.COM, INC.
`
`Plaintiff,
`
`v.
`
`AMAZON.COM, INC.;
`AMAZON.COM SERVICES, LLC; and
`AMAZON.COM WEB SERVICES, INC.;
`
`Defendants.
`
`
`NOTICE OF SUPPLEMENTAL FACTS IN SUPPORT OF VOIP-PAL.COM’S OPPOSITION
`TO DEFENDANTS’ MOTION TO STAY PENDING THE OUTCOME OF EX PARTE
`REEXAMINATION REJECTING ALL ASSERTED CLAIMS
`
`VoIP-Pal submits this notice to inform the Court of supplemental facts supporting its
`
`
`
`Opposition To Defendants’ Motion To Stay Pending The Outcome Of Ex Parte Reexamination
`
`Rejecting All Asserted Claims (Dkt. No. 101). These facts were not available to VoIP-Pal at the time
`
`it filed its Opposition.
`
`
`
`As VoIP-Pal noted at the time of its Opposition, “[t]he USPTO has only issued a non-final
`
`office action, and [sic] VoIP-Pal still has an opportunity to respond. No final rejection has been
`
`issued, and there is no argument scheduled before the Board of Patent Appeals and Interferences.”
`
`Dkt. No. 101 at 1. VoIP-Pal submitted a response to the non-final office action on July 24, 2023 and
`
`a response to a Notification of a Defective Paper in Reexam on September 29, 2023. On November
`
`9, 2023, the USPTO issued a Notice of Intent to Issue an Ex Parte Reexamination Certificate
`
`confirming all of the challenged claims of U.S. Patent No. 10,218,606 (“’606 patent) as patentable.
`
`A copy of the Notice is attached as Exhibit 1. Because all of the challenged claims of the ’606 patent
`
`will remain valid and unchanged, the reexamination will not simplify any issues in this action.
`
`
`
`1
`
`

`

`Case 6:20-cv-00272-ADA Document 104 Filed 11/15/23 Page 2 of 3
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`
`
`Dated: November 15, 2023
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` By: /s/Lewis E. Hudnell, III
`Lewis E. Hudnell, III
`lewis@hudnelllaw.com
`Nicolas S. Gikkas
`nick@hudnelllaw.com
`Hudnell Law Group P.C.
`800 W. El Camino Real Suite 180
`Mountain View, California 94040
`T: 650.564.3698
`F: 347.772.3034
`
`Sean Franklin Parmenter
`sean@parmenterip.com
`Parmenter Intellectual Property Law, PLLC
`8980 N Pine Hollow Drive
`Cedar Hills, Utah 84062
`T: 925.482.6515
`
`ATTORNEYS FOR PLAINTIFF
`VOIP-PAL.COM, INC.
`
`2
`
`

`

`Case 6:20-cv-00272-ADA Document 104 Filed 11/15/23 Page 3 of 3
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that all counsel of record who are deemed to have consented to
`electronic service are being served with a copy of the forgoing NOTICE OF SUPPLEMENTAL
`FACTS IN SUPPORT OF VOIP-PAL.COM’S OPPOSITION TO DEFENDANTS’ MOTION TO
`STAY PENDING THE OUTCOME OF EX PARTE REEXAMINATION REJECTING ALL
`ASSERTED CLAIMS via the Court’s CM/ECF system pursuant to the Federal Rules of Civil
`Procedure and Local Rule CV-5(b)(1) this 15th day of November, 2023.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By: /s/Lewis E. Hudnell, III
`Lewis E. Hudnell, III
`Hudnell Law Group P.C.
`800 W. El Camino Real Suite 180
`Mountain View, California 94040
`T: 650.564.3698
`F: 347.772.3034
`lewis@hudnelllaw.com
`
`3
`
`

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