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Case 6:20-cv-00272-ADA Document 121 Filed 07/31/24 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.
`
`
`SECOND 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 second 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
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`it filed its Opposition.
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`
`
`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. On December 15, 2023, the USPTO issued 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 Reexamination Certificate is attached as Exhibit 1. Because all of the challenged
`
`claims of the ’606 patent remain valid and unchanged and the reexamination has concluded, the
`
`reexamination will not simplify any issues in this action.
`
`
`
`1
`
`

`

`Case 6:20-cv-00272-ADA Document 121 Filed 07/31/24 Page 2 of 3
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`
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`Dated: July 31, 2024
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`
`
`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
`
`Mark D. Siegmund
`msiegmund@cjsjlaw.com
`Cherry Johnson Siegmund James, PLLC
`The Roosevelt Tower
`400 Austin Ave
`9th Floor, Suite 903
`Waco, TX 76701
`T: (254) 732-2242
`
`
`ATTORNEYS FOR PLAINTIFF
`VOIP-PAL.COM, INC.
`
`2
`
`

`

`Case 6:20-cv-00272-ADA Document 121 Filed 07/31/24 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 SECOND 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 31st day of July,
`2024.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`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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