`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`§
`
`§
`Case No. 6:21-cv-00984-ADA
`§
`
`JURY TRIAL DEMANDED
`§
`§
`
`§
`§
`§
`§
`§
`§
`
`
`
`
`v.
`
`
`APPLE INC.,
`
`
`Defendant.
`
`
`
`Case 6:21-cv-00984-ADA Document 110 Filed 12/23/22 Page 1 of 4
`
`
`JAWBONE INNOVATIONS, LLC,
`
`
`Plaintiff,
`
`
`JOINT MOTION TO DISMISS
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`Pursuant to Fed. R. Civ. P. 41(a)(2), Plaintiff Jawbone Innovations, LLC (“Jawbone” or
`
`“Plaintiff”) and Defendant Apple Inc. (“Apple” or “Defendant”) (collectively, the “Parties”),
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`represented by their attorneys, hereby stipulate and agree as follows:
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`The Parties have settled their respective claims for relief asserted in this litigation.
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`Accordingly, the Parties respectfully request that all claims for relief asserted against Apple by
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`Jawbone are dismissed with prejudice, and the Parties further request that all attorneys’ fees, costs
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`of court, and expenses be borne by each Party incurring the same.
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`So agreed and stipulated.
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`A proposed order is attached.
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`Dated: December 23, 2022
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`
`
`
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`Respectfully submitted,
`
` /s/ Peter Lambrianakos
`Raymond W. Mort, III
`Texas State Bar No. 00791308
`Email: raymort@austinlaw.com
`THE MORT LAW FIRM, PLLC
`100 Congress Avenue, Suite 2000
`Austin, Texas 78701
`Tel/Fax: 512-865-7950
`
`
`
`Case 6:21-cv-00984-ADA Document 110 Filed 12/23/22 Page 2 of 4
`
`
`OF COUNSEL:
`
`Alfred R. Fabricant (Pro Hac Vice to be filed)
`NY Bar No. 2219392
`Email: ffabricant@fabricantllp.com
`Peter Lambrianakos (Admitted Pro Hac Vice)
`NY Bar No. 2894392
`Email: plambrianakos@fabricantllp.com
`Vincent J. Rubino, III (Pro Hac Vice to be filed)
`NY Bar No. 4557435
`Email: vrubino@fabricantllp.com
`Richard M. Cowell (Admitted Pro Hac Vice)
`NY Bar No. 4617759
`Email: rcowell@fabricantllp.com
`FABRICANT LLP
`411 Theodore Fremd Avenue, Suite 206 South
`Rye, New York 10580
`Telephone: (212) 257-5797
`Facsimile: (212) 257-5796
`
`ATTORNEYS FOR PLAINTIFF
`JAWBONE INNOVATIONS, LLC
`
`
`
`
` /s/ Ricardo J. Bonilla (with permission)
`J. Stephen Ravel Texas
`State Bar No. 16584975
`KELLY HART & HALLMAN LLP
`303 Colorado, Suite 2000
`Austin, Texas 78701
`Tel: (512) 495-6429
`Email: steve.ravel@kellyhart.com
`
`Ricardo J. Bonilla
`Texas Bar No. 24082704
`rbonilla@fr.com
`FISH & RICHARDSON P.C.
`1717 Main Street, Suite 5000
`Dallas, Texas 75201
`(214) 747-5070 – Telephone
`(214) 747-2091 – Facsimile
`
`
`
`
`
`2
`
`
`
`Case 6:21-cv-00984-ADA Document 110 Filed 12/23/22 Page 3 of 4
`
`Benjamin C. Elacqua
`Texas Bar No. 24055443
`elacqua@fr.com
`FISH & RICHARDSON P.C.
`1221 McKinney Street, Suite 2800
`Houston, Texas 77010
`(713) 654-5300 – Telephone
`(713) 652-0109 – Facsimile
`
`Betty H. Chen
`Texas Bar No. 24056720
`bchen@fr.com
`FISH & RICHARDSON P.C.
`500 Arguello Street, Suite 500
`Redwood City, CA 94063
`(650) 839-5067 – Telephone
`(650) 839-5071 - Facsimile
`
`ATTORNEYS FOR DEFENDANT
`APPLE INC.
`
`3
`
`
`
`Case 6:21-cv-00984-ADA Document 110 Filed 12/23/22 Page 4 of 4
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`CERTIFICATE OF SERVICE
`
`I hereby certify that on December 23, 2022, I electronically filed the foregoing with the
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`Clerk of Court using the CM/ECF system, which will send notification of such filing via electronic
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`mail to all counsel of record.
`
`
`
`/s/ Peter Lambrianakos
` Peter Lambrianakos
`
`
`
`
`
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