`Direct Dial: 650.463.2633
`doug.lumish@lw.com
`
`October 8, 2020
`
`VIA EMAIL
`
`Philip X. Wang
`Russ August & Kabat
`12424 Wilshire Boulevard
`Twelfth Floor
`Los Angeles, California 90025
`pwang@raklaw.com
`
`140 Scott Drive
`Menlo Park, California 94025
`Tel: +1.650.328.4600 Fax: +1.650.463.2600
`www.lw.com
`
`FIRM / AFFILIATE OFFICES
`Moscow
`Beijing
`Boston
`Munich
`Brussels
`New York
`Century City
`Orange County
`Chicago
`Paris
`Riyadh
`Dubai
`Düsseldorf
`San Diego
`Frankfurt
`San Francisco
`Hamburg
`Seoul
`Hong Kong
`Shanghai
`Silicon Valley
`Houston
`London
`Singapore
`Los Angeles
`Tokyo
`Washington, D.C.
`Madrid
`Milan
`
`Re:
`
`Solas OLED Ltd. v. LG Display Co., Ltd., LG Electronics, Inc., & Sony
`Corporation, Case No. 6:19-cv-00236-ADA
`
`Dear Philip:
`
`Defendants LG Display Co., Ltd., LG Electronics, Inc., & Sony Corporation hereby
`stipulate that, if the Patent Trial and Appeal Board (“PTAB”) institutes the pending inter partes
`review petition in IPR2020-01055 challenging the patentability of claims 1, 9, 10, 11, 15, 36, 37,
`and 39 of U.S. Patent Number 7,907,137, then Defendants will not pursue the instituted
`invalidity grounds in the above-captioned litigation, 6:19-cv-00236.
`• For convenient reference, the proposed invalidity grounds in IPR2020-01055 are:
`Claims 1, 10, 11, 36 and 37 are unpatentable under 35 U.S.C. § 103 over
`Miyazawa (U.S. Appl. Publ. No. 2005/0116902), alone or with Childs (Int’l Pat.
`Publ. No. WO 2005/069267).
`• Claims 9, 15 and 39 are unpatentable under 35 U.S.C. § 103 over Miyazawa,
`alone or with Childs, and Kasai (U.S. Appl. Pub. No. 2005/0156837).
`
`To avoid any doubt, if the PTAB declines institution of IPR2020-01055, Defendants
`reserve the right to pursue these invalidity grounds in the parallel litigation.
`
`Best Regards,
`
`/s/ Douglas E. Lumish
`
`Douglas E. Lumish
`of LATHAM & WATKINS LLP
`
`LG Display Co., Ltd.
`Exhibit 1021
`LG Display v. Solas
`IPR2020-01055
`
`Ex. 1021-001
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
