`Case 1:14—cv—OO598—LPS Document 9-8 Filed 06/13/14 Page 1 of 3 Page|D #: 347
`
`EX HIBIT H
`
`EXHIBIT H
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`
`
`Case 1:14-cv-00598-LPS Document 9-8 Filed 06/13/14 Page 2 of 3 PageID #: 348
`
`John Yim <jyim@yimassociates.com>
`To: Christopher V. Goodpastor
`Settlement Purposes Only - (IRON DOME LLC V. E-WATCH, INC. Inter
`Partes Review) IPR2014-00439
`
`April 29, 2014 9:55 AM
`
`Chris:
`Further to our teleconference, where you expressed your client’s desire to
`settle this matter, here is our offer for settlement.
`Initial payment of $428,000 for withdrawing the IPR.
`
`Plus:
`
`First scheduled payment upon the first settlement with a first
`defendant;
`Second scheduled payment upon the second settlement with a
`second defendant;
`Third scheduled payment upon the third settlement with a third
`defendant;
`Fourth scheduled payment upon the fourth settlement with a fourth
`defendant; and
`Fifth scheduled payment upon the fifth settlement with a fifth
`defendant.
`
`Each of the scheduled payments being in the amount of $223,000
`if the settling defendant is Samsung or Apple; or $175,000 if any
`other defendant.
`
`Please contact us after review.
`
`John Yim
`
`John J. Yim & Associates, LLC
`7600 Leesburg Pike, Suite 470 East Bldg.
`
`1
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`E-Watch, Inc
`E-Watch, Inc
`Exhibit 2011
`Exhibit 2012
`Petitioner - Iron Dome LLC
`Petitioner - Iron Dome LLC
`Patent Owner - E-Watch Inc
`Patent Owner - E-Watch Inc
`IPR2014-00439
`IPR2014-00439
`
`
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`Case 1:14-cv-00598-LPS Document 9-8 Filed 06/13/14 Page 3 of 3 PageID #: 349
`
`Falls Church (Tysons Corner), VA 22043
`(703)749-0500 (Tel)
`(202)379-1723 (Fax)
`
`FOR SETTLEMENT PURPOSES ONLY
`
`2