`Case 1:17-cv-00585-CFC-SRF Document 153 Filed 10/30/18 Page 1 of 3 PageID #: 5093
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`CA. No. 17-585 (CFC) (SRF)
`
`) ) ) ) ) ) ) ) ) )
`
`UNIVERSAL SECURE REGISTRY LLC,
`
`Plaintiff,
`
`v.
`
`APPLE INC., VISA INC. and
`VISA U.S.A., INC.,
`
`Defendants.
`
`STIPULATION ANDMER STAYING
`
`LITIGATION PENDING IPR AND CBM REVIEW PROCEEDINGS
`
`WHEREAS, Defendant Apple Inc. (“Apple”) has filed the following IPR and CBM
`
`Review petitions currently pending before the Patent Trial and Appeal Board: IPR2018-OO809;
`
`IPR2018-00810;
`
`IPR2018-00811;
`
`IPR2018-00812;
`
`IPR2018-00813;
`
`CBM2018-00024;
`
`CBM2018-00025; and CBM2018-00026;
`
`WHEREAS, Defendants Visa Inc., and Visa U.S.A., Inc. (with Visa Inc., “Visa”) have
`
`filed the following IPR petitions currently pending before the Patent Trial and Appeal Board:
`
`IPR2018-01350 and IPR2018-01351; and
`
`WHEREAS, The Patent Trial and Appeal Board has instituted IPR proceedings based on
`
`the following petitions to date: IPR2018-00809; lPR2018-00810; and IPR2018-00813;
`
`NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and among
`
`Plaintiff Universal Secure Registry LLC (“USR”), Apple, and Visa, and subject to the approval
`
`of the Court, as follows:
`
`1.
`
`This case is stayed until the Patent Trial and Appeal Board issues either a final
`
`written decision or a decision not to institute IPR or CBM Review on each of the following
`
`proceedings:
`
`lPR2018-00809;
`
`IPR2018-00810;
`
`IPR2018-0081 l;
`
`IPR2018-00812;
`
`IPR2018-
`
`
`
`Case 1:17-cv-00585-CFC-SRF Document 153 Filed 10/30/18 Page 2 of 3 PageID #: 5094
`Case 1:17-cv-00585-CFC-SRF Document 153 Filed 10/30/18 Page 2 of 3 PageID #: 5094
`
`00813;
`
`IPR2018-01350;
`
`IPR2018-01351; CBM2018-00024; CBM2018-00025; CBM2018-
`
`00026 (collectively, “the PTAB proceedings”). The stay extends until the last of the final written
`
`decisions or decisions not to institute IPR or CBM Review in the PTAB proceedings has issued.
`
`2.
`
`The parties reserve their right to seek modification of the stay for good cause.
`
`USR reserves its right to move the Court to lift the stay before all the PTAB proceedings are
`
`resolved, and Apple and Visa reserve their rights to move the Court to extend the stay until all
`
`appeals of final written decisions issued in the PTAB proceedings are resolved. All parties
`
`reserve their rights to oppose any request for modification of the stay.
`
`3.
`
`Upon entry of this stipulation, Visa agrees to be subject to the same estoppel as
`
`Apple on the IPR and CBM Review petitions listed above filed by Apple, and Apple agrees to be
`
`subject to the same estoppel as Visa on the IPR petitions listed above filed by Visa.
`
`4.
`
`All discovery shall be immediately stayed pending entry of this stipulation. The
`
`parties agree to take reasonable measures to preserve fact discovery up to and including lifting of
`
`the stay of litigation.
`
`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
`
`POTTER ANDERSON & CORROON LLP
`
`[51 Zeremy a. rigan
`Jack B. Blumenfeld (#1014)
`Jeremy A. Tigan (#5239)
`1201 North Market Street
`Wilmington, DE 19899-1347
`(302) 658-9200
`jblumenfeld@mnat.com
`jtigan@mnat.com
`
`Attorneysfor Universal Secure Registry LLC
`
`[.91 (Bindu fl. (Palapura
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Stephanie E. O’Byme (#4446)
`Hercules Plaza, 6th Floor
`1313 North Market Street
`Wilmington, DE 19801
`(302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`sobyme@potteranderson.com
`
`Attorneys for Visa Inc. and Visa USA, Inc.
`
`
`
`Case 1:17-cv-00585-CFC-SRF Document 153 Filed 10/30/18 Page 3 of 3 PageID #: 5095
`Case 1:17-cv-00585-CFC-SRF Document 153 Filed 10/30/18 Page 3 of 3 PageID #: 5095
`
`RICHARDS, LAYTON & FINGER, PA.
`
`[51 Zason Z. fiawnsfey
`Frederick L. Cottrell, III (#2555)
`Jason J. Rawnsley (#5379)
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`cottrell@rlf.com
`rawnsley@rlf.com
`
`Attorneysfor Apple Inc.
`
`October 26, 2018
`
`so ORDERED thisfiflaay ode'dtu- , 2018.
`
`UNITED STATESfiJUDGE
`
`DIST/“‘7'
`
`
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