`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`UNIVERSAL SECURE REGISTRY LLC,
`
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`Plaintiff,
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`
`
`
`
`APPLE INC., VISA INC., and VISA U.S.A., INC.,
`
`
`v.
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`Defendants.
`
`)
`)
`)
`) C.A. No. 17-585-JFB-SRF
`)
`)
`)
`)
`)
`)
`APPLE INC.’S MOTION TO STAY
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`Defendant Apple Inc. (“Apple”) respectfully moves the Court to stay this litigation
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`pending the final resolution, including any appeal, of Apple’s petitions for inter partes and
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`covered business method review of U.S. Patent Nos. 8,577,813; 8,856,539; 9,100,826; and
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`9,530,137.
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`The grounds for this motion are set forth in Defendant Apple Inc.’s Opening Brief in
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`Support of Its Motion to Stay Pending Inter Partes and Covered Business Method Review, and
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`the Declaration of Mark D. Selwyn in support of same, filed contemporaneously herewith.
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`Pursuant to Rule 7.1.1 of the Local Rules of the United States District Court for the
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`District of Delaware, counsel for Apple have consulted with counsel for Plaintiff Universal
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`Secure Registry LLC regarding the subject matter of this motion, and Plaintiff has not consented
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`to the relief requested.
`
`
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`
`
`
`
`Case 1:17-cv-00585-JFB-SRF Document 90 Filed 06/15/18 Page 2 of 2 PageID #: 1379
`
`
`
`
`
`
`/s/ Jason J. Rawnsley
`Fredrick L. Cottrell, III (#2555)
`Jason J. Rawnsley (#5379)
`RICHARDS LAYTON, & FINGER, P.A.
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`cottrell@rlf.com
`rawnsley@rlf.com
`
`Attorneys for Defendant Apple Inc.
`
`
`
`
`
`
`OF COUNSEL:
`
`Mark D. Selwyn
`Liv L. Herriot
`WILMER CUTLER PICKERING HALE
`AND DORR LLP
`950 Page Mill Road
`Palo Alto, CA 94304
`(650) 858-6000
`
`Monica Grewal
`Kate Saxton
`WILMER CUTLER PICKERING HALE
`AND DORR LLP
`60 State Street
`Boston, MA 02109
`(202) 663-6000
`
`Derek A. Gosma
`WILMER CUTLER PICKERING HALE
`AND DORR LLP
`350 South Grand Avenue, Suite 2100
`Los Angeles, CA 90071
`(213) 443-5300
`
`Dated: June 15, 2018
`
`
`
`2
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`
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