`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`
`VLSI TECHNOLOGY LLC,
`
`
`
`
`INTEL CORPORATION,
`
`
`
`
`
`
`Defendant.
`
`Plaintiff,
`
`
`v.
`
`
`
`
`
`
`
`
`No. 18-966-CFC-CJB
`
`
`
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`
`
`
`STIPULATION OF DISMISSAL
`
`Whereas, U.S. Patent Nos. 6,212,633, 7,246,027, 7,247,552, 7,523,331, and 8,081,026 are
`
`collectively the “Asserted Patents” in the above-captioned Action;
`
`Whereas, Plaintiff VLSI Technology LLC (“VLSI”) and Defendant Intel Corporation
`
`(“Intel”) (each a “Party,” and together, the “Parties”) seek to permanently resolve all disputes
`
`concerning Intel or Intel technology with respect to the Asserted Patents; and
`
`Whereas, the Parties have agreed to dismissal of claims and counterclaims asserted in this
`
`action on the basis described below;
`
`Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii), the Parties hereby jointly
`
`stipulate as follows:
`
`That all counts of VLSI’s complaint, including amendments, are dismissed with prejudice;
`
`That all counts of Intel’s counterclaims, including amendments, are dismissed without
`
`prejudice;
`
`That all defenses to the Parties’ claims and counterclaims are dismissed without prejudice;
`
`
`
`Case 1:18-cv-00966-CFC-CJB Document 998 Filed 12/27/22 Page 2 of 2 PageID #: 38515
`
`That VLSI has granted to Intel, its affiliates and their respective former, current and future
`
`suppliers and customers under the Asserted Patents a certain covenant not to sue (the “Covenant
`
`Not To Sue”);
`
`That neither party is paying any amount to the other party;
`
`That this stipulation is entered voluntarily, and neither the fact of the stipulation or the
`
`Covenant Not To Sue, nor anything contained herein or in the Covenant Not To Sue, constitutes,
`
`or shall be construed as, an explicit or implied admission or evidence relating to any issue
`
`associated with the Action;
`
`That, unless otherwise further ordered by the Court, neither party shall file additional
`
`briefing in this Action, including the supplemental briefing with respect to the Court’s April 19,
`
`2022 Standing Order and related matters that would otherwise be due on January 13, 2023;
`
`That each Party will bear its own attorneys’ fees and costs incurred in connection with the
`
`Action; and
`
`That any disputes between the Parties regarding the Asserted Patents, the Covenant Not To
`
`Sue or this Stipulation shall be litigated solely in the United States District Court for the District of
`
`Delaware.
`
`Dated: December 27, 2022 SO STIPULATED AND AGREED.
`
`
`FARNAN LLP
`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
`
`
`/s/ Brian E. Farnan
`/s/ Jack B. Blumenfeld
`Brian E. Farnan (Bar No. 4089)
`Jack B. Blumenfeld (#1014)
`Michael J. Farnan (Bar No. 5165)
`Jeremy A. Tigan (#5239)
`919 N. Market St., 12th Floor
`1201 North Market Street
`Wilmington, DE 19801
`P.O. Box 1347
`Telephone : (302) 777-0300
`Wilmington, DE 19899
`Fax : (302) 777-0301
`(302) 658-9200
`bfarnan@farnanlaw.com
`jblumenfeld@morrisnichols.com
`jtigan@morrisnichols.com
`mfarnan@farnanlaw.com
`Attorneys for Plaintiff
`Attorneys for Defendant
`
`
`
`
`
`
`
`
`
`
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
