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Case 1:23-cv-00758-JLH-SRF Document 170 Filed 10/10/24 Page 1 of 2 PageID #: 4400
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR DISTRICT OF DELAWARE
`
`
`ORCA SECURITY LTD.,
`
`
`
`
`C.A. No. 23-758-JLH
`
`
`
`)))))))))
`
`
`)
`
`
`
`
`
`
`WIZ, INC.,
`
`
`
`Plaintiff and Counter-Defendant
`
`v.
`
`Defendant and Counter-Plaintiff.
`
`
`
`WIZ, INC.’S STIPULATION CONCERNING INVALIDITY GROUNDS
`
`On May 24, 2024, Defendant Wiz, Inc. (“Wiz”) filed petition numbers IPR2024-00863, -
`
`864, and -865 with the Patent Trial and Appeal Board requesting inter partes review (“IPR”) of
`
`U.S. Patent Nos. 11,663,031 (“the ’031 patent”), 11,663,032 (“the ’032 patent”), and 11,693,685
`
`(“the ’685 patent”), respectively. Each petition advances at least one ground of unpatentability
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`against every claim of its associated patent (“Challenged Claims”).
`
`Wiz hereby stipulates that if the Patent Trial and Appeal Board institutes an IPR on any
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`one of the petitions filed in IPR2024-00863, -864, and -865, then Wiz will not pursue in this
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`case, against any of the Challenged Claims in the instituted IPR(s), the specific grounds
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`advanced in the instituted IPR(s) or any ground that reasonably could have been raised in an IPR
`
`(i.e., any ground that could be raised under §§ 102 or 103 against any of the Challenged Claims
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`only on the basis of prior art patents or printed publications).
`
`This stipulation is not intended and should not be construed to limit Wiz’s ability to
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`assert invalidity of the claims of the ’031, ’032, or ’685 patents on any other ground regardless of
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`whether any of the IPRs are instituted.
`
`
`
`

`

`Case 1:23-cv-00758-JLH-SRF Document 170 Filed 10/10/24 Page 2 of 2 PageID #: 4401
`
`
`
`
`
`/s/ Christine D. Haynes
`Frederick L. Cottrell, III (#2555)
`Kelly E. Farnan (#4395)
`Christine D. Haynes (#4697)
`RICHARDS, LAYTON & FINGER, P.A.
`One Rodney Square
`920 N. King Street
`Wilmington, DE 19801
`(302) 658-6541
`cottrell@rlf.com
`farnan@rlf.com
`haynes@rlf.com
`
`Attorneys for Defendant and Counter-
`Plaintiff Wiz, Inc
`
`
`
`
`
`
`
`
`OF COUNSEL:
`
`Jordan R. Jaffe
`Catherine Lacy
`Alex Miller
`WILSON SONSINI GOODRICH &
`ROSATI, P.C.
`One Market Plaza
`Spear Tower, Suite 3300
`San Francisco, CA 94105
`(415) 947-2000
`
`Lisa D. Zang
`Callie Davidson
`WILSON SONSINI GOODRICH &
`ROSATI P.C.
`1900 Avenue of the Stars, 28th Floor
`Los Angeles, CA 90067
`(424) 466-6900
`
`Praatika Prasad
`WILSON SONSINI GOODRICH &
`ROSATI P.C.
`1301 Ave. of the Americas, 40th Fl.
`New York, NY 10019
`(212) 453-2803
`
`Dated: October 10, 2024
`
`
`
`
`-2-
`
`

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