`Filed: July 29, 2015
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`
`
`
`
`FORD MOTOR COMPANY,
`
`Petitioner
`
`v.
`
`CUOZZO SPEED TECHNOLOGIES LLC,
`
`Patent Owner
`
`____________
`
`Case No. IPR2014-01393
`Patent No. 6,778,074
`____________
`
`JOINT MOTION TO TERMINATE THE INTER PARTES REVIEW
`
`
`
`
`
`
`
`Pursuant to 35 U.S.C. § 317(a) and 37 C.F.R. § 42.72, Patent Owner and
`
`Case No. IPR2014-01393
`Patent No. 6,778,074
`
`
`
`Ford Motor Company (“Ford”) jointly request termination of Inter Partes Review
`
`Case No. IPR2014-01393.
`
`Patent Owner and Ford respectfully submit that termination is appropriate
`
`because they have reached an agreement resolving the dispute involving the patent
`
`at issue in the above-captioned Inter Partes Review, prior to oral hearing and prior
`
`to the Board’s final written decision in the above-captioned Inter Partes Review.
`
`Further, Ford represents that it will no longer participate even if the Board does not
`
`terminate the above-captioned Inter Partes Review. This means that Ford will file
`
`no further papers, will not be conducting any further cross examination of Patent
`
`Owner’s witnesses, and will not be participating in any oral argument.
`
`Furthermore, Patent Owner respectfully submits that there is no pending
`
`district court litigation involving the patent at issue in this proceeding, and a
`
`petition for rehearing en banc before the Federal Circuit involving the patent at
`
`issue in this proceeding was denied on July 8, 2015. In re Cuozzo Speed
`
`Technologies, LLC, 2014-1301 (Fed. Circ. Jul. 8, 2015).
`
`As required under 35 U.S.C. §317(b) and 37 C.F.R. § 42.72(b), filed
`
`herewith is a true copy of the written settlement agreement (“Agreement”)
`
`resolving the dispute in the above-captioned Inter Partes Review and the related
`
`2
`
`
`
`
`
`litigation. See Confidential Exhibit 1014. The parties do not foresee any further
`
`Case No. IPR2014-01393
`Patent No. 6,778,074
`
`litigation among them relating to the Subject Patent. The parties further certify,
`
`pursuant to the request from the Board, that there are no collateral agreements or
`
`understandings made in connection with the termination of the present Inter Partes
`
`review proceeding.
`
`Patent Owner and Ford are concurrently filing a Joint Request that the
`
`Agreement, Confidential Exhibit 1014, be treated as business confidential
`
`information, kept separate from the file of the involved patents, and made available
`
`only to Federal Government agencies on written request, or to any person on a
`
`showing of good cause pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. §42.74(c).
`
`
`
`Dated: July 29, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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`
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`Respectfully submitted,
`
`
`
`
`
`
`By: /Eric A. Buresh /
`Eric Buresh (Lead Counsel)
`Reg. No. 50,394
`Jason R. Mudd (Backup Counsel)
`Reg. No. 57,700
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, Kansas 66211
`P: 913-777-5600 / F: 913-777-5601
`eric.buresh@eriseip.com
`Jason.mudd@eriseip.com
`
`
`3
`
`
`By: /John R. Kasha/
`John R. Kasha
`Reg. No. 53,100
`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(708) 867-1886
`john.kasha@kashalaw.com
`
`Counsel for Speed Monitoring
`
`
`
`Case No. IPR2014-01393
`Patent No. 6,778,074
`
`Technologies LLC
`
`
`
`
`
`4
`
`
`Counsel for Petitioner, Ford Motor
`Company
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Case No. IPR2014-01393
`Patent No. 6,778,074
`
`The undersigned certifies that a copy of the foregoing JOINT MOTION
`
`TO TERMINATE was served on July 29, 2015, via electronic mail directed to
`
`counsel of record for the Patent Owner at the following:
`
`
`/s/Mark C. Lang/
`Mark C. Lang
`
`ERISE IP, P.A.
`
`
`
`5
`
`John R. Kasha
`Reg. No. 53,100
`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(708) 867-1886
`john.kasha@kashalaw.com
`
`Counsel for Patent Owner
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