`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`JUNIPER NETWORKS, INC.
`Petitioner
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`v.
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`IMPLICIT, LLC
`Patent Owner
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`Case: IPR2020-00587
`Patent No. 9,591,104
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`PATENT OWNER’S RESPONSE TO PETITION FOR INTER PARTES
`REVIEW OF U.S. PATENT NO. 9,591,104
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`Patent Owner Implicit, LLC (“Implicit”) files this Patent Owner’s Response
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`to update the Board on the status of these proceedings.
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`On October 7, 2020, Implicit and Juniper Networks, Inc. (“Juniper”) filed a
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`Motion in the accompanying Implicit v. Juniper District Court proceedings notifying
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`the Court that the parties settled, in principle, the claims between them:
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`Plaintiff Implicit, LLC (“Implicit”) and Defendant Juniper
`Networks, Inc. (“Juniper”) hereby notify the Court that
`they have settled, in principle, the claims between them.
`Accordingly Plaintiff Implicit and Defendant Juniper
`jointly move the Court to stay all deadlines in the above-
`captioned case until November 6, 2020, to allow the
`parties to finalize the settlement of this matter.
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`Implicit, LLC v. Imperva, Inc. et. al., Case No. 2:19-CV-00040-JRG-RSP (E.D. Tex.
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`Oct. 7, 2020) (Dkt. 274). The Court stayed all deadlines until November 6, 2020 to
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`allow the parties to finalize the settlement:
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`Before the Court is the Joint Motion to Stay All Deadlines
`and Notice of Settlement Between Plaintiff Implicit, LLC
`and Defendant Juniper Networks, Inc. filed by Implicit
`and Juniper. Dkt. No. 274. The parties’ Joint Motion
`notifies the Court that they have settled in principle the
`claims between them and seek a stay of all deadlines in the
`above-captioned matter until November 6, 2020 to allow
`the parties to finalize the settlement.
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`After due consideration, the Court GRANTS the Motion.
`The Court thereby ORDERS that the above-captioned
`matter is STAYED with respect to Implicit and Juniper
`until November 6, 2020.
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`Implicit, LLC v. Imperva, Inc. et. al., Case No. 2:19-CV-00040-JRG-RSP (E.D. Tex.
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`Oct. 7, 2020) (Dkt. 274). Implicit thus expects that, upon finalization of the
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`settlement, the parties will request to terminate these proceedings under 35 U.S.C. §
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`317 and 35 C.F.R. § 42.74. Implicit reserves all rights to address the Institution
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`Decision in the event that these proceedings are not terminated.
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`Dated: November 2, 2020
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`Respectfully submitted,
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`DAVIS FIRM, PC
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`By:_/Christian Hurt/___________
`Christian Hurt
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`CERTIFICATE OF COMPLIANCE
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`I hereby certify that the foregoing Patent Owner’s Response complies with
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`the type-volume limitation and general format requirements pursuant to 37 C.F.R.
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`§§42.24 and 42.6. I further certify that this response contains 308 words,
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`excluding parts exempted by 37 C.F.R. §42.24.
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`/Christian Hurt/
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`Christian Hurt
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`CERTIFICATE OF SERVICE
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`I hereby certify that on November 2, 2020, a true copy of the following
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`document(s):
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`PATENT OWNER IMPLICIT, LLC’S RESPONSE TO PETITION FOR
`INTER PARTES REVIEW OF U.S. PATENT NO. 9,591,104
`was served via email to the address and parties as follows:
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`Juniper-Implicit@irell.com
`Jonathan M. Lindsay
`David McPhie
`Courtney Dennis
`Irell & Manella LLP
`840 Newport Center Drive, Suite 400
`Newport Beach, CA 92660
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`I declare under penalty of perjury under the laws of the United States of
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`America that the foregoing is true and correct. Executed on November 2, 2020 at
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`Dallas, Texas.
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`/Christian Hurt/
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`Christian Hurt
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