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` Joint Motion to Amend the Scheduling Order
`IPR2020-01157
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`DELL INC.,
`Petitioner,
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`v.
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`3G LICENSING S.A.,
`Patent Owner.
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`Case No. IPR2020-01157
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`U.S. Patent No. 7,274,933
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`Joint Motion to Amend the Scheduling Order
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` Joint Motion to Amend the Scheduling Order
`IPR2020-01157
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`I.
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`INTRODUCTION
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`Petitioner Dell Inc. (“Dell”) and Patent Owner 3G Licensing S.A. (“3G”)
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`have reached a settlement as to all the disputes in this proceeding. Pursuant to a
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`telephone conference with the Board on December 7, 2021, Dell and 3G (the
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`Parties) jointly move to Amend the Scheduling Order to cancel the oral argument
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`in Due Date 8, see Paper 38 (Revised Scheduling Order, setting date for Oral
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`Argument), and cancelling the oral argument set forth in the Order Setting Oral
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`Argument, see Paper 43 (setting time and format for Oral Argument).
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`II.
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`STATEMENT OF FACTS
`Dell and 3G have reached a Settlement and License Agreement
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`(“Agreement”) to resolve the Parties’ disputes at issue in this proceeding. The
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`Agreement settles this proceeding. Pursuant to the Agreement, Dell will no longer
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`be participating in IPR2020-1157. The Agreement also settles the Parties’ dispute
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`in related District Court litigation: Sisvel Int’l S.A. v. Dell, Inc., C.A No. 1:19-cv-
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`01247-LPS (D. Del.). The Parties are filing a joint motion to dismiss that litigation.
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`No litigation or other proceeding between the parties involving the ’933 patent or
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`any related patent is contemplated in the foreseeable future.
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`III. AMENDMENT IS APPROPRIATE
`The parties have entered into a Settlement and License Agreement as to the
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`disputes at issue in this proceeding. Thus, it would save significant time, cost, and
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` Joint Motion to Amend the Scheduling Order
`IPR2020-01157
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`expense by the Parties and the Board to cancel the oral argument. Accordingly, the
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`Parties move to cancel Due Date 8, see Paper 38 (Revised Scheduling Order) (setting
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`date for Oral Argument), and the Order Setting Oral Argument, see Paper 43 (Order
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`Setting Oral Argument) (setting time and format for Oral Argument).
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`IV. CONCLUSION
`For the foregoing reasons, the Parties respectfully request that the Board
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`cancel the oral argument in this inter partes review, including by amending the
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`Scheduling Order to cancel Due Date 8, and by cancelling the Order Setting Oral
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`Argument.
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`DATED: December 8, 2021
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`Respectfully Submitted,
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`/Brian M. Buroker/
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`Brian M. Buroker (Reg. No. 39,125)
`GIBSON, DUNN & CRUTCHER LLP
`1050 Connecticut Ave. NW
`Washington, DC 20036
`Phone: (202) 955-8500
`Fax: (202) 467-0539
`Email: bburoker@gibsondunn.com
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`Attorney for Petitioner Dell Inc.
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` Joint Motion to Amend the Scheduling Order
`IPR2020-01157
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`CERTIFICATE OF SERVICE
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`The undersigned certifies service on the Patent Owner, pursuant to 37 C.F.R.
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`§ 42.6(e), by electronic (e-mail) delivery of a true copy of the foregoing JOINT
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`MOTION TO AMEND THE SCHEDULING ORDER to lead and back-up counsel
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`of record for Patent Owner as follows:
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`TD-PTAB@devlinlawfirm.com
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`nbenchell@devlinlawfirm.com
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`sberger@devlinlawfirm.com
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`ademarco@devlinlawfirm.com
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`dlflitparas@devlinlawfirm.com
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`DATED: December 8, 2021
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`By:
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`/Brian M. Buroker/
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`Brian M. Buroker (Reg. No. 39,125)
`GIBSON, DUNN & CRUTCHER LLP
`1050 Connecticut Ave. NW
`Washington, DC 20036
`Phone: (202) 955-8500
`Fax: (202) 467-0539
`Email: bburoker@gibsondunn.com
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`Attorney for Petitioner Dell Inc.
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`3
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