`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________
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`R.J. REYNOLDS VAPOR COMPANY
`
`Petitioner
`
`v.
`
`PHILIP MORRIS PRODUCTS S.A.,
`
`Patent Owner
`
`__________________
`
`IPR2021-00826
`U.S. Patent No. 9,814,265
`__________________
`
`
`NOTICE OF SOTERA STIPULATION
`
`The following Sotera stipulation was made in the co-pending district court
`
`
`
`
`
`case on September 22, 2021.
`
`
`
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`
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`NORTH POINT • 901 LAKESIDE AVENUE • CLEVELAND, OHIO 44114.1190
`
`TELEPHONE: +1.216.586.3939 • FACSIMILE: +1.216.579.0212
`
`
`
`
`629000-850001
`
`
`September 22, 2021
`
`Direct Number: (216) 586-7499
`dmaiorana@jonesday.com
`
`
`
`
`VIA E-MAIL
`
`Maximilian A. Grant, Esq.
`Latham & Watkins LLP
`555 Eleventh Street, NW, Suite 1000
`Washington, DC 20004
`
`Re:
`
`RAI Strategic Holdings, Inc. v. Altria Client Services LLC
`Case No. 1:20-cv-00393-LO-TCB (E.D. Va.)
`
`
`
`
`Dear Max:
`
`Plaintiffs RAI Strategic Holdings, Inc. and R.J. Reynolds Vapor Company (“Reynolds”)
`hereby stipulate that, if the Patent Trial and Appeal Board (“PTAB”) institutes the pending inter
`partes review petition in IPR2021-00826 challenging the patentability of claims 1, 3–5, 8, and 17
`of U.S. Patent Number 9,814,265, then Reynolds will not pursue as to the challenged claims any
`ground raised or that could have been reasonably raised in the IPR in the above-captioned
`litigation, 1:20-cv-00393.
`
`To avoid any doubt, if the PTAB declines institution of IPR2021-00826, Reynolds
`reserves the right to pursue these invalidity grounds in the parallel litigation.
`
`Very truly yours,
`
`David M. Maiorana
`
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`AMSTERDAM ATL ANTA BEIJING BOSTON BRISBANE BRUSSELS CHICAGO CLEVEL AND COLUMBUS DALL AS DETROIT
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`DUBAI DÜSSELDORF FRANKFURT HONG KONG HOUS TON IRVINE LONDON LOS ANGELES MADRID MELBOURNE
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`MEXICO CIT Y MIAMI MIL AN MINNEAPOLIS MOSCOW MUNICH NEW YORK PARIS PERTH PITTSBURGH SAN DIEGO
`
`SAN FRANCISCO SÃO PAULO SAUDI ARABIA SHANGHAI SILICON VALLEY SINGAPORE S YDNEY TAIPEI TOKYO WASHINGTON
`
`
`
`
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