`To:
`Cc:
`Subject:
`Date:
`Attachments:
`
`Yen Bruce
`"James Quigley"
`"Ashley N. Moore"; Alexandra F. Easley; PARC Snap; Chaikovsky Yar R.; Ou Philip; Faasisila Nikole; PH-Parc-Snap
`[PARC v. Snap] M&C re: Stay of PARC v. Snap, Case No. 2:20-cv-10755 AB(MRWx) (C.D. Cal.)
`Wednesday, May 19, 2021 3:54:37 PM
`image001.png
`CDCA-2-19-cv-03394-65 pdf
`CDCA-2-19-cv-04382-54 pdf
`CDCA-2-19-cv-10593-56 pdf
`CDCA-5-18-cv-00356-143 CDCA-5-18-cv-00357-142.pdf
`CDCA-2-17-cv-04395-127.pdf
`CDCA-2-17-cv-05653-85 pdf
`
`Hi James,
`
`We are reaching out to schedule a meet and confer on a motion to stay in the PARC v. Snap case, Case No. 2:20-cv-10755
`AB(MRWx). Please let us know of your availability tomorrow or Friday.
`
`Snap will be filing IPR petitions in the next few days that seek PTAB review of the two patents PARC has asserted against Snap,
`including each of the claims PARC has asserted in its infringement contentions.
`
`Snap believes that considering the circumstances here—being early in the case, all asserted claims of all asserted patents will be
`challenged, and parties not being competitors—it is very likely the Court will be inclined to grant a stay. Moreover, as you may know,
`the Court has a consistent record of granting stays pre-institution. Attached are a handful of relevant orders for your convenience.
`See Guy A. Shaked Investments, Ltd. v. Trade Box, LLC, Case No. 19-CV-10593-AB, Dkt. No. 56, at 3 (C.D. Cal. Nov. 18, 2020); DataQuill
`Ltd. v. TCL Commc’n Holdings Ltd., Case No. 19-CV-03394-AB, Dkt No. 65, at 5 (C.D. Cal. Apr. 24, 2020); Weserve Drone, LLC v. SZ DJI
`Tech. Co. Ltd., Case No. 19-CV-04382-AB, Dkt. No. 54, at 7 (C.D. Cal. Mar. 17, 2020); Sleep Number Corporation v. Sizewise Rentals,
`LLC, Case No. 18-CV-00356-AB, Dkt. No. 143, at 6 (C.D. Cal. Feb. 12, 2019); General Electric Company v. Vestas Wind Systems A/S,
`Case No. 17-CV-05653-AB, Dkt. No. 85, at 2 (C.D. Cal. Jun. 07, 2018); Essity Hygiene and Health Aktiebolag v. Tarzana Enterprises, LLC,
`Case No. 17-CV-04395-AB, Dkt. No. 127, at 16 (C.D. Cal. Sep. 27, 2017).
`
`In light of the Court’s opinions above, please let us know if you would agree to a joint motion stay pending institution and final
`resolution of the IPRs, which would save the parties time and expense on motion practice. If PARC opposes, please be prepared to
`discuss basis for your opposition during the meet and confer.
`
`Thank you,
`
`Bruce
`
`
`
`
`
`
`
`Bruce Yen | Associate
`Paul Hastings LLP | 1117 S. California Avenue, Palo Alto, CA 94304 | Direct: +1.650.320.1864 |
`Main: +1.650.320.1800 | Fax: +1.650.320.1900 | bruceyen@paulhastings.com |
`www.paulhastings.com
`
`Page 1 of 1
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`SNAP EXHIBIT 1020
`
`
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