`+1 202.942.5648 Direct
`jin.park@arnoldporter.com
`
`November 19, 2021
`
`VIA E-MAIL
`
`Peter Lambrianakos
`Fabricant LLP
`230 Park Avenue, 3rd Floor W
`New York, NY 10169
`plambrianakos@fabricantllp.com
`
`Re:
`
`Jawbone Innovations, LLC v. Samsung Elecs. Co., Ltd., et al., Case No.
`2:21-cv-00186 (E.D. Tex.)
`
`Dear Peter:
`
`We write regarding our on-going litigation, in which Jawbone Innovations, LLC
`asserts U.S. Patent No. 8,280,072 (the “’072 patent”) against Samsung Electronics Co.,
`Ltd. and Samsung Electronics America, Inc. (together, “Samsung”).
`
`Samsung is planning to submit a petition for inter partes review on claims 1-9 of
`the ’072 patent. By this letter, Samsung stipulates that, if the Board institutes inter partes
`review of IPR2022-00213, Samsung will not rely on either of U.S. Patent Application
`Publication 2008/0170716 or U.S. Patent Application Publication 2005/004182 to assert
`invalidity of the ’072 patent in the litigation.
`
`cc:
`
`Counsel of record
`
`Arnold & Porter Kaye Scholer LLP
`601 Massachusetts Ave, NW | Washington, DC 20001-3743 | www.arnoldporter.com
`
`Samsung Exhibit 1019
`Page 01 of 01
`
`
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