throbber
April 26, 2022
`
`VIA E-MAIL
`
`
`
`Raymond W. Mort, III
`raymort@austinlaw.com
`THE MORT LAW FIRM, PLLC
`100 Congress Avenue, Suite 2000
`Austin, Texas 78701
`
`Re:
`
`
`
`Jawbone Innovations, LLC v. Apple Inc., Case No. 6:21-cv-00984
`
`Counsel:
`
`We write regarding a petition for inter partes review (IPR) being filed with the Patent
`Trial and Appeal Board (PTAB) to address claims of U.S. Patent No. 8,467,543 (“the
`’543 patent”). The table below lists grounds asserted by Apple Inc. (“Apple”) in the
`IPR2022-00865 petition challenging claims of this patent, along with the implicated
`claims against which the grounds are asserted.
`
`We write to inform you that Apple hereby stipulates that in the event the PTAB
`institutes an inter partes review based on the IPR2022-00865 petition and including
`the grounds listed in the table below against the corresponding claims listed in the
`table for those grounds (“Instituted Grounds”), then Apple will not seek resolution in
`the above-captioned district court litigation (6:21-cv-00984) of the Instituted Grounds
`against the corresponding claims listed in the table for those same grounds.
`
`
`
`Patent
`No.
`
`8,467,543
`
`Proceeding No.
`
`Claim(s)
`
`Ground
`
`IPR2022-00865 1, 2, 6-10,
`12-18, 26
`
`Obvious (§ 103) over Yang and
`Burnett Thesis
`
`8,467,543
`
`IPR2022-00865 1, 3, 6-10,
`12-18, 26
`
`Obvious (§ 103) over Yang and
`Park
`
`8,467,543
`
`IPR2022-00865 19-25
`
`Obvious (§ 103) over Yang,
`Burnett Thesis or Park, and
`Sasaki
`
`Exhibit 1032
`Page 01 of 03
`
`

`

`
`
`
`
`
`Patent
`No.
`
`Proceeding No.
`
`Claim(s)
`
`Ground
`
`April 26, 2022
`Page 2
`
`8,467,543
`
`IPR2022-00865 4
`
`8,467,543
`
`IPR2022-00865 5
`
`8,467,543
`
`IPR2022-00865 8-11
`
`
`
`Obvious (§ 103) over Yang,
`Burnett Thesis or Park, and
`Litchblau
`
`Obvious (§ 103) over Yang,
`Burnett Thesis or Park, and
`Andrea
`
`Obvious (§ 103) over Yang,
`Burnett Thesis or Park, and
`Turnbull
`
`In so stipulating, Apple seeks to avoid multiple proceedings addressing the validity of
`the ’543 patent based on the same grounds. Rather, Apple wishes the patentability of
`this patent over the above-identified Grounds to be addressed at the PTAB. But, for
`the sake of clarity and to avoid any doubt, if the PTAB declines institution of Apple’s
`IPR petition relating to the ’543 patent, Apple reserves the right to seek resolution of
`the above-identified Grounds in the above-captioned district court litigation (6:21-cv-
`00984).
`
`
`
`
`
`
`Sincerely,
`
`/s/ Daniel R. Gopenko
`
`Daniel R. Gopenko
`Fish & Richardson P.C.
`Counsel for Apple Inc.
`
`
`
`
`
`
`
`
`Exhibit 1032
`Page 02 of 03
`
`

`

`
`
`
`
`
`April 26, 2022
`Page 3
`
`List of Prior Art References
`
`
`Reference
`Name
`
`Details
`
`Yang
`
`U.S. Patent Application Publication 2002/0193130
`
`Burnett Thesis Gregory Burnett, The Physiological Basis of Glottal
`Electromagnetic Micropower Sensors (GEMS) and Their Use
`in Defining an Excitation Function for the Human Vocal
`Tract, Dissertation, January 1999
`
`Park
`
`Sasaki
`
`U.S. Patent 5,590,241
`
`U.S. Patent 5,471,538
`
`Litchblau
`
`U.S. Patent 6,714,654
`
`U.S. Patent 6,061,456
`
`U.S. Patent 6,980,092
`
`Andrea
`
`Turnbull
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Exhibit 1032
`Page 03 of 03
`
`

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