`To: DG-Collabo; David DeZern
`Cc: ddacus@dacusfirm.com; QCOM-Collabo-Cov; Sharma, Anupam
`Subject: IPR2025-01015 (US 7,930,575)
`Date: Tuesday, July 15, 2025 12:30:00 PM
`Collabo Counsel,
`
`Qualcomm Inc. and Qualcomm Technologies, Inc. (Qualcomm) hereby stipulate that, if the
`Patent Trial and Appeal Board institutes inter partes
`review proceedings for U.S. Patent No.
`7,930,575 based on IPR2025-01015, then Qualcomm will not pursue an invalidity defense in
`Collabo Innovations, Inc. v. Qualcomm, Inc., 6:24-cv-00472 (W.D. Tex.) that the claims of the ’575
`Patent subject to the instituted IPR
`
`are invalid based on grounds that were raised or reasonably
`could have been raised in the instituted IPR petition and any grounds that include any prior art
`references relied upon in any of the grounds in the IPR petition. For clarity, the prior art
`references relied upon in the grounds of the IPR petition are listed below:
`· US 7,293,183 (Lee)
`· US 7,219,248 (Shikata)
`· US 7,664,970 (Jahagirdar)
`· US 5,530,879 (Crump)
`· US 5,502,689 (Peterson)
`· US 7,369,815 (Kang)
`· US 7,167,991 (Higadisha)
`· US 5,390,350 (Chung)
`
`Regards,
`
`Anupam
`
`Anupam Sharma | Attorney | Covington & Burling LLP | 3000 El Camino Real, 5 Palo Alto Square, Palo
`Alto, CA 94306 | (650) 632-4709 | asharma@cov.com
`
`
`
`IPR2025-01015
`Qualcomm Inc. v. Collabo Innovations, Inc.
`Collabo’s Exhibit 2010
`Ex. 2010, Page 1
`
`
`
`
`
`
`
`
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