`Sotera Stipulation
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TOYOTA MOTOR CORPORATION,
`Petitioner,
`V.
`BUNKER HILL TECHNOLOGIES, LLC
`
`Patent Owner
`
`Case No.: [PR2026-00333
`U.S. Patent No. 11,374,508
`
`SOTERA STIPULATION
`
`
`
`
`
`
`
`
`U.S. Patent No. 11,374,508
`Sotera Stipulation
`
`Petitioner hereby stipulates that, if an IPR is instituted based on Petitioner’s
`petition directed to U.S. Patent No. 11,374,508, Petitioner will not raise in the
`parallel district court action (Bunker Hill Technologies, LLC v. Toyota Motor Corp.
`et al., Case No. 2:25-cv-01133 (E.D. Tex.)) any ground raised or that could have
`been reasonably raised in the IPR.
`
`Respectfully submitted,
`Date: April 7, 2026 /s/ Alexander Englehart
`Alexander B. Englehart
`
`Counsel for Petitioner
`Registration No. 62,031
`
`
`
`
`
`
`
`
`
`U.S. Patent No. 11,374,508
`Sotera Stipulation
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. §§ 42.105 and 42.6, that
`
`service was made on the Patent Owner as detailed below.
`
`Date of service
`Manner of service
`Documents served
`
`Served upon:
`
`April 7, 2026
`Electronic Mail and UPS Mail Service
`
`Sotera Stipulation
`
`Ascenda Law Group, PC
`2150 N First Street, Suite 420
`San Jose, CA 85131
`
`Via UPS
`
`Patrick Conroy
`
`Nelson Bumgardner Conroy PC
`2727 N. Harwood Street, Suite 250
`Dallas, TX 75201
`
`pat@nelbum.com
`
`Courtesy copies served via UPS and
`Electronic Mail on Patent Owner’s
`litigation counsel
`
`/s/ Alexander Englehart
`
`Alexander B. Englehart
`
`Counsel for Petitioner
`
`Registration No. 62,031
`
`Merchant and Gould PC
`
`1900 Duke Street, Suite 600
`
`Alexandria, VA 22314
`
`Telephone: 703-518-4520
`
`E-Mail: aenglehart@merchantgould.com
`
`
`
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`
`
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