`BOARD CERTIFIED-CIVIL TRIAL LAW
`TEXAS BOARD OF LEGAL SPECIALIZATION
`DIRECT 713.600.4903
`MAIN 713.655.1101
`FAX 713.655.0062
`AALAVI@AZALAW.COM
`
`May 10, 2021
`
`By Email:
`Barry Herman
`Womble Bond Dickinson (US) LLP
`100 Light Street, 26th Floor
`Baltimore, MD 21202
`
`Re: DynaEnergetics Europe GmbH and DynaEnergetics US, Inc. v. Yellow
`Jacket Oil Tools, LLC; Civil Action No. 6:20-cv-01110 (Western Dist. of
`Texas)
`
`G&H Diversified Manufacturing, LP v. DynaEnergetics Europe GmbH
`and DynaEnergetics US, Inc.; Civil Action No. 3:20-cv-00376 (Southern
`Dist. of Texas)
`
`Dear Mr. Herman:
`
`As you are aware, we represent G&H Di
`
`intends to file with the Patent Trial and A
`
`ferenced litigations
`
`discusses closely related patents and
`
`acket hereby stipulate that in the event
`the PTAB institutes a PGR based on the Petition, G&H and Yellow Jacket will not rely
`on the References, either alone or in combination with prior art, to challenge the validity
`
`By so stipulating, G&H and Yellow Jacket seek to avoid multiple proceedings
`addressing the validity of the claims of the
`consistent with congressional intent, through this stipulation, G&H and Yellow Jacket
`express their intention that only the PTAB should address the invalidity of the claims
`asserted in the above-captioned litigation based on the References. But, for the sake of
`clarity and to avoid any doubt, if the PTAB declines to institute a PGR based on the GHD
`1026
`
`Page 1 of 2 (PGR2021-00078)
`G&H DIVERSIFIED MANUFACTURING, LP v. DYNAENERGETICS EUROPE GMBH
`
`
`
`Barry Herman
`May 10, 2021
`Page 2
`
`Petition, G&H and Yellow Jacket reserve the right to challenge the validity of claims of
` the References in the litigation. Additionally, even in the event
`of institution, G&H and Yellow Jacket reserves the right to rely on any prior art other
`than the References.
`
`Sincerely,
`
`Amir H. Alavi
`
`CC: Joshua Wyde (via email jwyde@azalaw.com)
`Steve Jugle (via email sjugle@azalaw.com)
`Masood Anjom (via email manjom@azalaw.com)
`
`Page 2 of 2 (PGR2021-00078)
`G&H DIVERSIFIED MANUFACTURING, LP v. DYNAENERGETICS EUROPE GMBH
`
`
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