Filed on behalf of: Unified Patents Inc.

By: P. Andrew Riley

James D. Stein
Finnegan, Henderson, Farabow,
Garrett & Dunner, L.L.P.
901 New York Avenue, NW
Washington, DC 200014413
Telephone: 202-408-4000
Email:
Novocrypt_IPR@finnegan.com
Jonathan Stroud
Unified Patents Inc.
1875 Connecticut Ave. NW, Floor 10
Washington, D.C., 20009
Telephone: 202-805-8931
Email:
jonathan@unifiedpatents.com

UNITED STATES PATENT AND TRADEMARK OFFICE

____________________________________________

BEFORE THE PATENT TRIAL AND APPEAL BOARD

____________________________________________

UNIFIED PATENTS INC.

Petitioner
v.
NOVOCRYPT LLC
Patent Owner

IPR2015-01606
Patent 7,743,213
JOINT MOTION TO TERMINATE UNDER 35 U.S.C. 317(a)

IPR2015-01606
Patent 7,743,213
Pursuant to 35 U.S.C. 317(a), Petitioner Unified Patents Inc.
(Unified) and Patent Owner Novocrypt LLC (Novocrypt) jointly request
termination of the Inter Partes Review of U.S. Patent 7,743,213, in
IPR2015-01606.
On March 31, 2016, the Parties informed the Board of the settlement
and requested authorization to file a joint motion to terminate the proceeding
with respect to both the Patent Owner and the Petitioner. The Board
authorized the filing of the requested joint motion to terminate this
proceeding as to both parties in an e-mail dated April 1, 2016.
This inter partes review has been instituted, but substantive briefing
has not begun. No depositions have been taken. Termination of this IPR is
appropriate as the Board has not yet decided the merits of the proceeding.
See, e.g., Office Patent Trial Practice Guide, 77 Fed. Reg. 48756, 48768
(Aug. 14, 2012). Moreover, ending this IPR early promotes the
Congressional goal of establishing a more efficient patent system by limiting
unnecessary and counterproductive costs. See Changes to Implement Inter
Partes

Review

Proceedings,

Post-Grant

Review

Proceedings,

and

Transitional Program for Covered Business Method Patents, 77 Fed. Reg.

48,680 (Aug. 14, 2012). Permitting termination as to all parties provides
certainty and fosters an environment that promotes settlements, creating a

IPR2015-01606
Patent 7,743,213
timely, cost-effective alternative to litigation.
Unified filed its petition for inter partes review on July 22, 2015.
Novocrypt LLC waived the right to file a preliminary response prior to
institution. The Board instituted this proceeding on December 22, 2015, on
all requested grounds and claims. The parties have now settled their dispute,
and have reached agreement to terminate this inter partes review.
This Settlement Agreement has been made in writing, and a true and
correct copy shall be filed with this Office as business confidential
information pursuant to 35 U.S.C. 317(b). As stated in 35 U.S.C. 317(a),
because Unified and Novocrypt LLC request this termination as to Petitioner
Unified, no estoppel under 35 U.S.C. 315(e) shall attach to Unified.
Therefore, Unified and Novocrypt LLC respectfully request
termination of the Inter Partes Review of U.S. Patent No., Case No.
IPR2016-01606.
Date: April 4, 2016

Respectfully submitted,
By: /P. Andrew Riley/
P. Andrew Riley (Lead Counsel)
Reg. No. 66,290