PAGE 1 – STIPULATION OF THE PARTIES REGARDING “SKYLAKE” PRODUCTS

John Mansfield, OSB No. 055390 

MansfieldLaw 

121 SW Morrison Ave., Suite 400 

Portland, OR 97204 

Telephone: 971.271.8615 

john@mansfieldlaw.net 

Jonathan Baker (appearing pro hac vice) 

FARNEY DANIELS PC 

411 Borel Avenue, Suite 350 

San Mateo, California 94402 

Telephone: (424) 278-5200 

jbaker@farneydaniels.com 

[Additional Counsel listed on signature page] 

Attorneys for Plaintiff Memory Integrity, LLC 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF OREGON 

PORTLAND DIVISION 

MEMORY INTEGRITY, LLC, 

Plaintiff, 

v. 

INTEL CORPORATION, 

Defendant. 

Case No. 3:15-cv-00262-SI

STIPULATION OF THE PARTIES 

REGARDING “SKYLAKE” 

PRODUCTS 

 

Case 3:15-cv-00262-SI Document 205 Filed 04/05/16 Page 1 of 4
PAGE 2 – STIPULATION OF THE PARTIES REGARDING “SKYLAKE” PRODUCTS

WHEREAS, on February 3, 2016, Plaintiff Memory Integrity, LLC (“MI” or “Plaintiff”) 

served a Supplemental Identification of Accused Products in this case, which, in addition to the 

products previously identified, further identified certain of Defendant Intel Corporation’s (“Intel” 

or “Defendant”) “Skylake” series of processors as products accused by MI of infringing the 

patents-in-suit; 

WHEREAS Intel has disputed the propriety of MI’s addition of the “Skylake” processors 

as accused products at this stage in this case; 

WHEREAS, without conceding their respective positions, the parties wish to enter into 

this stipulation in order to resolve this dispute without unnecessary motion practice; 

MI and Intel, by and through their respective counsel, stipulate as follows: 

1. MI withdraws its identification of Intel’s “Skylake” processors as accused 

products, and MI will not pursue claims of infringement against Intel’s “Skylake” 

processors in the trial of this action; 

2. Intel will not object to a subsequent suit asserting infringement claims against 

Intel’s “Skylake” products on the ground that such claims should have been 

included in the current case; 

3. Notwithstanding the above, in any subsequent suit against any Intel products 

(including “Skylake” products), Intel shall have the right to raise any other 

objection to such suit and to enforce any judgment or ruling against MI arising in 

this suit to the full extent of any applicable preclusion doctrine, including claim 

preclusion, issue preclusion, and the Kessler doctrine; 

4. In any subsequent suit against any Intel products (including “Skylake” products), 

MI shall have the right to assert any applicable preclusion doctrine against Intel; 

Case 3:15-cv-00262-SI Document 205 Filed 04/05/16 Page 2 of 4
PAGE 3 – STIPULATION OF THE PARTIES REGARDING “SKYLAKE” PRODUCTS

5. In any subsequent suit alleging infringement of U.S. Patent Nos. 8,572,206, 

8,898,254, 7,296,121, 7,103,636, or 7,107,409 against any Intel products 

(including “Skylake” products), MI must bring such action in the U.S. District 

Court for the District of Oregon, and MI will not seek different claim 

constructions than the constructions that the Court has adopted in this case (as 

may be corrected, reversed, vacated, or modified by the Court in this case or on 

appeal of this case). 

WHEREFORE, the parties stipulate as set forth above. 

Case 3:15-cv-00262-SI Document 205 Filed 04/05/16 Page 3 of 4
PAGE 4 – STIPULATION OF THE PARTIES REGARDING “SKYLAKE” PRODUCTS

Dated: April 5, 2016 Respectfully submitted, 

 /Jonathan Baker/ 

Jonathan Baker (appearing pro hac vice) 

Michael Saunders (appearing pro hac vice) 

Gurtej Singh (appearing pro hac vice) 

FARNEY DANIELS PC 

411 Borel Avenue, Suite 350 

San Mateo, California 94402 

Telephone: (424) 278-5200 

jbaker@farneydaniels.com 

msaunders@farneydaniels.com 

tsaunders@farneydaniels.com 

Bryan Atkinson (appearing pro hac vice) 

FARNEY DANIELS PC 

800 S. Austin Avenue, Suite 200 

Georgetown, Texas 78626 

Telephone: (512) 582-2828 

batkinson@farneydaniels.com 

John Mansfield, OSB No. 055390 

MANSFIELDLAW

121 SW Morrison Ave., Suite 400 

Portland, OR 97204 

Telephone: 971.271.8615 

john@mansfieldlaw.net 

Attorneys for Plaintiff

Memory Integrity, LLC 

 /Arthur W. Coviello/ 

Renée E. Rothauge, OSB #903712 

MARKOWITZ HERBOLD PC 

Suite 3000, Pacwest Center 

1211 SW Fifth Avenue 

Portland, OR 97204-3730 

ReneeRothauge@markowitzherbold.com 

Michael J. Summersgill (pro hac vice) 

Jordan L. Hirsch (pro hac vice) 

Sarah Beigbeder Petty (pro hac 

vice)Alexandra Wells Amrhein (pro hac 

vice) 

WILMERHALE LLP 

60 State Street 

Boston, MA 02109 

michael.summersgill@wilmerhale.com 

jordan.hirsch@wilmerhale.com 

sean.thompson@wilmerhale.com 

Grant K. Rowan (pro hac vice) 

WILMERHALE LLP 

1875 Pennsylvania Avenue, NW 

Washington, DC 20006 

Grant.rowan@wilmerhale.com 

Arthur W. Coviello (pro hac vice) 

WILMERHALE LLP 

950 Page Mill Road 

Palo Alto, CA 94304 

Arthur.coviello@wilmerhale.com 

Attorneys for Defendant

Intel Corporation

Case 3:15-cv-00262-SI Document 205 Filed 04/05/16 Page 4 of 4