Contract analysis

1. Dismissal of Plaintiff's Claims. The parties hereby stipulate and agree that all claims asserted by Plaintiff Pinnacle Innovations LLC against Defendant Vantage Mobility Systems Corp. in the above-captioned action, including without limitation all claims of patent infringement of United States Patent No. 9,847,312 B2 (entitled "Adaptive Sensor Integration Module for Vehicular Guidance Systems"), specifically Claim

2. Dismissal of Defendant's Counterclaims. The parties hereby stipulate and agree that all counterclaims asserted by Defendant Vantage Mobility Systems Corp. against Plaintiff Pinnacle Innovations LLC in this action, including without limitation Defendant's counterclaims of invalidity under 35 U.S.C. §§ 102 and 103, non-infringement, and inequitable conduct, as set forth in Defendant's Answer and Counterclaims (Dkt.

3. Attorneys' Fees and Costs. Each party shall bear its own attorneys' fees, costs, and expenses incurred in connection with this action. No party is designated a prevailing party for purposes of any fee-shifting statute, rule, or provision, including but not limited to 35 U.S.C. § 285, 28 U.S.C. § 1927, or Federal Rule of Civil Procedure 54(d). The parties expressly waive any right to seek attorneys' fees or costs f

4. Retention of Jurisdiction. This Joint Stipulation of Dismissal is submitted pursuant to and in furtherance of a settlement reached between the parties. The Court shall retain jurisdiction solely for the limited purpose of enforcing the terms of this Stipulation of Dismissal and the parties' confidential settlement agreement, if necessary. Except as provided in this paragraph, the Court's jurisdiction over this mat

5. Vacatur of Remaining Deadlines. All remaining deadlines in this action, including the expert report deadline of May 30, 2025, the Daubert motion deadline, the pretrial conference, the trial date of October 6, 2025, and any other pretrial deadlines, scheduling orders, or discovery obligations set forth in the Court's Scheduling Order (Dkt. No. 28) or any subsequent orders, are hereby vacated and rendered moot.

6. Authorization. The undersigned counsel represent and certify that they are fully authorized by their respective clients to execute this Joint Stipulation of Dismissal with Prejudice and to bind their respective clients to the terms set forth herein. WHEREFORE, the parties respectfully request that this Court enter the accompanying [Proposed] Order dismissing this action with prejudice and closing this case. Respec

1. All claims asserted by Plaintiff Pinnacle Innovations LLC against Defendant Vantage Mobility Systems Corp. in this action, including all claims of infringement of United States Patent No. 9,847,312 B2, are DISMISSED WITH PREJUDICE.

2. All counterclaims asserted by Defendant Vantage Mobility Systems Corp. against Plaintiff Pinnacle Innovations LLC in this action, including counterclaims of invalidity, non-infringement, and inequitable conduct, are DISMISSED WITH PREJUDICE.

3. Each party shall bear its own attorneys' fees, costs, and expenses. No party is designated a prevailing party for purposes of any fee-shifting statute or rule.

4. All remaining deadlines in this action, including the expert report deadline, the pretrial conference, and the trial setting of October 6, 2025, are hereby VACATED.

5. The Court retains jurisdiction solely for the purpose of enforcing the terms of this Stipulation of Dismissal and the parties' settlement agreement, if necessary.

6. The Clerk of Court is directed to CLOSE this case and enter this Order on the docket. SO ORDERED this _ day of ______, 2025. ________________________________________ Hon. J. Rodney Gilstrap United States District Judge CERTIFICATE OF CONFERENCE Pursuant to Local Rule CV-7(h) of the United States District Court for the Eastern District of Texas, the undersigned counsel for Defendant Vantage Mobility Systems Corp. h