"1. In light of the Collateral Estoppel Order, the Parties request that the Court enter, and/or incorporate into any final judgment of the Court in this matter, the Stipulated Partial Judgment attached hereto as Exhibit “A”."

If Handal wants to preserve Exhibit “A” for the future, beyond this court...IMO, the agreed language needs some tweaking. As I see it, it's only preserved if the judge rules on any details...Markman proceedings...etc.

doni