Case 1:13-cv-00919-LPS Document 306 Filed 03/10/21 Page 1 of 14 PageID #: 24390
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`ARENDI S.A.R.L.,
`
`Plaintiff,
`
`v.
`
`MOTOROLA MOBILITY LLC
`f/k/a MOTOROLA MOBILITY, INC.,
`
`Defendant.
`
`ARENDI S.A.R.L.,
`
`Plaintiff,
`
`v.
`
`GOOGLE LLC,
`
`Defendant.
`
`C.A. No. 12-1601-LPS
`
`Original Version Filed: March 5, 2021
`Public Version Filed: March 10, 2021
`
`C.A. No. 13-919-LPS
`
`Original Version Filed: March 5, 2021
`Public Version Filed: March 10, 2021
`
`DECLARATION OF SETH ARD
`
`I, Seth Ard, hereby declare as follows.
`
`1.
`
`I am over 18 years of age, of sound mind, and otherwise competent to make this
`
`declaration. The evidence set out in the foregoing Declaration is based on my personal knowledge.
`
`2.
`
`I am an attorney and partner at the law firm Susman Godfrey LLP, counsel of record
`
`for Plaintiff, Arendi S.à.r.l. in the above-captioned action. I am admitted pro hac vice to practice
`
`before this Court.
`
`3.
`
`Attached as Exhibit 1 is a true and correct copy of Apple Inc. v. Arendi S.A.R.L.
`
`IPR2014-00208, Paper No. 1 (P.T.A.B. Dec. 2, 2013) (Petition for Inter Partes Review of ’843)
`
`produced by Defendants as FOX_0009000 - FOX_0009060.
`
`1
`
`

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`Case 1:13-cv-00919-LPS Document 306 Filed 03/10/21 Page 2 of 14 PageID #: 24391
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`4.
`
`Attached as Exhibit 2 is a true and correct copy of Motorola Mobility LLC v. Arendi
`
`S.A.R.L. IPR2014-00203, Paper No. 3 (P.T.A.B. Dec. 2, 2013) (Petition for Inter Partes Review
`
`or ’993 Patent) produced by Defendants as FOX_0012183 – FOX_0012246.
`
`5.
`
`Attached as Exhibit 3 is a true and correct copy of Apple Inc. v. Arendi S.A.R.L.
`
`IPR2014-00206, Paper No. 3 (P.T.A.B. Dec. 2, 2013) (Petition for Inter Partes Review of ’854
`
`Patent) produced by Defendants as FOX_0009888 – FOX_0009951.
`
`6.
`
`Attached as Exhibit 4 is a true and correct copy of Apple Inc. v. Arendi S.A.R.L.
`
`IPR2014-00207, Paper No. 3 (P.T.A.B. Dec. 2, 2013) (Petition for Inter Partes Review of ’854
`
`Patent) produced by Arendi as ARENDI 199613 – ARENDI 199675.
`
`7.
`
`Attached as Exhibit 5 is a true and correct copy of Google Inc. v. Arendi S.A.R.L.
`
`IPR2014-00450, Paper No. 1 (P.T.A.B. Feb. 20, 2014) (Petition for Inter Partes Review of ’356
`
`Patent) produced by Arendi as FOX_0008130 – FOX_0008194.
`
`8.
`
`Attached as Exhibit 6 is a true and correct copy of Google Inc. v. Arendi S.A.R.L.
`
`IPR2014-00452, Paper No. 1 (P.T.A.B. Feb. 21, 2014) (Petition for Inter Partes Review of ’853
`
`Patent) produced by Arendi as ARENDI 148048 – ARENDI 148110.
`
`9.
`
`Attached as Exhibit 7 is a true and correct copy of Apple Inc. v. Arendi S.A.R.L.
`
`IPR2014-00208, Paper No. 8 (P.T.A.B. June 9, 2015) (Decision to Institute for ’843 Patent)
`
`produced by produced by Arendi as ARENDI 210101 – ARENDI 210120.
`
`10.
`
`Attached as Exhibit 8 is a true and correct copy of Apple Inc. v. Arendi S.A.R.L.
`
`IPR2014-00208, Paper No. 33 (P.T.A.B. June 9, 2015) (Final Written Decision for ’843 Patent)
`
`produced by Arendi as ARENDI 209923 – ARENDI 209938.
`
`
`
`2
`
`

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`Case 1:13-cv-00919-LPS Document 306 Filed 03/10/21 Page 3 of 14 PageID #: 24392
`
`11.
`
`Attached as Exhibit 9 is a true and correct copy of the Expert Report of Edward
`
`Fox, Ph.D. on the Invalidity of U.S. Patent No. 7,917,843 served by Google LLC and Motorola
`
`Mobility LLC (collectively, “Defendants”) on August 7, 2020.
`
`12.
`
`Attached as Exhibit 10 is a true and correct copy of the Reply Expert Report of
`
`Edward Fox, Ph.D. on the Invalidity of U.S. Patent No. 7,917,843 served by Defendants on
`
`December 4, 2020.
`
`13.
`
`Attached as Exhibit 11 is a true and correct copy of U.S. Patent No. 7,917,843,
`
`produced by Arendi in this litigation as AHL0118048 - AHL0118078.
`
`14.
`
`Lodged with the Court as Exhibit 12 is a true and correct copy of ARENDI100002,
`
`which is a copy of a CD-ROM containing part 1 of 2 of the file wrapper for the ’843 Patent. The
`
`copied CD-ROM was obtained by Arendi from the United States Patent and Trademark Office.
`
`Arendi produced ARENDI100002 to Defendants on August 27, 2013.
`
`15.
`
`Attached as Exhibit 13 is a true and correct copy of the sealed certificate from the
`
`United States Patent and Trademark Office in conjunction with Exhibit 12 and certifying the
`
`original of Exhibit 12 as a true copy and produced by Arendi to Defendants as ARENDI100001
`
`on August 27, 2013.
`
`16.
`
`Attached as Exhibit 14 is a true and correct copy of the document titled
`
`“CyberDesk: A Framework for Providing Self-Integrating Ubiquitous Software Services” with the
`
`citation GVU Technical Report, GIT-GVU-97-10, produced by Arendi to Defendants as
`
`AHL0122266 – AHL0122283 on October 18, 2013.
`
`17.
`
`Attached as Exhibit 15 is a true and correct copy of the document titled
`
`“CyberDesk: Automated Integration of Desktop and Network Services” with the citation CHI ’97
`
`Note, produced by Arendi to Defendants as AHL0122288 – AHL0122292 on October 18, 2013.
`
`
`
`3
`
`

`

`Case 1:13-cv-00919-LPS Document 306 Filed 03/10/21 Page 4 of 14 PageID #: 24393
`
`18.
`
`Attached as Exhibit 16 is a true and correct copy of the document titled “Context-
`
`awareness in wearable and ubiquitous computing” with the citation GVU Technical Report GIT-
`
`GVU-97-11, produced by Arendi to Defendants as AHL0145938– AHL0145950 on October 18,
`
`2013.
`
`19.
`
`Attached as Exhibit 17 is a true and correct copy of the document titled
`
`“CyberDesk: a framework for providing self-integrating context-aware services” with the citation
`
`Knowledge-Based Systems 11 (1998) 3 - 13, produced by Arendi to Defendants as AHL0121553
`
`– AHL0121563 on October 18, 2013.
`
`20.
`
`Attached as Exhibit 18 is a true and correct copy of the document titled “Applying
`
`Dynamic Integration as a Software Infrastructure for Context-Aware Computing” produced by
`
`Arendi to Defendants as AHL0122306 – AHL0122315 on October 18, 2013.
`
`21.
`
`Attached as Exhibit 19 is a true and correct copy of the document titled “Context-
`
`Aware Computing: The CyberDesk Project” produced by Defendants in this litigation as
`
`ARENDI-DEFS00021056 - ARENDI-DEFS00021058.
`
`22.
`
`Attached as Exhibit 20 is a true and correct copy of the document titled “Future
`
`Computing Environments: CyberDesk,” produced by Defendants in this litigation as ARENDI-
`
`DEFS00021090 - ARENDI-DEFS00021091.
`
`23.
`
`Attached as Exhibit 21 is a true and correct copy of the document titled
`
`“CyberDesk: A Framework for Providing Self-Integrating Context-Aware Services” produced by
`
`Defendants in this litigation as FOX_006473 - FOX_006488.
`
`24.
`
`Attached as Exhibit 22 is a true and correct copy of the document titled
`
`“CyberDesk: A Framework for Providing Self-Integrating Ubiquitous Software Services”
`
`
`
`4
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`

`

`Case 1:13-cv-00919-LPS Document 306 Filed 03/10/21 Page 5 of 14 PageID #: 24394
`
`produced by Defendants
`
`in this
`
`litigation as ARENDI- DEFS00001151 - ARENDI-
`
`DEFS00001160.
`
`25.
`
`Attached as Exhibit 23 is a true and correct copy of the Joint Initial Invalidity
`
`Contentions of Defendants LG Electronics Inc.., LG Electronics USA, Inc. and LG Electronics
`
`Mobilecomm U.S.A., Inc.; Blackberry Limited and Blackberry Corporation; Nokia Corporation
`
`and Nokia Inc.; HTC Corp. a/k/a High Tech Computer Corp, HTC America, Inc., and Exedea,
`
`Inc.; Motorola Mobility LLC, f/k/a Motorola Mobility Inc.; Sony Mobile Communications (USA)
`
`Inc. f/k/a Sony Ericsson Mobile Communications (UYSA) Inc., Sony Corporation, and Sony
`
`Corporation of America; Google Inc.; and Yahoo! Inc. (“Initial Invalidity Contentions”) served by
`
`Defendants in this litigation on January 17, 2014.
`
`26.
`
`Attached as Exhibit 24 is a true and correct copy of Exhibit B-10 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`27.
`
`Attached as Exhibit 25 is a true and correct copy of Exhibit B-14 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`28.
`
`Attached as Exhibit 26 is a true and correct copy of Exhibit C-7 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`29.
`
`Attached as Exhibit 27 is a true and correct copy of Exhibit C-8 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`30.
`
`Attached as Exhibit 28 is a true and correct copy of Exhibit C-10 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`31.
`
`Attached as Exhibit 29 is a true and correct copy of Exhibit C-11 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`
`
`5
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`

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`Case 1:13-cv-00919-LPS Document 306 Filed 03/10/21 Page 6 of 14 PageID #: 24395
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`32.
`
`Attached as Exhibit 30 is a true and correct copy of Exhibit C-31 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`33.
`
`Attached as Exhibit 31 is a true and correct copy of Exhibit C-32 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`34.
`
`Attached as Exhibit 32 is a true and correct copy of Exhibit C-33 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`35.
`
`Attached as Exhibit 33 is a true and correct copy of Exhibit C-42 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`36.
`
`Attached as Exhibit 34 is a true and correct copy of Exhibit C-53 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`37.
`
`Attached as Exhibit 35 is a true and correct copy of Exhibit G to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`38.
`
`Attached as Exhibit 36 is a true and correct copy of pages 1-3, 16-17, 28, 30-33, 82
`
`and 272 of the transcript of the Deposition of Anind Dey, dated November 12, 2019.
`
`39.
`
`Attached as Exhibit 37 is a true and correct copy of the Joint Amended Invalidity
`
`Contentions of Defendants LG Electronics Inc., LG Electronics USA, Inc. and LG Electronics
`
`Mobilecomm U.S.A., Inc.; Blackberry Limited And Blackberry Corporation; Microsoft Mobile,
`
`Inc. (f/k/a Nokia Inc.); Motorola Mobility LLC, f/k/a Motorola Mobility Inc.; Sony Mobile
`
`Communications (USA) Inc. f/k/a Sony Ericsson Mobile Communications (USA) Inc., Sony
`
`Corporation, and Sony Corporation of America; Google LLC; Oath Holdings Inc.; Apple Inc.; and
`
`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (“Joint Amended Invalidity
`
`Contentions”) served by Defendants in this litigation on March 27, 2019.
`
`
`
`6
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`

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`Case 1:13-cv-00919-LPS Document 306 Filed 03/10/21 Page 7 of 14 PageID #: 24396
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`40.
`
`Attached as Exhibit 38 is a true and correct copy of Exhibit C-7A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`41.
`
`Attached as Exhibit 39 is a true and correct copy of Exhibit C-11A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`42.
`
`Attached as Exhibit 40 is a true and correct copy of Exhibit C-22A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`43.
`
`Attached as Exhibit 41 is a true and correct copy of Exhibit C-27A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`44.
`
`Attached as Exhibit 42 is a true and correct copy of Exhibit C-26A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`45.
`
`Attached as Exhibit 43 is a true and correct copy of Exhibit C-29A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`46.
`
`Attached as Exhibit 44 is a true and correct copy of Exhibit C-33A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`47.
`
`Attached as Exhibit 45 is a true and correct copy of Exhibit C-36A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`48.
`
`Attached as Exhibit 46 is a true and correct copy of Exhibit C-73 to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`49.
`
`Attached as Exhibit 47 is a true and correct copy of Exhibit E-57 to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`50.
`
`Attached as Exhibit 48 is a true and correct copy of Google LLC’s Subpoena to
`
`Anind Dey, dated and served on Arendi on September 13, 2019.
`
`
`
`7
`
`

`

`Case 1:13-cv-00919-LPS Document 306 Filed 03/10/21 Page 8 of 14 PageID #: 24397
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`51.
`
`Attached as Exhibit 49 is a true and correct copy of Motorola Mobility LLC’s
`
`Subpoena to Anind Dey, dated and served on Arendi on September 13, 2019.
`
`52.
`
`Attached as Exhibit 50 is a true and correct copy of Google LLC’s Subpoena to
`
`Georgia Institute of Technology, dated and served on Arendi on August 13, 2019.
`
`53.
`
`Attached as Exhibit 51 is a true and correct copy of Motorola Mobility LLC’s
`
`Subpoena to Georgia Institute of Technology, dated and served on Arendi on August 13, 2019.
`
`54.
`
`Attached as Exhibit 52 is a true and correct copy of the document titled “Applying
`
`Dynamic Integration as a Software Infrastructure for Context-Aware Computing” produced by
`
`Defendants in this litigation as ARENDI- DEFS00021045 - ARENDI- DEFS00021050.
`
`55.
`
`Attached as Exhibit 53 are true and correct copies of the documents titled “From
`
`Documents to Objects: An Overview of LiveDoc” and “Drop Zones: An Extension of LiveDoc”
`
`produced by Defendants
`
`in
`
`this
`
`litigation as ARENDI-DEFS00003076 – ARENDI-
`
`DEFS00003095.
`
`56.
`
`Attached as Exhibit 54 is a true and correct copy of the document titled
`
`“Collaborative Programmable Intelligent Agents” (Nardi) produced by Defendants in this
`
`litigation as ARENDI-DEFS00003329 – ARENDI-DEFS00003337.
`
`57.
`
`Attached as Exhibit 55 is a true and correct copy of the document titled “Drop
`
`Zones: An Extension to LiveDoc” produced by Defendants in this litigation as ARENDI-
`
`DEFS00000642 – ARENDI-DEFS00000646.
`
`58.
`
`Attached as Exhibit 56 is a true and correct copy of the document titled “Apple
`
`Data Detectors User’s Manual” produced by Arendi to Defendants as AHL0120682 –
`
`AHL0120697 on October 18, 2013.
`
`
`
`8
`
`

`

`Case 1:13-cv-00919-LPS Document 306 Filed 03/10/21 Page 9 of 14 PageID #: 24398
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`59.
`
`Attached as Exhibit 57 is a true and correct copy of the document titled “Apple
`
`Internet Address Detectors User’s Manual” produced by Arendi to Defendants as AHL0123031 –
`
`AHL0123046 on October 18, 2013.
`
`60.
`
`Attached as Exhibit 58 is a true and correct copy of the document titled
`
`“Developer’s Guide to Apple Data Detectors” produced by Arendi to Defendants as AHL0124440
`
`– AHL0124473 on October 18, 2013.
`
`61.
`
`Attached as Exhibit 59 is a true and correct copy of the document referenced as
`
`Apple Data Detectors Webpages and produced by Arendi to Defendants as AHL0135930 –
`
`AHL0135944 on October 18, 2013.
`
`62.
`
`Attached as Exhibit 60 is a true and correct copy of the document titled “Claris
`
`Em@iler Getting Started” produced by Arendi to Defendants as AHL0140270 – AHL0140334 on
`
`October 18, 2013.
`
`63.
`
`Attached as Exhibit 61 is a true and correct copy of the document titled “Apple
`
`Introduces Internet Address Detectors” produced by Arendi to Defendants as AHL0114770 –
`
`AHL0114773 on October 18, 2013.
`
`64.
`
`Attached as Exhibit 62 is a true and correct copy of the document titled
`
`“MessagePad 2000 User’s Manual” produced by Defendants in this litigation as ARENDI-
`
`DEFS00004995 – ARENDI-DEFS00005285.
`
`65.
`
`Attached as Exhibit 63 is a true and correct copy of the document titled “Newton
`
`2.0 User Interface Guidelines” produced by Defendants in this litigation as ARENDI-
`
`DEFS00003338 – ARENDI-DEFS00003644.
`
`
`
`9
`
`

`

`Case 1:13-cv-00919-LPS Document 306 Filed 03/10/21 Page 10 of 14 PageID #: 24399
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`66.
`
`Attached as Exhibit 64 is a true and correct copy of the document titled “Newton
`
`Programmer’s Guide” produced by Defendants in this litigation as ARENDI-DEFS00003649 –
`
`ARENDI-DEFS00004590.
`
`67.
`
`Attached as Exhibit 65 is a true and correct copy of the document tilted “Review:
`
`Eudora Pro 3.0” produced by Defendants in this litigation as ARENDI-DEFS00014105 -
`
`ARENDI-DEFS00014111.
`
`68.
`
`Attached as Exhibit 66 is a true and correct copy of the document tilted “Eudora
`
`Mail Pro: Version 3.0 for Windows User Manual” produced by Arendi in this litigation as
`
`ARENDI315568 – ARENDI 315722.
`
`69.
`
`Attached as Exhibit 67 is a true and correct copy of the document tilted “Eudora
`
`Mail Pro: Version 3.1 for Macintosh User Manual” produced by Arendi in this litigation as
`
`AHL0154945 – AHL0155143 on October 18, 2013.
`
`70.
`
`Attached as Exhibit 68 is a true and correct copy of the document tilted “Special
`
`Edition Using Microsoft Word 97,” ch. 17 “Mastering Envelopes, Mail Merge, and Form Letters”
`
`produced by Arendi in this litigation as AHL0194629 – AHL0194667.
`
`71.
`
`Attached as Exhibit 69 is a true and correct copy of the document titled “Getting
`
`Results with Microsoft Office 97,” produced by Apple in this litigation as ARENDI-
`
`DEFS00001442 - ARENDI-DEFS00002143.
`
`72.
`
`Attached as Exhibit 70 is a true and correct copy of the document titled “Using
`
`Microsoft Outlook 97, Special Edition” produced by Arendi in this litigation as ARENDI 203925
`
`– ARENDI 204221.
`
`
`
`10
`
`

`

`Case 1:13-cv-00919-LPS Document 306 Filed 03/10/21 Page 11 of 14 PageID #: 24400
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`73.
`
`Attached as Exhibit 71 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 6,085,201, produced by Arendi in this litigation as
`
`AHL0125164 - AHL0125173 on October 18, 2013.
`
`74.
`
`Attached as Exhibit 72 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 6,377,965, produced by Arendi in this litigation as
`
`AHL0120123 - AHL0120140 on October 18, 2013.
`
`75.
`
`Attached as Exhibit 73 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 5,392,386, produced by Arendi in this litigation as
`
`ARENDI 7985 – ARENDI 8001 on October 18, 2013.
`
`76.
`
`Attached as Exhibit 74 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 5,392,386, produced by Arendi in this litigation as
`
`ARENDI 11243 - ARENDI 11259 on October 18, 2013.
`
`77.
`
`Attached as Exhibit 75 is a true and correct copy of the document tilted “The
`
`Selection Recognition Agent: Instant Access to Relevant Information and Operations” produced
`
`by Defendants in this litigation as ARENDI-DEFS00008664 - ARENDI-DEFS00008669.
`
`78.
`
`Attached as Exhibit 76 is a true and correct copy of the document titled “The
`
`Selection Recognition Agent: Instant Access to Relevant Information and Operations” produced
`
`by Arendi to Defendants as AHL0122361– AHL0122366 on October 18, 2013.
`
`79.
`
`Attached as Exhibit 77 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 5,477,447 produced by Defendants in this litigation as
`
`ARENDI-DEFS00009411 - ARENDI-DEFS00009440.
`
`
`
`11
`
`

`

`Case 1:13-cv-00919-LPS Document 306 Filed 03/10/21 Page 12 of 14 PageID #: 24401
`
`80.
`
`Attached as Exhibit 78 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 5,644,735 produced by Defendants in this litigation as
`
`FOX_0012496 - FOX_0012524.
`
`81.
`
`Lodged with the Court as Exhibit 79 is a true and correct copy of ARENDI-
`
`DEFS00000001, which contains the video files ADD-2xcdrom.avi, ADD-720x480.mov, ADD-
`
`DSLmedium.mov, and Data Detectors @ MW ’96.mov.
`
`82.
`
`Lodged with the Court as Exhibit 80 is a true and correct copy of ARENDI-
`
`DEFS00021315, produced by Defendants in this litigation.
`
`83.
`
`Attached as Exhibit 81 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 5,946,647, produced by Defendants in this litigation as
`
`ARENDI-DEFS00010281 - ARENDI-DEFS00010296.
`
`84.
`
`Attached as Exhibit 82 is a true and correct copy of the transcript of the Deposition
`
`of Jim Miller in the above-captioned cases, dated October 16, 2016.
`
`85.
`
`Attached as Exhibit 83 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 5,859,636, produced by Defendants in this litigation as
`
`ARENDI-DEFS00010090 - ARENDI-DEFS00010105.
`
`86.
`
`Exhibit 84 is intentionally blank.
`
`87.
`
`Attached as Exhibit 85 is a true and correct copy of the document titled “Apple
`
`Introduces Internet Address Detectors” produced by Defendants in this litigation as ARENDI-
`
`DEFS00000623 - ARENDI-DEFS00000627.
`
`88.
`
`Attached as Exhibit 86 is a true and correct copy of the document titled “US
`
`Geographic Detectors Read Me.txt,” produced by Defendants in this litigation as ARENDI-
`
`DEFS00011455 - ARENDI-DEFS00011456.
`
`
`
`12
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`

`

`Case 1:13-cv-00919-LPS Document 306 Filed 03/10/21 Page 13 of 14 PageID #: 24402
`
`89.
`
`Attached as Exhibit 87 is a true and correct copy of Nardi et al, “Collaborative
`
`Programmable Intelligent Agents,” produced by Arendi in this litigation as AHL0125017 –
`
`AHL0125025 on October 18, 2013.
`
`90.
`
`Attached as Exhibit 88 is a true and correct copy of the deposition transcript of Atle
`
`Hedløy in this litigation, dated October 29, 2019.
`
`91.
`
`Attached as Exhibit 89 is a true and correct copy of the deposition transcript of Atle
`
`Hedløy in this litigation, dated October 30, 2019.
`
`92.
`
`Attached as Exhibit 90 is a true and correct copy of the deposition transcript of Atle
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`Hedløy in this litigation, dated November 5, 2019.
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`93.
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`Attached as Exhibit 91 is a true and correct copy of the deposition transcript of Atle
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`Hedløy in this litigation, dated November 6, 2019.
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`94.
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`Attached as Exhibit 92 is a true and correct copy of the deposition transcript of Atle
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`Hedløy in this litigation, dated November 7, 2019.
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`95.
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`Attached as Exhibit 93 is a true and correct copy of the production email sent by
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`Arendi to Defendants on August 27, 2013 with ARENDI 100001 - ARENDI 100007 and ARENDI
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`100015 - ARENDI 100018.
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`96.
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`Attached as Exhibit 94 is a true and correct copy of the production email sent by
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`Arendi to Defendants on October 18, 2013 with AHL 000001 – AHL 197687, ARENDI 000001 –
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`ARENDI 17167, and ARENDI 100019 – ARENDI 100024.
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`97.
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`Attached as Exhibit 95 is a true and correct copy of the document titled “List of
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`Patents and Publications for Applicant’s Corrected and Supplemental Information Disclosure
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`Statement,” produced by Arendi in this litigation as AHL0165305 - AHL0165327 on October 18,
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`2013.
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`13
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`Case 1:13-cv-00919-LPS Document 306 Filed 03/10/21 Page 14 of 14 PageID #: 24403
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`98.
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`Attached as Exhibit 96 is a true and correct copy of pages 1, 88, 118, and 248 of
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`the deposition transcript of Frank Casanova, dated September 25, 2019.
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`99.
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`Attached as Exhibit 97 is a true and correct PDF copy of the “Assignments” page
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`of the Public Patent Application Information Retrieval (“Public PAIR”) webpage of the United
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`States Patent and Trademark Office for U.S. Patent No. 5,784,001, accessed March 5, 2021.
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`I declare under penalty of perjury under the laws of the United States that the foregoing is
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`true and correct and that this declaration was executed on March 5, 2021.
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`/s/______________________
`Seth Ard
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`14
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