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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 16-454 (RGA)
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`DECLARATION OF RICARDO VALERDI, PH.D.
`IN SUPPORT OF PLAINTIFF ACCELERATION BAY LLC’S OPPOSITION TO
`DEFENDANT ELECTRONIC ARTS, INC.’S MOTIONS FOR SUMMARY JUDGMENT
`AND TO EXCLUDE EXPERT OPINIONS UNDER F.R.E. 702
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`Plaintiff,
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`v.
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`Defendant.
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`ACCELERATION BAY LLC,
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`ELECTRONIC ARTS, INC.
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`Case 1:16-cv-00454-RGA Document 468 Filed 04/13/18 Page 2 of 3 PageID #: 38456
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`I, Ricardo Valerdi, Ph.D., hereby declare as follows:
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`1.
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`I am an Associate Professor in the Systems and Industrial Engineering
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`Department at the University of Arizona, and have been retained by counsel for Plaintiff
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`Acceleration Bay, LLC (“Acceleration Bay”) to serve as an expert witness in the above-
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`captioned action.
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`2.
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`I submit this declaration in support of Acceleration Bay’s Opposition to
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`Defendant Electronic Arts, Inc.’s Motions for Summary Judgment and to Exclude Expert
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`Opinions (“Opposition”).
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`3.
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`Attached to Acceleration Bay’s Opposition is a true and correct copy of my
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`Expert Report Regarding Cost Estimates, dated October 6, 2017.
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`4.
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`I also understand that Acceleration Bay will submit a copy of its Opposition with
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`hyperlinks linking to complete true and accurate copy of the above report.
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`5.
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`I incorporate by reference the opinions set forth in my expert report in the above
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`referenced matter, and swear to their contents, as if fully set forth herein.
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`6.
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`The statements and opinions set forth in my expert report for this case are true and
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`accurate based on my personal knowledge and professional experience. My expert report also
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`accurately reflect the facts and circumstances described therein.
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`7.
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`I expect to testify at trial in this action regarding the opinions set forth in my
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`expert report, as well as on any other issues for which I have submitted or will submit an expert
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`report in this action.
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`Case 1:16-cv-00454-RGA Document 468 Filed 04/13/18 Page 3 of 3 PageID #: 38457
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`I declare under penalty of perjury of the laws of the United States that the foregoing is
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`true and correct to the best of my knowledge.
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`Executed this 13th day of April, 2018.
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`___________________
`Ricardo Valerdi, Ph.D.
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`- 2 -
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