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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`Plaintiff,
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`Defendant.
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` )
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`ALMONDNET, INC.,
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`v.
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`OATH HOLDINGS INC.,
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`Civil Action No. 18-cv-943-CFC-SRF
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`DECLARATION OF LOUIS J. HOFFMAN IN SUPPORT OF
`PLAINTIFF ALMONDNET’S
`RESPONSE TO OATH HOLDINGS’S MOTION TO DISMISS
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`I, Louis J. Hoffman, do hereby declare:
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`1.
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`I am a partner with the law firm of Louis J. Hoffman, P.C. (also known as
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`Hoffman Patent Firm). I am an attorney in good standing licensed to practice law in the
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`State of Arizona, and admitted to practice pro hac vice in the United States District Court
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`for the District of Delaware as counsel to plaintiff AlmondNet, Inc. in this action.
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`2.
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`I am also admitted to practice pro hac vice in the United States District
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`Court for the Eastern District of New York, No. 16-cv-01557-ILG-SMG, as counsel to
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`the plaintiffs AlmondNet, Inc., Datonics, LLC and Intent IQ, LLC (“the New York
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`action”). I make this declaration upon my own personal knowledge.
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`3.
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`Attached as Exhibit 1 is a true and correct copy of the transcript of a
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`hearing on September 29, 2016, at which I appeared for oral argument on behalf of
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`plaintiff on Yahoo’s motion to dismiss the New York action.
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`4.
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`Attached as Exhibit 2 is a true and correct copy of the public version of
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`two infringement charts that I served on Yahoo in April 2017 the New York action as
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`AlmondNet’s contentions with respect to certain patents that are at issue in the New York
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`action and parents to the MPS and OTA patents in suit in this Delaware case. Although
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`1
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`Case 1:18-cv-00943-RGA Document 15 Filed 09/14/18 Page 2 of 2 PageID #: 171
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`the patents are not precisely the same, in that they have different claims, each of the
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`patents in suit are related to the respective parent patents, including sharing common
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`written specifications and having overlap of many claim elements. AlmondNet also
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`served supplemental infringement contentions for the MPS and OTA patents in suit
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`I declare under penalty of perjury that the foregoing is true and correct. Executed
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`this 14th day of September, 2018, in Scottsdale, Arizona.
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`Louis J. Hoffman
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`2
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`
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