`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`Case No.: 19-1410-MN
`
`)))))))))
`
`VB ASSETS, LLC,
`
`Plaintiff,
`
`v.
`
`AMAZON.COM, et al.,
`
`Defendants.
`
`DECLARATION OF NATHANIEL POLISH, PH.D. IN SUPPORT OF
`PLAINTIFF’S RESPONSES IN OPPOSITION TO AMAZON’S MOTIONS FOR
`SUMMARY JUDGMENT OF INVALIDITY AND NON-INFRINGEMENT
`
`I, Nathaniel Polish, Ph.D., declare the following:
`
`1.
`
`I submit this declaration in the above-identified action on behalf of Plaintiff VB
`
`Assets, LLC (“VoiceBox”).
`
`2.
`
`I have been asked to provide certain opinions in this litigation regarding issues
`
`related to infringement, validity, and other technical issues involving U.S. Patent Nos. 8,073,681
`
`(“the ’681 Patent”); 7,818,176 (“the ’176 Patent”); 8,886,536 (“the ’536 Patent”); 9,269,097 (“the
`
`’097 Patent”); and 9,626,703 (“the ’703 Patent”) (collectively, the “Patents-in-Suit” or “Asserted
`
`Patents”).
`
`3.
`
`In this litigation I prepared and provided the following reports:
`
` Opening Expert Report of Nathaniel Polish, Ph.D. (“Polish Opening Report”)
`
`(D.I. 190-1 Ex. 9);
`
` Rebuttal Expert Report of Nathaniel Polish, Ph.D. (“Polish Rebuttal Report”)
`
`(D.I. 190-1 Ex. 10); and
`
` Reply Expert Report of Nathaniel Polish, Ph.D. (“Polish Reply Report”) (D.I.
`
`190-1 Ex. 11).
`
`-1-
`
`
`
`Case 1:19-cv-01410-MN Document 204 Filed 03/03/23 Page 2 of 2 PageID #: 7781
`
`4.
`
`My statements and opinions in the Polish Opening Report, Polish Rebuttal Report,
`
`and Polish Reply Report are each true and correct to the best of my knowledge.
`
`I declare under penalty of perjury of the laws of the United States of America that the
`
`foregoing is true and correct. Executed this 3rd day of March 2023, in New York, New York.
`
`___________________________
`Nathaniel Polish, Ph.D.
`
`-2-
`
`
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