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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`VB ASSETS, LLC,
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`v.
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`Plaintiff,
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`AMAZON.COM SERVICES LLC,
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`Defendant.
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`
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`C.A. No. 1:19-cv-01410-MN
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`DECLARATION OF MELANIE GENS
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`I, Melanie Gens, hereby declare as follows:
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`1.
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`I am a Principal Software Engineer, Alexa AI-Natural Understanding, at
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`Amazon.com Services LLC (“Amazon”). I have personal knowledge of the facts stated in this
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`declaration and, if called upon to testify, could and would testify competently about them.
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`2.
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`I have reviewed my declaration dated October 27, 2023 (“Gens Decl.”). Paragraphs
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`3 and 4 of the Gens Decl. include sensitive and non-public information about Amazon’s large
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`language model (LLM) system. Specifically, Amazon has not publicly disclosed when
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`development of the LLM system began, the status of public release of the LLM system, the current
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`Alexa system components it may replace, and the substance of changes between the LLM system
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`and those components. See Gens Decl. at ¶¶ 3, 4.
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`3.
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`Disclosure of Amazon’s confidential information excerpted in the paragraph above
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`would harm Amazon and violate its interest in keeping the information private. The excerpts
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`reference fundamental operation of the next generation of Amazon’s cutting-edge and ubiquitous
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`“Alexa” service. They provide a peek behind the curtain of Amazon’s development of the future
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`1
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`Case 1:19-cv-01410-MN Document 264 Filed 10/30/23 Page 2 of 2 PageID #: 10732
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`LLM system, including when Amazon began its development. The excerpts also identify
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`differences between the new LLM system and Alexa’s present system. Public disclosure of these
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`valuable details would provide an unfair advantage to business competitors as they would gain
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`access to non-public information about the operation and development of the next generation of
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`Alexa.
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` I
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` 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 this 30th day of October in Honolulu,
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`Hawaii.
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`Melanie Gens
`Principal Software Engineer
`Amazon.com Services LLC
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`2
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