Case 1:19-cv-01410-MN Document 271 Filed 10/31/23 Page 1 of 12 PageID #: 10820
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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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`
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`
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`Plaintiff,
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`v.
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`AMAZON.COM SERVICES LLC,
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`Defendant.
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`C.A. No. 1:19-cv-01410-MN
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`REDACTED
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`DECLARATION OF MELANIE GENS
`
`ASHBY & GEDDES
`Steven J. Balick (#2114)
`Andrew C. Mayo (#5207)
`500 Delaware Avenue, 8th Floor
`P.O. Box 1150
`Wilmington, DE 19899
`(302) 654-1888
`sbalick@ashbygeddes.com
`amayo@ashbygeddes.com
`
`Attorneys for Defendants
`
`Of Counsel:
`
`J. David Hadden, CSB No. 176148
`Email: dhadden@fenwick.com
`Saina S. Shamilov, CSB No. 215636
`Email: sshamilov@fenwick.com
`Ravi R. Ranganath, CSB No. 272981
`rranganath@fenwick.com
`Vigen Salmastlian, CSB No. 276846
`Email: vsalmastlian@fenwick.com
`FENWICK & WEST LLP
`Silicon Valley Center
`801 California Street
`Mountain View, CA 94041
`Telephone: 650.988.8500
`Facsimile: 650.938.520
`
`Dated: October 29, 2023
`
`

`

`Case 1:19-cv-01410-MN Document 271 Filed 10/31/23 Page 2 of 12 PageID #: 10821
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`VB ASSETS, LLC,
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`Plaintiff,
`
`v.
`
`AMAZON.COM SERVICES LLC,
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`Defendant.
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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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`On September 20, 2023, Amazon published on its website an article by Daniel
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`Rauch, Vice President, Alexa and Fire TV, titled “Previewing the future of Alexa.” The article
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`includes a video “shar[ing] an early preview” of a future version of Alexa “based on a new large
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`language model (LLM) . . . .” Mr. Rauch noted that the announcement marked “the start of a
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`journey—a foundation that we believe will lead to a new version of Alexa powered by generative
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`AI.” A true and correct copy of this article is attached hereto as Exhibit A.
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`3.
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`I am part of a team of Alexa engineers that worked on the LLM system referenced
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`in this article.
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`1
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`

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`Case 1:19-cv-01410-MN Document 271 Filed 10/31/23 Page 3 of 12 PageID #: 10822
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`4.
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`The LLM system is a new generative AI Alexa system that once released, will be
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`invoked in certain smart home use cases, search requests on Fire TVs, and as part of a new “Alexa,
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`let’s chat” feature.
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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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`27th
`true and correct, and that this declaration was executed on this _____ 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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`10/27/2023
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`

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`Case 1:19-cv-01410-MN Document 271 Filed 10/31/23 Page 4 of 12 PageID #: 10823
`Case 1:19-cv-01410-MN Document 271 Filed 10/31/23 Page 4 of 12 PagelD #: 10823
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`EXHIBIT A
`EXHIBIT A
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`News / Devices
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`Previewing the future of Alexa
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`beta]Cains] aUAPG)
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`SCa aetee ecoleeee
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`Case 1:19-cv-01410-MN Document 271 Filed 10/31/23 Page 5 of 12 PageID #: 10824
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`Page 1
`Amazon previews the future of Alexa with generative AI
`https: //www.aboutamazon.com/news/devices/amazon-alexa-generative-ai
`16:22 10-26-2023
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`amazon
`ee
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`fo]
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`WhoWeAre ~ WhatWeDo ~ OurWorkplace ~ Ourlmpact ~ OurPlanet ~
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`| olga
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`iN etaglecd ee
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`f ¥ &
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`Reading:
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`Previewingthefutureof
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`Hee
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`Yo
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`With generative AI bringing our north star
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`for Alexa within reach, we're previewing a
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`new large language model and a suite of
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`deliver an even moreintuitive, intelligent,
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`and useful Alexa.
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`Case 1:19-cv-01410-MN Document 271 Filed 10/31/23 Page 6 of 12 PageID #: 10825
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`Page 2
`Amazon previews the future of Alexa with generative AI
`https: //www.aboutamazon.com/news/devices/amazon-alexa-generative-ai
`16:22 10-26-2023
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`TRENDING STORIES
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`Amazonrolls out Al-
`powered image
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`generation to help
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`athvertisers deliver a
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`Every newdevice
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`2023—and all the new
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`devices coming soon
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`I'm an Amazon VP who's
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`grown with the company
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`for 12 years. Here are my
`top 5 leadership tips for
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`managers,
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`Seethe ‘Thursday Night
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`Football’
`schedulefor the
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`(eAsOn On
`2025 |
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`Prime Video
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`Over the last few years, we've often talked about how we'reliving ina
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`golden age of artificial intelligence (Al). Ideas that seemed like science
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`fiction not so long ago are now a reality—and there's no better example of
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`that than Alexa. What started as a sketch on a whiteboard has evolved into
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`an entirely new computing paradigm—one that has fundamentally
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`changed how people across the world interact with technology in their
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`homes. Having passed half a billion devices sold, and with tens of millions
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`of interactions every hour, Alexa has become part of the family in millions
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`of households. We've always thought of Alexa as an evolving service, and
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`we've been continuously improving it since the day we introduced it in
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`2014. A longstanding mission has been to make a conversation with Alexa
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`as natural as talking to another human, and with the rapid development
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`of generative Al, what we imagined is now well within reach. Today, we're
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`excited to share an early preview of what the future lookslike.
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`ie
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`Customers preview new Alexa capabilities | Amazon Ne...
`a
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`7
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`Ceeans
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`Watch on £3 Youlube
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`This is an early look at a smarter and more conversational Alexa, powered
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`by generative Al. It's based on a new large language model (LLM) that's
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`been custom-built and specifically optimized for voice interactions, and
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`efficient smart home control, and maximizing their home entertainment.
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`Webelieve this will drive the future of Alexa, enabling us to enhance five
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`foundational capabilities:
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`We've studied a lot about conversation in the last few years, and we know
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`that being conversational goes beyond words. In any conversation, we
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`process tons of additional information, such as body language, knowledge
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`of the person you're talking with, and eye contact. To enable that with
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`input, its ability to detect presence—with Al models that can understand
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`those non-verbal cues. We've also focused on reducing latency so
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`conversations flow naturally, without pause, and responses are the right
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`Case 1:19-cv-01410-MN Document 271 Filed 10/31/23 Page 7 of 12 PageID #: 10826
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`Page 3
`Amazon previews the future of Alexa with generative AI
`https: //www.aboutamazon.com/news/devices/amazon-alexa-generative-ai
`16:22 10-26-2023
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`length for voice—not the equivalent of listening to paragraph after
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`paragraph read aloud. Whenyou ask for the latest on a trending news
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`2. Real-world utility
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`Introducing a new era for the Alexa
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`smart home
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`Amazon advances home automation with new Alexa
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`experiences powered by generative Al, and newways to
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`control devices with Echo Hub and Map View
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`To be truly useful, Alexa has to be able to take action in the real world,
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`which has been one of the unsolved challenges with LLMs—howto
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`integrate APIs at scale and reliably invoke themto take the right actions.
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`This new Alexa LLM will be connected to hundreds of thousands ofreal-
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`world devices and services via APIs. It also enhances Alexa’s ability to
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`process nuance and ambiguity—muchlike a person would—and
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`intelligently take action. For example, the LLM gives you the ability to
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`program complex Routines entirely by voice—customers can just say,
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`“Alexa, every weeknight at 9 p.m., make an announcement that it’s bed
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`time for the kids, dim the lights upstairs, turn on the porch light, and
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`switch on the fan in the bedroom." Alexa will then automatically program
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`that series of actions to take place every night at 9 p.m.
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`3. Personalization and context
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`An LLM for the home has to be personalized to you, and your family. Just
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`as a conversation with another person would be shaped by context—such
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`as your previous conversations or the situational context—Alexa needs to
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`do the same. The next generation of Alexa will be able to deliver unique
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`experiences based on the preferences you've shared, the services you've
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`interacted with, and information about your environment. Alexa also
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`carries over relevant context throughout conversations, in the same way
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`that humans do all the time. People use pronouns, catchphrases, and build
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`up context of the places, times, or scenes we talk about. Ask Alexa a
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`question about a museum, and you'll be able to ask a series of follow-ups
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`about its hours, exhibits, and location without needing to restate any of
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`the prior context, like the name or the day you plan to go.
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`4. Personality
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`Case 1:19-cv-01410-MN Document 271 Filed 10/31/23 Page 8 of 12 PageID #: 10827
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`Page 4
`Amazon previews the future of Alexa with generative AI
`https: //www.aboutamazon.com/news/devices/amazon-alexa-generative-ai
`16:22 10-26-2023
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`Customers have told us time and again that they love Alexa's personality.
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`You don't want a rote, robotic companion in your home, and I'd argue
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`Alexa’s personality is one of the biggest reasons for Alexa’s broad
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`adoption. As we've alwayssaid, the most boring dinner party is one where
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`nobody has an opinion—and, with this new LLM, Alexa will have a point of
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`view, making conversations more engaging. Alexa can tell you which
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`movies should have won an Oscar, celebrate with you when you answer a
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`quiz question correctly, or write an enthusiastic note for you to send to
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`congratulate a friend on their recent graduation.
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`5. Trust
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`There should be no trade-off between trustworthiness and performance.
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`Customers around the world have welcomed Alexa into their home, and to
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`be truly useful in their daily lives, we must continue to create experiences
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`that they both love and trust. While the integration of generative Al brings
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`infinite new possibilities, our commitment to earning our customers’ trust
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`will not change. As with all our products, we will design experiences to
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`protect our customers’ privacy and security, and to give them control and
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`transparency.
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`a
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`services, and a suite of devices—and it's not limited to a tab in a browser.
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`And we're just getting started—with generative Al, we're also able to
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`enhance a number of core components of the Alexa experience.
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`Everything you need to know about
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`Explore with Alexa, Amazon's new
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`conversational feature for kids
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`Amazon's new Explore with Alexa is a conversational
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`experience for kids that combines entertaining facts and trivia questionsto fuel deepercuriosity and exploration.
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`Read more (> )
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`Case 1:19-cv-01410-MN Document 271 Filed 10/31/23 Page 9 of 12 PageID #: 10828
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`Page 5
`Amazon previews the future of Alexa with generative AI
`https: //www.aboutamazon.com/news/devices/amazon-alexa-generative-ai
`16:22 10-26-2023
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`One of these components is how customersstart an interaction with
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`Alexa. This will build on the experience that exists today by enabling
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`customers who choose to enroll in Visual ID to start a conversation with
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`Alexa simply by facing the screen on an Echo Show—no wake word
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`required. The result is the most natural conversation experience we've ever
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`built. Secondly, we built a whole new conversational speech recognition
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`conversation to gather our thoughts, or emphasize a point, and identifying
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`those cues is incredibly hard for an Al. This new CSR engine is capable of
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`adjusting to those commonnatural pauses and hesitation—enabling more
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`flowing, natural conversation. Finally, generative Al has enabled us to
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`enhanceour text-to-speech technology, using a large transformer model
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`to make Alexa much more expressive and attuned to conversational cues.
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`What this means is that Alexa will adapt to your cues and modulate its
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`response and tone akin to human conversations. Ask Alexa if your team
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`won, and it will respond in a joyful voice if so; if they lost, the responseis
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`more empathetic. Ask Alexa for an opinion, and the response will be more
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`enthusiastic, as it would if a friend was sharing a point of view.
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`To demonstrate how far we've come, here's a reminder of how Alexa
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`sounded when wefirst launched:
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`About Amazon© HowAlexa sounded whenwefirst 1...
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`hat
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`Alexa sounds
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`like today
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`And here is what Alexa will sound like early next year:
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`oY WhatAlexawill sound like early nex...
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`About Amazon»What Alexa will sound like in the not-too-distant future
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`Combined, these enhancementswill take whatis already the world’s best
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`personal Al, and make it even better.I've been using these new capabilities
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`over the past few months, and it feels just as transformative as the first
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`time | experienced talking to Alexa a decade or so ago. That's not to say
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`Case 1:19-cv-01410-MN Document 271 Filed 10/31/23 Page 10 of 12 PageID #: 10829
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`Page 6
`Amazon previews the future of Alexa with generative AI
`https: //www.aboutamazon.com/news/devices/amazon-alexa-generative-ai
`16:22 10-26-2023
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`it'll be perfect—Alexa will make mistakes—but,like it always has, the
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`experience will continue to get better over time.
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`We're at the start of a journey—a foundation that we believe will lead to a
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`new version of Alexa powered by generative Al. We'll continue to develop
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`and add more capabilities as part of a free preview, which will be available
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`to Alexa customers in the U.S. soon. We know customers will have lots of
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`feedback, and we can't wait to hear it.
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`Stay tuned for more. In the meantime, here is an early look at Alexa's new
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`capabilities.
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` —7 | AE
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`“Alexa, let's
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`Previewall-
`new Alexa
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`chat.”
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`Watch on (3 Youlube
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`Case 1:19-cv-01410-MN Document 271 Filed 10/31/23 Page 11 of 12 PageID #: 10830
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`Page 7
`Amazon previews the future of Alexa with generative AI
`https: //www.aboutamazon.com/news/devices/amazon-alexa-generative-ai
`16:22 10-26-2023
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`Case 1:19-cv-01410-MN Document 271 Filed 10/31/23 Page 12 of 12 PageID #: 10831
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`CERTIFICATE OF SERVICE
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`I hereby certify that on 29th day of October, 2023, the attached DECLARATION OF
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