`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF DELAWARE
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`ALMONDNET, INC. and INTENT IQ,
`LLC,
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`
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`Plaintiffs,
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`v.
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`LINKEDIN, CORPORATION,
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`
`
`
`
`
`
`Defendant.
`
`
`
`
`C.A. No. 23-1373 (MN)
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`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
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`DECLARATION OF REZA MIRZAIE IN SUPPORT OF ALMONDNET’S RESPONSE
`BRIEF IN OPPOSITION TO LINKEDIN’S MOTION TO DISMISS
`
`
`
`Case 1:23-cv-01373-MN Document 16 Filed 03/04/24 Page 2 of 3 PageID #: 511
`
`I, Reza Mirzaie, declare and state as follows:
`
`1.
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`I am a member of the State Bar of California, an attorney at the firm of Russ
`
`August & Kabat, and counsel of record for Plaintiff AlmondNet, Inc. in the above-captioned
`
`action. I submit this declaration in support of AlmondNet’s Response Brief In Opposition To
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`LinkedIn’s Motion To Dismiss. I have personal knowledge of the facts set forth herein, and if
`
`called upon to testify, could and would testify competently thereto.
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`2.
`
`Attached as Exhibit A is a true and correct copy of a side-by-side comparison
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`between (1) claim 1 of the ’139 patent with claim 1 of the ’146 patent and (2) claim 1 of the
`
`’398 patent with claim 1 of the ’878 patent. This comparison is annotated with highlighting
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`demonstrating overlapping concepts.
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`3.
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`Attached as Exhibit B is a true and correct copy of Microsoft’s Form 10-K for
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`the fiscal year ended June 30, 2016. This document was downloaded from Microsoft’s
`
`collection
`
`of SEC Filings
`
`from
`
`its
`
`Investor Relations Page
`
`located
`
`at:
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`https://www.microsoft.com/en-us/Investor/sec-filings.aspx.
`
`4.
`
`Attached as Exhibit C is a true and correct copy of Microsoft’s Form 10-K for
`
`the fiscal year ended June 30, 2023. This document was downloaded from Microsoft’s
`
`collection
`
`of SEC Filings
`
`from
`
`its
`
`Investor Relations Page
`
`located
`
`at:
`
`https://www.microsoft.com/en-us/Investor/sec-filings.aspx.
`
`5.
`
`Attached as Exhibit D is a true and correct copy of LinkedIn’s Form 10-K for the
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`fiscal year ended December 31, 2015. This document was downloaded from EDGAR at:
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`https://www.sec.gov/edgar/browse/?CIK=1271024.
`
`6.
`
`Attached as Exhibit E is a true and correct copy of a Microsoft’s website
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`statement
`
`regarding
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`“Intellectual
`
`property
`
`and
`
`open
`
`innovation”
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`located
`
`at:
`
`
`
`i
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`
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`Case 1:23-cv-01373-MN Document 16 Filed 03/04/24 Page 3 of 3 PageID #: 512
`
`https://www.microsoft.com/en-us/legal/intellectualproperty. This document was generated via
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`Chrome’s “Save as PDF” feature.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed on March 4, 2024, at Los Angeles, California.
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`
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`
`
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`
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`/s/ Reza Mirzaie
`Reza Mirzaie
`
`
`
`ii
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