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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`14 Civ. 2396 (PGG)
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`14 Civ. 9558 (PGG)
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`NETWORK-1 TECHNOLOGIES, INC.,
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`Plaintiff,
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`v.
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`GOOGLE LLC and YOUTUBE, LLC,
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`Defendants.
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`DECLARATION OF AMY E. HAYDEN IN SUPPORT OF PLAINTIFF NETWORK-1
`TECHNOLOGIES, INC.’S OPENING CLAIM CONSTRUCTION BRIEF
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`Case 1:14-cv-02396-PGG-MHD Document 148-3 Filed 05/30/19 Page 2 of 4
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`I, Amy E. Hayden, declare as follows:
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`
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`1.
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`I am an attorney with Russ, August & Kabat, counsel for Network-1 Technologies,
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`Inc. in the above-captioned cases. I have personal knowledge of the facts states herein, and I could
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`and would competently testify to them if asked to as a witness.
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`2.
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`Attached as Exhibit 1 is a true and correct copy of United States Patent Number
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`8,010,988, dated August 30, 2011.
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`3.
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`Attached as Exhibit 2 is a true and correct copy of United States Patent Number
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`8,205,237, dated June 19, 2012.
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`4.
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`Attached as Exhibit 3 is a true and correct copy of United States Patent Number
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`8,904,464, dated December 2, 2014.
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`5.
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`Attached as Exhibit 4 is a true and correct copy of Richard O. Duda & Peter E. Hart,
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`Pattern Classification and Scene Analysis at 189-260 (Chapter 6, entitled “Unsupervised Learning
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`and Clustering”) (1973).
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`6.
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`Attached as Exhibit 5 is a true and correct copy of Keinosuke Fukunaga,
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`Introduction to Statistical Pattern Recognition at 508-63 (Chapter 11, entitled “Clustering”) (2d
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`ed. 1990).
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`7.
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`Attached as Exhibit 6 is a true and correct copy of Peter N. Yianilos, Excluded
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`Middle Vantage Point Forests for Nearest Neighbor Search, DIMACS Implementation Challenge:
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`Near Neighbor Searches Workshop (1999).
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`8.
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`Attached as Exhibit 7 is a true and correct copy of Peter N. Yianilos, Locally
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`Lifting the Curse of Dimensionality for Nearest Neighbor Search, Symposium on Discrete
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`Algorithms (SODA, 2000).
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`
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`1
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`Case 1:14-cv-02396-PGG-MHD Document 148-3 Filed 05/30/19 Page 3 of 4
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`9.
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`Attached as Exhibit 8 is a true and correct copy of excerpts from Paul C. Denny,
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`Search and Enumeration Techniques for Incidence Structures, CDMTCS Research Report Series
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`(1998).
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`10.
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`Attached as Exhibit 9 is a true and correct copy of excerpts from Jon Orwant et al.,
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`Mastering Algorithms with Perl (1999).
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`11.
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`Attached as Exhibit 10 is a true and correct copy of United States Patent Number
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`7,831,438, dated November 9, 2010.
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`12.
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`Attached as Exhibit 11 is a true and correct copy of United States Patent Number
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`8,065,733, dated November 22, 2011.
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`13.
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`Attached as Exhibit 12 is a true and correct copy of excerpts from Webster’s New
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`World Dictionary (3d ed.1994).
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`14.
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`Attached as Exhibit 13 is a true and correct copy of Orjan Carlborg et al., The Use
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`of a Genetic Algorithm for Simultaneous Mapping of Multiple Interacting Quantitative Trait Loci,
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`155 Genetics 2003-10 (2000).
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`15.
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`Attached as Exhibit 14 is a true and correct copy of Frederic Dufaux & Fabrice
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`Moscheni, Background Mosaicking for Low Bit Rate Video Coding, Proc. 3d IEEE Int’l
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`Conference on Image Processing (1996).
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`16.
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`Attached as Exhibit 15 is a true and correct copy of G.I. Robertson et al.,
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`Non-Exhaustive Search Methods and Their Use in the Minimization of Reed-Muller Canonical
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`Expansions, 80 Int. J. Electronics 1-12 (1996).
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`17.
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`Attached as Exhibit 16 is a true and correct copy of Sudhir Kumar, A Stepwise
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`Algorithm for Finding Minimum Evolution Trees, 13 Molecular Biology & Evolution 584-93
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`(1996).
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`2
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`Case 1:14-cv-02396-PGG-MHD Document 148-3 Filed 05/30/19 Page 4 of 4
`Case 1:14-cv-02396-PGG-MHD Document 148-3 Filed 05/30/19 Page 4 of 4
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`I declare under penalty of per} my that the forgoing is true and correct. Executed this 30th
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`day of May 2019 at Los Angeles, Caiifornia.
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`
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`Amy E. Hayden
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