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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`
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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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`
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`Plaintiff,
`
`- against -
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`GOOGLE LLC and YOUTUBE, LLC
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`Defendants.
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`DECLARATION OF SAMUEL BRYANT DAVIDOFF
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`I, Samuel Bryant Davidoff, hereby declare as follows:
`
`1.
`
`I am a partner at the law firm of Williams & Connolly LLP and counsel for
`
`Google LLC and YouTube, LLC in the above-captioned actions.
`
`2.
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`I make this declaration based on my personal knowledge and in support of
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`Defendants’ Response Claim Construction Brief.
`
`3.
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`Attached hereto as Exhibit A is a true and correct copy of U.S. Patent
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`No. 8,010,988.
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`4.
`
`Attached hereto as Exhibit B is a true and correct copy of U.S. Patent
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`No. 8,205,237.
`
`5.
`
`Attached hereto as Exhibit C is a true and correct copy of U.S. Patent
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`No. 8,904,464.
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`6.
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`Attached hereto as Exhibit D is a true and correct excerpt of the prosecution
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`history of U.S. Patent No. 8,010,988.
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`Case 1:14-cv-02396-PGG-MHD Document 153 Filed 06/28/19 Page 2 of 4
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`
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`7.
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`Attached hereto as Exhibit E is a true and correct excerpt of the prosecution
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`history of U.S. Patent No. 8,904,464.
`
`8.
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`Attached hereto as Exhibit F is a true and correct copy of U.S. Patent
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`No. 8,640,179.
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`9.
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`Attached hereto as Exhibit G is a true and correct copy of the Final Written
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`Decision (Paper No. 30) issued by the U.S. Patent and Trademark Office’s Patent Trial and
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`Appeal Board in Google Inc. v. Network-1 Technologies, Inc., Case No. IPR2015-00343.
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`10.
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`Attached hereto as Exhibit H is a true and correct copy of the Petition for Inter
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`Partes Review of U.S. Patent No. 8,640,179 (Paper No. 1) filed with the U.S. Patent and
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`Trademark Office’s Patent Trial and Appeal Board in Google Inc. v. Network-1 Technologies,
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`Inc., Case No. IPR2015-00343.
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`11.
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`Attached hereto as Exhibit I is a true and correct copy of the Brief of Cross-
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`Appellant and Appellee Network-1 Technologies, Inc. (ECF No. 30) filed with the U.S. Court of
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`Appeals for the Federal Circuit in Google Inc. v. Network-1 Technologies, Inc., Appeal
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`Nos. 2016-2509, 2016-2510, 2016-2511, and 2016-2512.
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`12.
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`Attached hereto as Exhibit J is a true and correct copy of the transcript of oral
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`argument before the U.S. Court of Appeals for the Federal Circuit held on December 4, 2017 in
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`Google Inc. v. Network-1 Technologies, Inc., Appeal Nos. 2016-2509, 2016-2510, 2016-2511,
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`and 2016-2512.
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`13.
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`Attached hereto as Exhibit K is a true and correct copy of the transcript of the
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`deposition of Professor Michael Mitzenmacher conducted on June 24, 2019.
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`2
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`Case 1:14-cv-02396-PGG-MHD Document 153 Filed 06/28/19 Page 3 of 4
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`
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`14.
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`Attached hereto as Exhibit L is a true and correct screenshot of the definitions of
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`the word “derive” on the webpage https://www.merriam-webster.com/dictionary/derive on June
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`28, 2019.
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`15.
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`Attached hereto as Exhibit M is a true and correct excerpt of Richard O. Duda and
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`Peter E. Hart, Pattern Classification and Scene Analysis (1973).
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`16.
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`Attached hereto as Exhibit N is a true and correct copy of U.S. Patent
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`No. 5,874,686.
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`17.
`
`Attached hereto as Exhibit O is a true and correct copy of Christian Böhm,
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`Bernhard Braunmüller, Hans-Peter Kriegel, and Matthias Schubert, Efficient Similarity Search in
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`Digital Libraries (2000).
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`18.
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`Attached hereto as Exhibit P is a true and correct excerpt of Philip A. LaPlante,
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`ed., Dictionary of Computer Science, Engineering, and Technology (2001).
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`19.
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`Attached hereto as Exhibit Q is a true and correct copy of Jürg Nievergelt,
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`Exhaustive Search, Combinatorial Optimization and Enumeration: Exploring the Potential of
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`Raw Computing Power (2000).
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`20.
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`Attached hereto as Exhibit R is a true and correct copy of Jon Louis Bentley,
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`Multidimensional Binary Search Trees Used for Associative Searching (1975).
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`21.
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`Attached hereto as Exhibit S is a true and correct screenshot of the definitions of
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`the word “calculate” on the webpage https://www.merriam-webster.com/dictionary/calculate on
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`June 28, 2019.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`3
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`Case 1:14-cv-02396-PGG-MHD Document 153 Filed 06/28/19 Page 4 of 4
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`Executed this 28th day of June, 2019.
`
`
` /s/ Samuel Bryant Davidoff
`Samuel Bryant Davidoff
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`4
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