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Case 1:14-cv-02396-PGG-SN Document 239-3 Filed 11/12/20 Page 1 of 3
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`Exhibit 21
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`Case 1:14-cv-02396-PGG-SN Document 239-3 Filed 11/12/20 Page 2 of 3
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`NETWORK-1 TECHNOLOGIES, INC.
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`Plaintiff,
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`14 Civ. 2396 (PGG-SN)
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`14 Civ. 9558 (PGG-SN)
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`- against -
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`GOOGLE LLC and YOUTUBE, LLC
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`Defendants.
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`1
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`Case 1:14-cv-02396-PGG-SN Document 239-3 Filed 11/12/20 Page 3 of 3
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`DECLARATION OF ERLING WOLD
`I, Erling Wold, declare as follows:
`1.
`I am the Executive Scientist at Audible Magic Corporation. I make this
`declaration in connection with documents produced by Audible Magic in this case.
`2.
`I am aware that older source code of Audible Magic, including Exhibits 10 and 11
`to my deposition, was restored from backup tapes in March 2013 in connection with a prior
`litigation pending at that time, Blue Spike LLC v. Audible Magic Corp. et al., Civil Action No.
`6:12-CV-576-LED (EDTX).
`3.
`I am aware that the same data restored from backup tapes in March 2013 was
`produced again in this case, Network-1 Technologies, Inc. v. Google LLC and YouTube LLC, 14
`Civ. 2396 (PGG-SN) and 14 Civ. 9558 (PGG-SN) (SDNY).
`4.
`I did not at any time make any alterations to any files restored from the backup
`tapes in March 2013, including but not limited to Exhibits 10 and 11 to my deposition.
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`I declare under penalty of perjury under the laws of the United States of America that the
`foregoing is true and correct to the best of my knowledge. Executed this __ day of October,
`12th
`2020, in San Francisco, California.
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`Erling Wold
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`2
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