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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`LIBERTY MUTUAL INSURANCE CO.
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`Petitioner
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`V.
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`PROGRESSIVE CASUALTY INSURANCE CO.
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`Patent Owner
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`Case CBMZOIZ-OOOOZ (IL)
`Patent 6,064,970
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`Declaration of John V. Biernacki
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`Pll- I266693v]
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`Progressive Exhibit 2019
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`Liberty Mutual V. Progressive
`CBM 2012-00002
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`
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`Declaration of John V. Biernacki
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`I, John V. Biernacki, make the following Declaration pursuant to 28 U.S.C.
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`§ 1746:
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`1.
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`2.
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`I am an attorney with the law firm Jones Day.
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`I provide this Declaration in connection with the above-identified
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`Covered Business Method Patent Review proceeding. Unless otherwise stated, the
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`facts stated in this Declaration are based on my personal knowledge.
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`3.
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`Exhibit 2013 hereto is a true and correct copy of the deposition
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`transcript of Mary L. O’Neil.
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`4.
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`Exhibit 2018 hereto is a true and correct copy of the deposition
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`transcript of Scott Andrews.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Date: May 1, 2013
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`
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`I’ll-1266693“
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`