`______________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`LIBERTY MUTUAL INSURANCE CO.
`Petitioner
`v.
`PROGRESSIVE CASUALTY INSURANCE CO.
`Patent Owner
`______________
`Case CBM2012-00003
`Patent 8,140,358
`______________
`Before the Honorable JAMESON LEE, JONI Y. CHANG, and MICHAEL R.
`ZECHER, Administrative Patent Judges.
`
`SECOND RULE 42.64(b)(2) DECLARATION OF SCOTT ANDREWS ON
`BEHALF OF PETITIONER LIBERTY MUTUAL INSURANCE CO.
`REGARDING U.S. PATENT NO. 8,140,358
`
`I, Scott Andrews, hereby declare under penalty of perjury under the laws of the
`
`United States of America:
`
`I have previously been asked by Liberty Mutual Insurance (“Liberty”) to testify
`
`as an expert witness in this action.
`
`I.
`
`Prior Testimony
`
`1.
`
`I am the same Scott Andrews who provided a Declaration in this matter
`
`executed on September 15, 2012 as Exhibit 1025, a Rebuttal Declaration in this
`
`matter executed on August 15, 2013 as Exhibit 1034, and a Rule 42.64(b)(2)
`
`Declaration in this matter executed on September 5, 2013 as Exhibit 1040. (My
`
`
`
`Liberty Mutual Exhibit 1042
`Liberty Mutual v. Progressive
`CBM2012-00003
`Page 00001
`
`
`
`
`
`information regarding experience, qualifications, and compensation has been provided
`
`along with my Declaration, Exhibit 1025, and CV, Exhibit 1026.)
`
`
`
`II. Response to Evidentiary Objections
`
`2.
`
`Exhibit 1038, the Declaration of Jordan M. Rossen, indicates Exhibit
`
`1037 was downloaded from The Apache Software Foundation website,
`
`http://www.apache.org/history/timeline.html. As I stated in my previous Rule
`
`42.64(b)(2) Declaration, The Apache Software Foundation is “a US 501(3)(c) non-
`
`profit corporation [that] provides organizational, legal, and financial support for a
`
`broad range of over 140 open source software projects,” including the Apache Server
`
`projects. Exhibit 1043, The Apache Software Foundation – Foundation Project,
`
`http://www.apache.org/foundation/. In my experience in the computer industry, I
`
`(and other experts) would reasonably rely on The Apache Software Foundation
`
`website as a source of accurate information related to the history of the Apache
`
`Server, and I have visited and consulted this website in the course of my work in this
`
`field.
`
`
`Executed this 26th day of September, 2013
`
`
`
`
`
` Scott Andrews
`
`
`At: Petaluma, CA
`
`
`
`
`
`Page 00002
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