`
`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
`
`Declaration of John V. Biernacki
`
`CLI-Zl46970vl
`
`Progressive Exhibit 2017
`Liberty Mutual V. Progressive
`
`CBM2012—00003
`
`
`
`Declaration of John V. Biernacki
`
`I, John V. Biernacki, make the following Declaration pursuant to 28 U.S.C.
`
`§ 1746:
`
`1.
`
`I am an attorney with the law firm Jones Day.
`
`2.
`
`I provide this Declaration in connection with the above-identified
`
`Covered Business Method Patent Review proceeding. Unless otherwise stated, the
`
`facts stated in this Declaration are based on my personal knowledge.
`
`3.
`
`Exhibit 2014 hereto is a true and correct copy of Progressive’s Exhibit
`
`2014 from the deposition of Mary L. O’Neil, which is a copy of a book chapter
`
`titled, “Automobile Insurance,” “North America,” authored by Mary L. O’Neil.
`
`4.
`
`Exhibit 2015 hereto is a true and correct copy of excerpted pages from
`
`the deposition transcript of Mary L. O’Neil dated September 13, 2013.
`
`5.
`
`Exhibit 2016 hereto is a true and correct copy of excerpted pages from
`
`the deposition transcript of Scott Andrews dated September 24, 2013.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
` Signature:
`
`John V Biernacki
`
`CLI-2146970v1
`
`
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