`______________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`LIBERTY MUTUAL INSURANCE CO.
`Petitioner
`v.
`PROGRESSIVE CASUALTY INSURANCE CO.
`Patent Owner
`______________
`Case CBM2012-00004
`Patent 6,064,970
`______________
`Before the Honorable JAMESON LEE, JONI Y. CHANG, and MICHAEL R.
`ZECHER, Administrative Patent Judges.
`
`SECOND RULE 42.64(b)(2) DECLARATION OF MARY LOU O’NEIL ON
`BEHALF OF PETITIONER LIBERTY MUTUAL INSURANCE CO.
`REGARDING U.S. PATENT NO. 6,064,970
`
`I, Mary Lou O’Neil, hereby declare under penalty of perjury under the laws of
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`the United States of America:
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`I have previously been asked by Liberty Mutual Insurance (“Liberty”) to testify
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`as an expert witness in this action.
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`I.
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`Prior Testimony
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`1.
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`I am the same Mary Lou O’Neil who provided a Declaration in this
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`matter executed on September 14, 2012 as Exhibit 1011, a Rebuttal Declaration in
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`this matter executed on August 6, 2013 as Exhibit 1022, and a Rule 42.64(b)(2)
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`Declaration in this matter executed on August 27, 2013 as Exhibit 1025. (My
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`Liberty Mutual Exhibit 1027
`Liberty Mutual v. Progressive
`CBM2012-00004
`Page 00001
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`
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`Sep 18 13 09:27p
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`O'Neil Consulting Service
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`4128842402
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`p.2
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`information regarding experience, qualifications, and compensation has been provided
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`along with my Rebuttal Declaration, Exhibit 1011, and CV, Exhibit 1012.}
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`II.
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`Response to Evidentiarv Objections
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`2.
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`In my previous Rule 42.64fb) [2) Declaration, Exhibit 1025, I indicated
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`that “I was familiar with and have used Interpretive Opinion 4 found in Exhibit 1023
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`in my work on numerous occasions during the period in which it was in force.” Ex.
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`1025, 1] 4. Additionally, I was familiar with and have used Interpretive Opinion 3
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`found in the same exhibit. In my previous Rule 42.64(b) (2) Declaration, when I
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`stated that the hard copy of Interpretive Opinion 4 in my possession contains the
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`same substance, I meant that it contains the same words, but may contain slightly
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`different formatting.
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`Executed this 18th day of September, 2013
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`Page 00002
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`Page 00002
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