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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 CBM2012-00004
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`Patent 6,064,970
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`Declaration of John V. Biernacki
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`Progressive Exhibit 2023
`Liberty Mutual V. Progressive
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`CBM2012-00004
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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 2021 hereto is a true and correct copy of CBM2012-00003,
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`Progressive’s Exhibit 2014, CBM2013-00004, Progressive’s Exhibit 2018, and
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`CBM2013-00009, Progressive’s Exhibit 2027 from the deposition of Mary L.
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`O’Neil, which is a copy of a book chapter titled, “Automobile Insurance,” “North
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`America,” authored by Mary L. O’Neil.
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`4.
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`Exhibit 2022 hereto is a true and correct copy of excerpted pages from
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`the deposition transcript of Mary L. O’Neil dated September 13, 2013.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Date: Octoberl 20
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`Signature:
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`John V.
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`iemacki
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