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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`K—40 ELECTRONICS, LLC
`Petitioner
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`V.
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`ESCORT, INC.
`Patent Owner
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`Case IPR 2013-00240
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`US Patent No. 6,670,905
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`DECLARATION OF BETH ANDREWS
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`Mail Stop "PA TENT BOARD”
`Patent Trial and Appeal Board
`US. Patent and Trademark Office
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`PO. Box 1450
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`Alexandria, VA 22313- 1450
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`Escort Ex. 2053, pg. 1
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`Escort Ex. 2053, pg. 1
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`1.
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`I was employed at Cincinnati Microwave Inc. (“CMI”) from or about
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`1983 to or about December 1996. From or about 1993 to or about December 1996
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`I was a Product Manager at CMI.
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`2.
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`In or about 1996, I was involved with product planning at CMI. At
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`that time, it was important to marketing to have the CM] technical staff develop a
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`product to deal with the “falsing” issue, i.e., that solved the false alarm door opener
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`problem wherein a radar detector would render an alert from a non-police radar
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`emission. In other words, in 1996 CMI wanted to have a product that had less
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`“falsing” than other brands so we had a real need to figure out a way to deal with
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`“falsing.”
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`3.
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`Attached hereto as Exhibit 2050 is a true and correct copy of pages
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`from my 1996 “QUAD” calendar. More specifically, as shown therein and in a
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`true and correct excerpt therefrom that is reproduced herein, at or about 1 pm.
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`GEDT), Tuesday,
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` April 2, 1996, a
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`“Brainstorming”
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`‘ -' '-* L
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`meeting with
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`Greg Blair, Steve Orr, Tom Perszyk, and myself was held in Conference Room D
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`at CMI. During that meeting, I recorded notes on a whiteboard which had the
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`option to send those notes to a printer. Attached hereto as Exhibit 2051 is a true
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`Page 2 of 4
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`Escort Ex. 2053, pg. 2
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`Escort Ex. 2053, pg. 2
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`and correct copy of the printout from the whiteboard from that brainstorming
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`session. The printout includes my following handwritten notes:
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`(wringing? __._ wwww
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`ix. gag.
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`Thus, during this brainstorming session, I recorded that the “Next Product” would
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`include “GPS” and that it would have a “trainable auto-X source.” Exhibit 2051.
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`In other words, the goal was to have a device which one could train, by using
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`Global Positioning System (“GPS”) data, to automatically cancel (“X”) false radar
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`sources, i.e., sources of radar from other than actual police activities. Id.
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`4.
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`In the weeks thereafter, as further Shown in my 1996 “QUAD”
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`calendar (Ex. 2050)
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`and in the true and
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`correct excerpts
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`Page 3 of 4
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`Escort Ex. 2053, pg. 3
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`Escort Ex. 2053, pg. 3
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`therefrom that are reproduced herein,
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`there was “Follow up on [the]
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`brainstorming” session and attention to
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`5. I recall that Steve Orr actively
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`the required “Accessory items —
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`Significant —— GPS” for “Velocity”
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`monitoring, determining the locations
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`of “Speed traps,” and for the “trainable
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`auto-X source” “Program” feature.
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`pursued developing a prototype of this
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`“Next Product” and would periodically and generally informally provide updates
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`on his progress. At one point, he provided a demonstration of a prototype system
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`he had developed on a picnic table in the CMI outdoor lounge area, a true and
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`correct picture of which is shown herein. His demonstration used a laptop
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`computer and showed the desired GPS functionality.
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`5. While it was not clear whether Steve Orr’s GPS solution would be
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`affordable at the time, that question was not resolved prior to my departure.
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`6.
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`I declare under penalty of perjury that the foregoing is true and
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`correct.
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`Z 7 /47
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`Date:
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`@452? '
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`Beth Andrews
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`Page 4 of 4
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`Escort Ex. 2053, pg. 4
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`Escort Ex. 2053, pg. 4
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