`Patent 5,891,453
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_________________________
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`CLIO USA, INC.
`Petitioner
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`v.
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`THE PROCTER & GAMBLE COMPANY
`Patent Owner
`
`_________________________
`
`
`Case IPR2013-00448
`Patent 5,891,453
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`_________________________
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`DECLARATION OF KENNETH S. LUCHESI
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`Declaration of Kenneth S. Luchesi
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`Case IPR2013-00448
`Patent 5,891,453
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`I, Kenneth S. Luchesi, 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 Inter Partes
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`Review proceeding. Unless otherwise stated, the facts stated in this Declaration
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`are based on my personal knowledge.
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`3.
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`Exhibit 2010 is a true and correct copy of excerpted pages from the
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`deposition transcript of Dr. Abdul Gaffar dated September 5, 2013 from Procter &
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`Gamble Co. v. Team Techs., Inc., No. 1:12-cv-00552-TSB (S.D. Ohio). Page
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`numbers and an exhibit label have been added to the bottom of this document but
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`no other alterations have been made.
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`4.
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`Exhibit 2011 is a true and correct copy of an internet page regarding
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`Paul A. Sagel from http://news.crest.com. Page numbers and an exhibit label have
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`been added to the bottom of this document but no other alterations have been
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`made.
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`5.
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`Exhibit 2012 is a true and correct copy of an internet page regarding
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`Crest 3D White awards and recognition from http://www.3dwhite.com. Page
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`
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`
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`Case IPR2013-00448
`Patent 5,891,453
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`numbers and an exhibit label have been added to the bottom of this document but
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`no other alterations have been made.
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`6.
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`Exhibit 2013 is a true and correct copy of an internet page regarding
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`the 2012 Edison Award winners from http://www.edisonawards.com. Page
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`numbers and an exhibit label have been added to the bottom of this document but
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`no other alterations have been made.
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`7.
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`Exhibit 2014 is a true and correct copy of an internet page regarding
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`new products of the decade from http://adage.com. Page numbers and an exhibit
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`label have been added to the bottom of this document but no other alterations have
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`been made.
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`8.
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`Exhibit 2015 is a true and correct copy of an internet page regarding
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`the SCI Gordon E. Moore Medal from http://www.soci.com. Page numbers and an
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`exhibit label have been added to the bottom of this document but no other
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`alterations have been made.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Date: March 14, 2014
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`Signature: ~ •
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`Kenne h
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`. uchesi
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`2
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