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`Case IPR2O 13-00448
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`Patent 5,891 ,453
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`CLIO USA, INC.
`Petitioner
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`VI
`
`THE PROCTER & GAMBLE COMPANY
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`Patent Owner
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`Case IPR2013—00448
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`Patent 5,891,453
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`DECLARATION OF KENNETH S. LUCHESI
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`
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`Page 001
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`Page 001
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`
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`Declaration of Kenneth S. Luchesi
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`Case IPR2013-00448
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`Patent 5,891,453
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`1, 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 2005 hereto is a true and correct copy of excerpted pages from
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`the deposition transcript of Dr. Abdul Gaffar dated September 5, 2013 from
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`Procter & Gamble Co. v. Team Techs., Inc., No. 1:12-cv—0O552-TSB (S.D. Ohio).
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`Page numbers and an exhibit label have been added to the bottom of this document
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`but no other alterations have been made.
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`4.
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`Exhibit 2007 hereto is a true and correct copy of excerpted pages from
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`Dr. Abdul Gaffar’s Expert Report on Claim Construction dated August 13, 2013
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`from Procter & Gamble Co. v. Team Techs., Irzc., No. 1:12-cv—0O552-TSB (S.D.
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`Ohio). Page numbers and an exhibit label have been added to the bottom of this
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`document but no other alterations have been made.
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`Page 002
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`Page 002
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`Case IPR2013-00448
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`Patent 5,891,453
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Date: October 17 2013
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`Signature :
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`Page 003
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`Page 003
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