`U.S. Patent. No. 8,532,641
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD;
`SAMSUNG ELECTRONICS AMERICA, INC.,
`
`Petitioners,
`V.
`
`AFFINITY LABS OF TEXAS, LLC,
`
`Patent Owner.
`
`Case IPR2014-01181
`
`Patent No. 8,532,641 B2
`
`DECLARATION OF CINDY D. KUCHESKA IN SUPPORT OF PATENT
`OWNER'S RESPONSE TO INTER FAR TES REVIEW OFUNITED
`STATES PATENT NO. 8,532,641
`
`SAMSUNG ELECTRONICS CO., LTD., v. AFFINITY LABS OF TEXAS, LLC
`IPR2014-01181 EXHIBIT 2004 – 1
`
`
`
`IPR2014-01181
`U.S. Patent No. 8,532,641
`I, Cindy D. Kucheska make the following Declaration pursuant to 28 U.S.C. §
`
`1746:
`
`1.
`
`I am currently the Word Processing Manager at the law firm of Robins
`
`Kaplan LLP.
`
`2.
`
`I provide this Declaration in connection with the above-identified inter
`
`partes review proceeding.
`
`3. Attached hereto as Exhibit 2004A is a true and correct copy of the
`
`document containing a comparison of the specifications (not including the figures or
`
`claims) of U.S. Patent No. 7,187,947 to U.S. Patent No. 8,532,641. I created this
`
`document on April 30, 2015 using the Workshare Compare software. On May 12,
`
`2015, I formatted the content to fit on a full-size page. The text from '947 patent
`
`served as the original document. The text of the '641 patent served as new document.
`
`Changes from the text of the '947 patent to the text of the '641 patent are represented
`
`by the following markings: the blue underlined text indicates an insertion; the fed
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`f,trikc through text indicates a deletion; the green strikethrough text indicates that text
`
`was moved from that location; the green underlined text indicates that text was
`
`moved to that location.
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`4. Attached hereto as Exhibit 2004B is a true and correct copy of the
`
`document containing a comparison of the specifications (not including the figures or
`
`claims) of U.S. Patent No. 7,778,595 to U.S. Patent No. 8,532,641. I created this
`
`document on May 12, 2015 using the Workshare Compare software. The text
`
`SAMSUNG ELECTRONICS CO., LTD., v. AFFINITY LABS OF TEXAS, LLC
`IPR2014-01181 EXHIBIT 2004 – 2
`
`
`
`IPR2014-01181
`U.S. Patent No. 8,532,641
`from '595 patent served as the original document. The text of the '641 patent served
`
`as new document. Changes from the text of the '595 patent to the text of the '641
`
`patent are represented by the following markings: the blue underlined text indicates an
`
`insertion; the feel-strike-threugh text indicates a deletion; the grccn (cid:9) strikcthrough text
`
`indicates that text was moved from that location; the green underlined text indicates
`
`that text was moved to that location.
`
`5.
`
`I make these declarations on my own personal knowledge. If called to
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`testify as to the truth of the matters stated herein, I could and would testify
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`competently.
`
`6.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`21
`Executed this I (cid:9) day of May, 2015.
`
`SAMSUNG ELECTRONICS CO., LTD., v. AFFINITY LABS OF TEXAS, LLC
`IPR2014-01181 EXHIBIT 2004 – 3
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