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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`ARRIS GROUP, INC.
`Petitioner
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`v.
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`C-CATION TECHNOLOGIES, LLC
`Patent Owner
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`Case: IPR2014-00746
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`DECLARATION OF TROY VAN AACKEN
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`PO Box 1450
`Alexandria, Virginia 22313-1450
`Submitted Electronically via the Patent Review Processing System
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`ARRIS GROUP, INC.
`IPR2015-00635 , p. 1
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`I, Troy Van Aacken, hereby declare as follows:
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`1.
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`I hold the position of Lead Counsel at ARRIS Group, Inc. I have personal
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`knowledge of the facts stated herein and if called upon to testify to them, I can and
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`will do so.
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`2.
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`ARRIS has certain agreements with its customers, including Comcast.
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`Comcast is ARRIS's largest customer at this time.
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`3.
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`The agreements that ARRIS has with its customers include provisions that
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`are negotiated between the parties and are not publicly available.
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`4.
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`ARRIS treats its agreements with its customers as sensitive and confidential
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`business information. Our customers, including Comcast, also expect these
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`agreements to be confidential. As such, ARRIS restricts access to the agreements
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`and does not make them available to the public, or our competitors. The
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`agreements also include confidentiality provisions that limits ARRIS's ability to
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`disseminate them. We understand that our customers are also obligated under the
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`agreements to keep the agreements and their terms confidential.
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`5.
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`If the terms of these agreements between ARRIS and Comcast were made
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`available to the public, including ARRIS's competitors, then both ARRIS and
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`Comcast's competitive position would be compromised
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`6.
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`I hereby declare that all statements made herein of my own knowledge are
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`true, and that all statements made on information and belief are believed to be true.
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`ARRIS GROUP, INC.
`IPR2015-00635 , p. 2
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`I further declare that these statements were made with the knowledge that willful
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`false statements are punishable by fine or imprisonment, or both, under Section
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`1001 of Title 18 of the United States Code.
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`Dated: _~,~~~
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`2
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`ARRIS GROUP, INC.
`IPR2015-00635 , p. 3