`United States Patent No. 8,532,641
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`§ Attorney Docket No.:
`United States Patent No.: 8,532,641
`§
`110797-0004-659
`Inventors: Russell W. White,
`§ Customer No. 28120
`Kevin R. Imes
`Formerly Application No.: 13/673,391 § Petitioners:
`Issue Date: Sept. 10, 2013
`§
`Samsung Electronics Co., Ltd.;
`Filing Date: Nov. 9, 2012
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`Samsung Electronics America, Inc.
`Priority Date: March 28, 2000
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`Former Group Art Unit: 2646
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`Former Examiner: Erika Washington
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`For: SYSTEM AND METHOD FOR MANAGING MEDIA
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`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`Post Office Box 1450
`Alexandria, Virginia 22313-1450
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`DECLARATION OF HAYAN YOON IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF
`UNITED STATES PATENT NO. 8,532,641
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`I, Hayan Yoon, make the following Declaration pursuant to 28 U.S.C. § 1746:
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`1.
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`2.
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`I am an attorney at the law firm of Ropes & Gray LLP.
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`I provide this Declaration in connection with the above-identified Inter
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`Partes Review proceeding that is being requested at the United States Patent and
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`Trademark Office (“USPTO”) by the above-identified petitioners under 35 U.S.C. §§
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`311-319 and 37 C.F.R. § 42. Unless otherwise stated, the facts stated in this
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`Declaration are based on my personal knowledge.
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`Samsung Ex. 1425 p. 1
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`3.
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`Exhibit 1401 hereto is a true and correct copy of United States Patent
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`No. 8,532,641 to White et al., which was downloaded from the USPTO Patent
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`Application Information Retrieval (“PAIR”) website and which is a record of the
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`USPTO to which all parties have access. This document has been marked with an
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`exhibit label and page numbers on each page at the bottom right corner. However,
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`no alterations, other than these noted markings, have been made to this document.
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`4.
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`Exhibit 1402 hereto is a true and correct copy of the file history for
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`United States Patent No. 8,532,641 to White et al., which was downloaded from the
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`USPTO PAIR website and which is a record of the USPTO to which all parties have
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`access. This document has been marked with an exhibit label and page numbers on
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`each page at the bottom right corner. However, no alterations, other than these noted
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`markings, have been made to this document.
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`5.
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`Exhibit 1403 hereto is a true and correct copy of United States Patent
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`No. 6,990,334 to Ito, which was downloaded from the USPTO PAIR website and
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`which is a record of the USPTO to which all parties have access. This document has
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`been marked with an exhibit label and page numbers on each page at the bottom right
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`corner. However, no alterations, other than these noted markings, have been made to
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`this document.
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`6.
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`Exhibit 1406 hereto is a true and correct copy of United States Patent
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`No. 6,973,067 to Haartsen, which was downloaded from the USPTO PAIR website
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`Samsung Ex. 1425 p. 2
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`and which is a record of the USPTO to which all parties have access. This document
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`has been marked with an exhibit label and page numbers on each page at the bottom
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`right corner. However, no alterations, other than these noted markings, have been
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`made to this document.
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`7.
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`Exhibit 1408 hereto is a true and correct copy of United States Patent
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`No. 7,123,936 to Rydbeck et al., which was downloaded from the USPTO PAIR
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`website and which is a record of the USPTO to which all parties have access. This
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`8.
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`Exhibit 1409 hereto is a true and correct copy of United States Patent
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`No. 6,845,398 to Galensky et al., which was downloaded from the USPTO PAIR
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`website and which is a record of the USPTO to which all parties have access. This
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`9.
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`Exhibit 1410 hereto is a true and correct copy of United States Patent
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`No. 6,633,932 to Bork et al., which was downloaded from the USPTO PAIR website
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`and which is a record of the USPTO to which all parties have access. This document
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`has been marked with an exhibit label and page numbers on each page at the bottom
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`- 3 -
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`Samsung Ex. 1425 p. 3
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`right corner. However, no alterations, other than these noted markings, have been
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`made to this document.
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`10. Exhibit 1411 hereto is a true and correct copy of United States Patent
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`No. 6,212,403 to Ushiroda, which was downloaded from the USPTO PAIR website
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`and which is a record of the USPTO to which all parties have access. This document
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`has been marked with an exhibit label and page numbers on each page at the bottom
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`right corner. However, no alterations, other than these noted markings, have been
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`made to this document.
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`11. Exhibit 1412 hereto is a true and correct copy of the file history for
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`United States Patent No. 7,187,947 to White et al., which was downloaded from the
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`USPTO PAIR website and which is a record of the USPTO to which all parties have
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`access. This document has been marked with an exhibit label and page numbers on
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`each page at the bottom right corner. However, no alterations, other than these noted
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`markings, have been made to this document.
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`12. Exhibit 1414 hereto is a true and correct copy of the file history for
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`United States Patent No. 7,953,390 to White et al., which was downloaded from the
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`USPTO PAIR website and which is a record of the USPTO to which all parties have
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`access. This document has been marked with an exhibit label and page numbers on
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`each page at the bottom right corner. However, no alterations, other than these noted
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`markings, have been made to this document.
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`Samsung Ex. 1425 p. 4
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`13. Exhibit 1415 hereto is a true and correct copy of the Institution
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`Decision dated May 20, 2014 in Case IPR 2014-00209 (Inter Partes Review of U.S.
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`Patent No. 7,953,390), which was downloaded from the USPTO Patent Review
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`Processing System (“PRPS”) website and which is a record of the USPTO to which
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`all parties have access. This document has been marked with an exhibit label and
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`page numbers on each page at the bottom right corner. However, no alterations,
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`other than these noted markings, have been made to this document.
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`14. Exhibit 1416 hereto is a true and correct copy of the Institution
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`Decision dated May 20, 2014 in Case IPR 2014-00212 (Inter Partes Review of U.S.
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`Patent No. 7,953,390), which was downloaded from the USPTO PRPS website and
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`which is a record of the USPTO to which all parties have access. This document has
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`been marked with an exhibit label and page numbers on each page at the bottom right
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`corner. However, no alterations, other than these noted markings, have been made to
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`this document.
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`15. Exhibit 1417 hereto is a true and correct copy of the Action Closing
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`Prosecution issued on June 12, 2014 in Reexamination Control Nos. 95/001,262 and
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`90/011,254 (inter partes and ex parte reexaminations of U.S. Patent No. 7,187,947),
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`which was downloaded from the USPTO PAIR website and which is a record of the
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`USPTO to which all parties have access. This document has been marked with an
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`- 5 -
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`Samsung Ex. 1425 p. 5
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`exhibit label and page numbers on each page at the bottom right corner. However,
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`no alterations, other than these noted markings, have been made to this document.
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`16. Exhibit 1418 hereto is a true and correct copy of the Patent Trial and
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`Appeal Board decision dated June 30, 2014, Appeal No. 2014-002024
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`in
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`Reexamination Control No. 95/001,281 (inter partes reexamination of U.S. Patent No.
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`7,634,228), which was downloaded from the USPTO PAIR website and which is a
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`record of the USPTO to which all parties have access. This document has been
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`marked with an exhibit label and page numbers on each page at the bottom right
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`corner. However, no alterations, other than these noted markings, have been made to
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`this document.
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`17. Exhibit 1419 hereto is a true and correct copy of a document titled
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`“Specification of the Bluetooth System v1.0 B, Vols. 1 & 2” by Telefonaktiebolaget
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`LM Ericsson et al., dated December 1, 1999, which was submitted by Patent Owner
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`Affinity Labs of Texas, LLC during prosecution of United States Patent No.
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`8,532,641 and produced by Affinity Labs of Texas, LLC in Affinity Labs of Texas, LLC
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`v. Samsung Electronics Co., Ltd et al., No. 3:14-cv-3030 (NDCA), marked with bates
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`numbers AFFLT0293229-AFFLT0294750. This document has been additionally
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`marked with an exhibit label and page numbers on each page at the bottom right
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`corner. However, no alterations, other than these noted markings, have been made to
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`this document.
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`18. Exhibit 1420 hereto is a true and correct copy of an excerpt from “IBM
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`DICTIONARY OF COMPUTING,” compiled and edited by George McDaniel,
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`published by McGraw-Hill Inc., and dated 1994. This document has been marked
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`with an exhibit label and page numbers on each page at the bottom right corner.
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`However, no alterations, other than these noted markings, have been made to this
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`document.
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`19. Exhibit 1421 hereto is a true and correct copy of the Institution
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`Decision dated January 30, 2015 in Case IPR 2014-01181 (Inter Partes Review of U.S.
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`Patent No. 8,532,641), which was downloaded from the USPTO PRPS website and
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`which is a record of the USPTO to which all parties have access. This document has
`
`been marked with an exhibit label and page numbers on each page at the bottom right
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`corner. However, no alterations, other than these noted markings, have been made to
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`this document.
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`20. Exhibit 1422 hereto is a true and correct copy of the Institution
`
`Decision dated January 30, 2015 in Case IPR 2014-01182 (Inter Partes Review of U.S.
`
`Patent No. 8,532,641), which was downloaded from the USPTO PRPS website and
`
`which is a record of the USPTO to which all parties have access. This document has
`
`been marked with an exhibit label and page numbers on each page at the bottom right
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`corner. However, no alterations, other than these noted markings, have been made to
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`this document.
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`Samsung Ex. 1425 p. 7
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`21.
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`Exhibit 1423 hereto is a true and correct copy of the Institution
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`Decision dated january 30, 2015 in Case [PR 2014~01184 (Inter Paris; Review of US.
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`Patent No. 8,532,641), which was downloaded from the USPTO PRPS website and
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`which is a record of the USPTO to which all parties have access. This document has
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`been marked with an exhibit label and page numbers on. each page at the bottom right
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`corner.
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`I-lowever, no alterations, other than these noted markings, have been made to
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`this document.
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`22.
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`I make this declaration of my own personal knowledge.
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`If called to
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`testify as
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`to the truth of the matters stated herein,
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`1 could and would testify
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`competently.
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`23.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`[Executed this 27‘“ day of February 2015 in East Palo Alto, CA.
`
`m H
`
`ayan Yoon
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`Samsung EX. 1425 p. 8
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`Samsung Ex. 1425 p. 8
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