`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`COALITION FOR AFFORDABLE DRUGS IV LLC
`Petitioner
`v.
`PHARMACYCLICS, INC.
`Patent Owner
`
`Case No. IPR2015-01076
`Patent No. 8,754,090
`
`DECLARATION OF TCHAO J. THAO
`
`08/19/15
`Coalition for Affordable Drugs IV LLC - Exhibit 1049
`
`
`
`Case IPR2015-01076
`Patent 8, 754,090
`
`In support of the Motion to Correct Petition, I, Tchao J. Thao, do declare and
`
`state as follows:
`
`1.
`
`I am an attorney at the law firm of Merchant & Gould, PC in the
`
`Minneapolis, Minnesota office.
`
`2.
`
`I assisted on the preparation of the petition requesting Inter Partes
`
`Review of U.S. Patent No. 8,754,090 ("Petition"), as well as the supporting
`
`documents submitted with it.
`
`3.
`
`Merchant &Gould maintains a folder entitled "Searches and
`
`References" in its internal document management system for saving prior art
`
`related to the '090 patent. The "Searches and References" folder is part of a
`
`network directory specifically reserved for this matter, which is client matter
`
`number 04852.000SUSWX. The prior art stored in the "Searches and References"
`
`folder included an April 13, 2009 Pharmacyclics Press Release ("April 2009 Press
`
`Release") and a December 9, 2009 Pharmacyclics Press Release ("December 2009
`
`Press Release").
`
`4.
`
`In preparing the Petition for filing, I was asked to compile electronic
`
`copies of the Exhibits to the Petition. The electronic copies of the Exhibits were to
`
`be labeled according to their exhibit number listed in the Appendix of Exhibits. In
`
`preparing the Exhibits, I accidentally selected the December 2009 Press Release
`
`1
`
`08/19/15
`Coalition for Affordable Drugs IV LLC - Exhibit 1049
`
`
`
`Case IPR2015-01076
`Patent 8, 7 54, 090
`
`from the "Searches and References" folder instead of the April 2009 Press Release.
`
`This was unintentional and a result of clicking on the wrong file link in the
`
`"Searches and References" folder as both links were positioned next to each other
`
`and the files were similar in layout and style. I intended to save the April 2009
`
`Press Release as the Exhibit for filing. I was not aware of the mistake in collecting
`
`and labelling Exhibit 1004 until I read the Patent Owner's Preliminary Response.
`
`5.
`
`I hereby declare under penalty of perjury under the laws of the United
`
`States of America that the foregoing is true and correct, and that all statements
`
`made of my own knowledge are true and that all statements made on information
`
`and belief are believed to be true. I understand that willful false statements and the
`
`like are punishable by fine or imprisonment, or both, under 18 U.S.C. § 1001.
`
`Dated: August 19, 2015
`
`2
`
`08/19/15
`Coalition for Affordable Drugs IV LLC - Exhibit 1049
`
`
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