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`Patent 8,155,342
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`UNIFIED PATENTS INC.
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`Petitioner
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`BLITZSAFE TEXAS, LLC
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`Patent Owner
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`Patent 8,155,342
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`Multimedia Device Integration System
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`PETITIONER’S VOLUNTARY IN TERROGATORY RESPONSES
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`Petitioner Unified - Exhibit 1019 - Page 1
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`Petitioner Unified - Exhibit 1019 - Page 1
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`IPRZO l 6-OXXXX Petition
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`Patent 8,155,342
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`Petitioner, Unified Patents
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`Inc.
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`provides
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`the
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`following
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`voluntary
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`interrogatory responses.
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`DEFINITIONS
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`A.
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`’342 PATENT means U.S. Patent No. 8,155,342.
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`B.
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`COMMUNICATIONS means the transmission or receipt of information of
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`any kind through any means (e.g. email, text message, voicemail, audio,
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`computer readable media, or orally).
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`C. MEMBER means any company that participates in UNIFIED’S solution
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`and MEMBERS means all such companies.
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`D.
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`IPR means inter partes review.
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`E.
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`F.
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`THE INSTANT IPR means this proceeding.
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`PETITION means the petition,
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`including the exhibits thereto, for THE
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`INSTANT IPR.
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`G.
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`UNIFIED means Unified Patents Inc. and include any shareholder, officer,
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`director, employee, agent, representative, privies,
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`intermediaries or other
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`individual authorized to act on behalf of Unified Patents Inc.
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`H.
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`USPTO means the United States Patent and Trademark Office.
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`Petitioner Unified - Exhibit 1019 - Page 2
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`Petitioner Unified - Exhibit 1019 - Page 2
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`IPR2O 1 6-OXXXX Petition
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`Patent 8,155,342
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`RESPONSES TO INTERROGATORIES
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`INTERROGATORY NO. 1:
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`Identify any COMMUNICATIONS between UNIFIED and any entity other than
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`its counsel relating to the financing, preparation, editing, prior review, or approval
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`of the PETITION.
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`RESPONSE NO. 1:
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`UNIFIED states that no such communication exist.
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`UNIFIED states that it was founded by intellectual property professionals
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`over concerns with the increasing risk of non-practicing entities (NPES) asserting
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`poor quality patents against strategic technologies and industries. The founders
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`thus created a f1rst—of-
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`its—kind company whose sole purpose is to deter NPE
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`litigation by protecting technology sectors,
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`like automotive,
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`the technology at
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`issue in the ’342 patent.
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`Companies in a technology sector subscribe to
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`UNIFIED’s technology specific deterrence, and in turn, UNIFIED performs many
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`NPE—deterrent activities, such as analyzing the technology sector and monitoring
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`patent activity (including patent ownership and sales, NPE demand letters and
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`litigation, and industry companies). UNIFIED’s monitoring activities allow
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`Petitioner Unified - Exhibit 1019 - Page 3
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`Petitioner Unified - Exhibit 1019 - Page 3
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`IPR20l6—OXXXX Petition
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`Patent 8,155,342
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`UNIFIED to identify patents, perform prior art research, analyze invalidity, and to
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`sometimes file reexams or IPRS against some patents.
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`UNIFIED states that it has sole and absolute discretion over its decision to
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`contest patents through the USPTO’s post—grant proceedings. Based on its own
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`analysis, UNIFIED determines which patents are worth pursuing in terms of
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`searching for prior art or taking action,
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`including filing an IPR. UNIFIED’s
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`decisions to file an IPR are made independently without the input, assistance or
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`approval of its MEMBERS. Should UNIFIED decide to challenge a patent in a
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`post-grant proceeding, UNIFIED controls every aspect of such a challenge,
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`including controlling which patent and claims to challenge, which prior art to
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`apply and the grounds raised in the challenge, and when to bring any challenge.
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`MEMBERS receive no prior notice of UNIFIED’s patent challenges. After
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`filing a post—grant proceeding, UNIFIED retains sole and absolute discretion and
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`control over all strategy decisions (including any decision to continue or terminate
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`UNIFIED’s participation). UNIFIED is also solely responsible for paying for
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`the preparation, filing, and prosecution of any post—grant proceeding, including
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`any expenses associated with the proceeding.
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`Petitioner Unified - Exhibit 1019 - Page 4
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`Petitioner Unified - Exhibit 1019 - Page 4
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`IPRZO 1 6—OXXXX Petition
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`Patent 8,155,342
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`In THE INSTANT IPR, UNIFIED exercised its sole discretion and control
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`in deciding to file this PETITION against the ’342 patent, including paying for all
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`fees and expenses.
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`UNIFIED shall exercise sole and absolute control and
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`discretion of the continued prosecution of this proceeding (including any decision
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`to terminate UNIFIED’s participation) and shall bear all subsequent costs related
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`to this proceeding.
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`INTERROGATORY NO. 2:
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`Identify any individuals acting for or on behalf of any entity other
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`than
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`UNIFIED’S counsel and expert that participated or assisted in any way with the
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`financing, preparation, editing, prior review, approval, or filing of the PETITION.
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`RESPONSE NO. 2:
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`UNIFIED states that no such individuals exist. UNIFIED further states that
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`no individuals other than UNIFIED employees and its counsel had any prior
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`knowledge of the filing of THE INSTANT IPR.
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`As stated in response to Interrogatory No. 1,
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`in the instant proceeding,
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`UNIFIED exercised its sole discretion and control in deciding to file this petition
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`against the ’342 patent, including paying for all fees and expenses. UNIFIED
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`shall exercise sole and absolute control and discretion of the continued prosecution
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`Petitioner Unified - Exhibit 1019 - Page 5
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`Petitioner Unified - Exhibit 1019 - Page 5
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`IPRZO I 6-OXXXX Petition
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`Patent 8,155,342
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`of this proceeding (including any decision to terminate UNIFIED’s participation)
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`and shall bear all subsequent costs related to this proceeding.
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`UNIFIED further states that its MEMBERS do not get to participate in any way in
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`UNIFIED’s deterrent activities. UNIFIED does not receive input
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`from its
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`members, nor give them an opportunity to participate or an opportunity to even
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`know that UNIFIED is contemplating filing an IPR before the IPR is filed.
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`In the
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`instant proceeding, none of UNIFIED’s MEMBERS had any prior knowledge of,
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`or involvement in, the preparation and filing of the INSTANT IPR.
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`INTERROGATORY NO. 3:
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`Identify payments by any entity to UNIFIED relating to the financing of the
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`INSTANT IPR.
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`RESPONSE N0. 3:
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`UNIFIED states that no such payments exist.
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`UNIFIED states that its MEMBERS pay only a yearly subscription fee to a
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`specific technology zone, and in return, UNIFIED performs its many NPE-
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`deterrent activities. UNIFIED’s MEMBERS do not pay any fees designated for
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`IPRs, let alone for IPRs against specific patents.
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`It is UNIFIED and UNIFIED
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`alone that determines how to spend its money. UNIFIED independently selects
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`Petitioner Unified - Exhibit 1019 - Page 6
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`Petitioner Unified - Exhibit 1019 - Page 6
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`IPR20 1 6—0XXXX Petition
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`Patent 8,155,342
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`which patents to target based on the perceived deterrent value to a technology
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`zone. Based on its own analysis, UNIFIED determines which patents are worth
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`pursuing in terms of filing an IPR or performing some other activity. UNIFIED’s
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`decisions to tile an IPR are made independently without the input, assistance, or
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`approval of its MEMBERS. UNIFIED states that there are no explicit or implicit
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`agreements with its MEMBERS about UNIFIED’s performing any particular
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`deterrent strategy, including the INSTANT IPR.
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`Unified Patents Inc.
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`W//i
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`Paul C. Haughey, Reg. No. 3 ,83d/
`KILPATRICK TOWNSEN & S OCKTON LLP
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`Two Embareadero Center, Eighth Floor
`San Francisco, CA 941 l l~3834
`Tel: 415-576-0200
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`Petitioner Unified - Exhibit 1019 - Page 7
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`Petitioner Unified - Exhibit 1019 - Page 7
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`IPR2O l 6-OXXXX Petition
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`Patent 8,155,342
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`VERIFICATION
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`I, Kevin Jakel, state that I am CEO of Unified Patents Inc., and that I am
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`authorized to make this Verification for and on its behalf.
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`I certify that I have read
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`the foregoing Interrogatory responses, and that the responses are true and accurate
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`to the best of my own knowledge, information and belief. Further, I make this
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`Verification with the knowledge that willful false statements and the like so made
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`are punishable by fine or imprisonment, or both, under Section 1001 of Title 18 of
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`the United States Code and that such willful false statements may jeopardize the
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`results of these proceedings.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`By: K
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`lévin Jakel
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`Petitioner Unified - Exhibit 1019 - Page 8
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`Petitioner Unified - Exhibit 1019 - Page 8