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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`WTS Paradigm, LLC,
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`Petitioner
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`v.
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`EdgeAQ, LLC,
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`Patent Owner
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`
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`Case IPR: Unassigned
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`Patent 7,805,461
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`DECLARATION OF LOUIS A. KLAPP IN SUPPORT OF
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,805,461
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`WTS PARADIGM LLC EXHIBIT 1003
`1 of 3
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`I, Louis A. Klapp, do hereby declare as follows:
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`1.
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`I am an attorney at Quarles & Brady LLP and counsel for Petitioner. I
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`make this declaration based on personal knowledge.
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`2.
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`Exhibit 1002 is a true and correct copy of the curriculum vitae of
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`Deborah McGuinness as received from Deborah McGuinness.
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`3.
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`Exhibit 1004 is a true and correct copy of U.S. Patent No. 7,805,461,
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`the patent that is the subject of the present Petition.
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`4.
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`5.
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`6.
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`Exhibit 1005 is a true and correct copy of U.S. Patent No. 6,397,221.
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`Exhibit 1006 is a true and correct copy of U.S. Patent No. 6,810,401.
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`Exhibit 1007 is a true and correct copy of Fikes & Kehler, The Role of
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`Frame Based Representation in Reasoning (1985) from Communications of the
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`ACM, Volume 28, Number 9, September 1985.
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`7.
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`Exhibit 1008 is a true and correct copy of excerpts from Alison
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`Cawsey, The Essence of Artificial Intelligence (1998), a book published by
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`Prentice Hall.
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`8.
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`9.
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`Exhibit 1009 is a true and correct copy of U.S. Patent No. 6,108,670.
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`Exhibit 1010 is a true and correct copy of U.S. Patent No. 5,953,726.
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`10. Exhibit 1011 is a true and correct copy of U.S. Patent No. 5,467,471.
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`11. Exhibit 1012 is a true and correct copy of U.S. Patent No. 6,442,566.
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`1
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`WTS PARADIGM LLC EXHIBIT 1003
`2 of 3
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`12. Exhibit 1013 is a true and correct copy of Jon R. Wright et al., A
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`Knowledge-Based Configurator That Supports Sales, Engineering, and
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`Manufacturing at AT&T Network Systems (1993) from AI Magazine Volume 14
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`Number
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`3
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`as
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`downloaded
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`from
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`the
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`AAAI
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`website
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`at
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`http://www.aaai.org/ojs/index.php/aimagazine/article/view/1055/973.
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`13. All statements made herein are of my own knowledge and true, and
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`all statements made on information and belief are believed to be true. I have been
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`and am hereby warned that willful false statements and the like are punishable by
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`fine or imprisonment, or both (18 U.S.C. § 1001) and may jeopardize the petition
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`which this declaration supports. Pursuant to 28 U.S.C. § 1746, I declare under
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`penalty of perjury that the foregoing is true and correct.
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`
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`/Louis A. Klapp/
`Louis A. Klapp
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`Executed on November 16, 2015
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`2
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`WTS PARADIGM LLC EXHIBIT 1003
`3 of 3
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