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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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`MICROSOFT CORPORATION,
`Petitioner
`
`v.
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`BRADIUM TECHNOLOGIES LLC,
`Patent Owner
`
`CASE IPR2016-00448
`Patent 7,908,343
`
`DECLARATION OF IAN MOORE
`IN SUPPORT OF PATENT OWNER’S REPLY IN SUPPORT OF ITS
`MOTION TO EXCLUDE EVIDENCE
`
`Exhibit 2085
`Bradium Technologies LLC - patent owner
`Microsoft Corporation - petitioner
`IPR2016-00448
`
`1
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`
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`DECLARATION OF IAN MOORE
`
`I, Ian Moore, make the following declaration under penalty of perjury:
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`1. My name is Ian Moore. I am an attorney at Andrews Kurth Kenyon
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`LLP.
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`2.
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`I am over 18 years of age and make this declaration based upon my
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`own knowledge, personal experience, and belief. If called upon, I could
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`competently testify to the facts stated in this declaration.
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`3.
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`I assisted in the collection and assembly of the documents included as
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`Exhibits for Patent Owner’s Reply in Support of Its Motion to Exclude Evidence. I
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`have personal knowledge regarding the preparation of the exhibits described
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`below.
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`4.
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`Exhibit 2082 is a true and correct copy of a letter received by Mr.
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`Isaac Levanon from DENSO CORPORATION, dated November 23, 2016.
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`5.
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`Exhibit 2083 is a true and correct printed copy of the LinkedIn
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`website profile of Yoni Lavi at https://il.linkedin.com/in/yoni-lavi-a590b224. The
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`first two pages of the copy were collected from Yoni Lavi’s profile without
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`logging in to LinkedIn. The last three pages were collected from Yoni Lavi’s
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`profile while logged in to a LinkedIn account.
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`6.
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`Exhibit 2084 is a true and correct copy of a letter sent from Mr. Chris
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`Coulson of Andrews Kurth Kenyon LLP to Mr. Evan Day of Perkins Coie LLP as
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`well as the counsel of record in IPR2016-00448 via email on February 13, 2017.
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`1
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`2
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`
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`DECLARATION OF IAN MOORE
`
`I hereby declare that all statements made herein of my own knowledge are
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`true; that all statements made on information and belief are believed to be true; and
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`further that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under 18 U.S.C. § 1001 and that such willful false statements may jeopardize the
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`validity of the application or any patent issued thereupon.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`
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`Executed on this 5th day of April, 2017 in Jersey City, NJ.
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`_______ ______________________
`Ian A. Moore
`
`2
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`3
`
`
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