`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`MICROSOFT CORPORATION,
`Petitioner
`
`v.
`
`BRADIUM TECHNOLOGIES LLC,
`Patent Owner
`____________________
`
`CASE IPR2016-00449
`Patent 8,924,506 B2
`____________________
`
`
`
`DECLARATION OF IAN MOORE
`IN SUPPORT OF PATENT OWNER’S REPLY IN SUPPORT OF PATENT
`OWNER’S MOTION TO EXCLUDE EVIDENCE
`
`Exhibit 2085
`Bradium Technologies LLC - patent owner
`Microsoft Corporation - petitioner
`IPR2016-00449
`
`1
`
`
`
`DECLARATION OF IAN MOORE
`
`I, Ian Moore, make the following declaration under penalty of perjury:
`
`1. My name is Ian Moore. I am an attorney at Andrews Kurth Kenyon
`
`LLP.
`
`2.
`
`I am over 18 years of age and make this declaration based upon my
`
`own knowledge, personal experience, and belief. If called upon, I could
`
`competently testify to the facts stated in this declaration.
`
`3.
`
`I assisted in the collection and assembly of the documents included as
`
`Exhibits for Patent Owner’s Reply in Support of Patent Owner’s Motion to
`
`Exclude Evidence. I have personal knowledge regarding the preparation of the
`
`exhibits described below.
`
`4.
`
`Exhibit 2082 is a true and correct copy of a letter received by Mr.
`
`Isaac Levanon from DENSO CORPORATION, dated November 23, 2016.
`
`5.
`
`Exhibit 2083 is a true and correct printed copy of the LinkedIn
`
`website profile of Yoni Lavi at https://il.linkedin.com/in/yoni-lavi-a590b224. The
`
`first two pages of the copy were collected from Yoni Lavi’s profile without
`
`logging in to LinkedIn. The last three pages were collected from Yoni Lavi’s
`
`profile while logged in to a LinkedIn account.
`
`6.
`
`Exhibit 2084 is a true and correct copy of a letter sent from Mr. Chris
`
`Coulson of Andrews Kurth Kenyon LLP to Mr. Evan Day of Perkins Coie LLP as
`
`well as the counsel of record in IPR2016-00448 via email on February 13, 2017.
`
`1
`
`2
`
`
`
`DECLARATION OF IAN MOORE
`
`I hereby declare that all statements made herein of my own knowledge are
`
`true; that all statements made on information and belief are believed to be true; and
`
`further that these statements were made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under 18 U.S.C. § 1001 and that such willful false statements may jeopardize the
`
`validity of the application or any patent issued thereupon.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`
`
`Executed on this 7th day of April, 2017 in New York, New York.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`_____________________________
`Ian A. Moore
`
`2
`
`3
`
`