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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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`Taiwan Semiconductor Manufacturing Company Limited
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`Petitioner
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`V.
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`Godo Kaisha IP Bridge 1
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`Patent Owner
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`DECLARATION OF THOMAS E. GORMAN
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`FOR INTER PARTES REVIEW OF UNITED STATES
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`PATENT NO. 6,538,324
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`IPR2016-01264 and IPR2016-01249
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`Page 1 0f 3
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`TSMC Exhibit 1039
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`TSMC v. IP Bridge
`IPR2016-01264
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`Page 1 of 3
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`TSMC Exhibit 1039
`TSMC v. IP Bridge
`IPR2016-01264
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`I, Thomas E. Gorman, declare as follows:
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`1.
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`I am an attorney in Keker, Van Nest & Peters LLP’s offices in San
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`Francisco, California.
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`2.
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`I am counsel for Taiwan Semiconductor Manufacturing Company,
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`Ltd. (“TSMC”) retained in connection with Godo Kaisha 1P Bridge I v. Broadcom
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`Corp, Broadcom Limited, Avago Technologies, Ltd, Avago Technologies US,
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`Inc, and LS] Corp, Case No. 2:16—cv—00134—JRG—RSP, in the Eastern District of
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`Texas. Among other things, the plaintiff (“IP iBridge”) alleged that each of the
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`defendants infringed US. Patent No. 6,538,324. See Ex. A (PACER Docket).
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`3.
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`The defendants served their Patent Rule 3—3 Invalidity Contentions on
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`June 20, 2016. Ex. B (E.D. Tex. Patent Rule 3—3) at 7; Ex. C (Docket Control
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`Order) at 4; Ex. D (Defendants’ Notice of Compliance Regarding P.R. 3—3 and 3—4
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`Disclosures). Counsel for the defendants provided me with a copy of their as—
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`served Invalidity Contentions, which TSMC filed as Exhibit 1037 in both inter
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`partes review proceedings IPR2016—01264 and IPR2016-01249. Exs. E and F.
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`4.
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`TSMC’s Exhibit 1037 is a true and correct copy of the Defendants’
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`Patent Rule 3—3 Invalidity Contentions and their attached Appendices B-1 to B—15,
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`as received from defendants’ counsel in the above-identified litigation. See id at
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`60—229 (Appendices B—1 to B—15).
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`Page 2 of 3
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`Page 2 of 3
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` (cid:9)
`5.
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`I declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true;
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`and 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 Section 1001 of Title 18 of the United States Code.
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`Dated: June 8 2017
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` (cid:9)
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`By: M
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`Thomas
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`orman
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`Page 3 of 3
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`Page 3 of 3
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