`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`Valeo North America, Inc. and Valeo Embrayages,
`Petitioners,
`
`v.
`
`Schaeffler Technologies AG & Co. KG,
`Patent Owner.
`
`__________________
`
`Case IPR2017-00442
`
`U.S. Patent No. 8,573,374
`
`__________________
`
`DECLARATION OF PASCAL HERVET
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`Valeo Exhibit 1107, pg. 1
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`
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`U.S. Patent No. 8,573,374
`Declaration of Pascal Hervet
`
`I, Pascal Hervet, declare as follows:
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`1.
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`I am over the age of 21 and competent to make this
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`declaration.
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`2.
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`Although French is my native language, I am sufficiently
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`proficient in the English language to make this declaration in English.
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`3.
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`I have personal knowledge of the facts contained herein
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`unless otherwise indicated.
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`4.
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`I am an employee of Valeo in Amiens, France. I have
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`worked at Valeo for 11 years.
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`5.
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`In 2008, the scope of my work at Valeo included attending
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`conferences and accessing publicly available information relating to
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`torque converter design.
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`6.
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`Exhibit 1106 is an excerpt from a book including a
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`presentation by Wolfgang Reik, entitled The Centrifugal Pendulum
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`Absorber Calming Down the Drivetrain (“Reik”). This presentation was
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`given at the December 2008 CTI Symposium. I attended that
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`symposium, and I personally obtained a copy of Reik in December 2008
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`1
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`Valeo Exhibit 1107, pg. 2
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`
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`because all participants received a copy of a book containing the
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`U.S. Patent No. 8,573,374
`Declaration of Pascal Hervet
`
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`presentations from the symposium.
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`7.
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`Like me, any other interested member of the public could
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`have obtained a copy of Reik in December 2008 by paying the
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`symposium fee. Anyone who paid the symposium fee had access to all of
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`the papers presented at the symposium, including the Reik paper, in
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`the form of the book given to attendees.
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`8.
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`The CTI Symposium is a leading conference on the subject of
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`automotive powertrains and transmissions. The organizers of the CTI
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`Symposium actively solicit experts from automotive manufacturers and
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`suppliers and institutions to submit proposals for technical
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`presentations related to automotive transmissions and powertrains.
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`The organizers also actively solicit attendance at the symposiums. The
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`December 2008 CTI Symposium had over 1,000 participants, all of
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`whom could access the Reik paper in the book and keep the copy that
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`was given to them in the book.
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`9.
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`I hereby declare under penalty of perjury of the laws of the
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`United States of America that all statements made herein of my own
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`knowledge are true and that all statements made on information and
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`
`
`2
`
`Valeo Exhibit 1107, pg. 3
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`
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`U.S. Patent No. 8,573,374
`
`Declaration of Pascal Hervet
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`belief are believed to be true; and further that these statements were
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`made with the knowledge that willful false statements and the like so
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`made are punishable by fine or imprisonment, or both, under Section
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`1001 of Title 18 of the United States Code and that such willful false
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`statements may jeopardize the results of these proceedings.
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`Date3_2O16/12/01_
`
`Pascal Hervet
`
`Ainiens, France
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`Valeo Exhibit 1107, pg. 4
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`Valeo Exhibit 1107, pg. 4