`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`RADWARE, TNC.,
`
`Petitioner
`
`V.
`
`F5 NETWORKS, INC.,
`Patent Owner
`
`Case IPR2017-00653
`
`Patent 7,472,413 B1
`
`Case IPR2017-00654
`
`Patent 7,472,413 B1
`
`DECLARATION OF AMIR PELES IN
`
`SUPPORT OF PETITIONER’S REPLY
`
`Radware Exhibit 1023
`
`
`
`I, Amir Peles, declare as follows:
`
`1.
`
`1 am Vice President of Technologies of Radware, Inc. (“INC”).
`
`I
`
`make this declaration based upon my personal knowledge of the facts stated herein.
`
`2.
`
`Although INC is a wholly-owned subsidiary of Radware, Ltd.
`
`(“LTD”), INC and LTD are separate companies with separate budgets. They
`
`maintain separate business records, pay separate taxes, and are measured based
`
`upon different business targets.
`
`3.
`
`INC is a New Jersey corporation engaged in selling, marketing
`
`installing, and servicing network management and data-security devices, and is the
`
`only Radware entity that operates in the United States. Besides INC’s
`
`headquarters are in Mahwah, New Jersey, INC also has offices in Illinois, North
`
`Carolina, and California.
`
`In total, INC employs approximately 176 persons in the
`
`US.
`
`4.
`
`LTD, on the other hand, is a publically traded Israeli corporation
`
`based in Tel Aviv, engaged in design, research and development and
`
`manufacturing of network management and data-security devices.
`
`5.
`
`In April of 2016, F5 Networks, Inc. (“F5”) sued INC -— but not LTD —
`
`in the US. District Court for the Western District of Washington for allegedly
`
`infringing US. Patent Nos. 6,31 1,278; 7,472,413; and 8,676,955 (“asserted
`
`patents").
`
`
`
`6.
`
`INC therefore has a direct and immediate interest in adjudicating the
`
`validity of the asserted patents. For this reason, INC has petitioned the United
`
`States Patent and Trade Mark Office for review of the validity of these patents.
`
`7.
`
`INC is solely responsible for directing, controlling, and bearing the
`
`costs of these petitions, including: (i) legal fees, (ii) filing fees, and (iii) expert
`
`fees, associated with the proceedings.
`
`I declare under penalty of perjury under the laws of the United States of
`
`America that the foregoing is true and correct. Executed this 3 1st of May, 2017, at
`
`Mahwah, New Jersey.
`
`By:
`
`m1r Peles
`
`
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