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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`'CISCO SYSTEMS, INC,
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`Petitioner
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`V.
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`FATPIPE NETWORKS PRIVATE LIMITED
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`Patent Owner
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`Case IPR2017~01845
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`Patent 6,775,23 5
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`DECLARATION OF ROBERT HILTON
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`Cisco Systems, Inc.
`IPR2017-01845
`Exhibit 1022
`Page 1 of 3
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`
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`Declaration of Robert C. Hilton
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`IPR2017—01845 (Patent 6,775,235)
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`1, Robert C. Hilton, hereby declare as follows:
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`1.
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`My name is Robert Hilton.
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`I am a Partner at McGuireWoods LLP.
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`1
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`make this declaration from my personal knowledge.
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`I
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`2.
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`I am lead counsel for Viptela, LLC, formerly known as Viptela, Inc.,
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`in IPR2017—00684 and IPR2017—01125. I managed a team at McGuireWoods that
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`was involved in all aspects of the preparation of the petitions for inter partes
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`review, including the search for relevant prior art.
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`3.
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`As part of the analysis and preparation for 1PR2017-00684 and
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`IPR2017~01125, McGuireWoods engaged a professional search firm, Cardinal IP,
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`to search for prior art relevant to US. Patent No. 6,775,235. Attached as Exhibit
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`1023 is a copy of the Patent Search Report provided by Cardinal 1P on November
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`23, 2016. Ex. 1023. The Patent Search Report includes the search results provided
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`by Cardinal 1P (Ex. 1023, pp. 2—25) and the search history performed by Cardinal
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`1P (Ex. 1023, pp. 26—33). The Cardinal 1? Patent Search Report does not list US.
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`Patent No. 6,243,754 to Guerin (“Guerin”), which I understand is Exhibit 1006 in
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`IPR2017»01845.
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`4.
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`1 was not aware of Guerin prior to its appearance in Cisco’s public
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`' filing ofIPR2017-01845, and I would have known if any member of my team was
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`aware of Guerin.
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`Cisco Systems, Inc.
`IPR2017-01845
`Exhibit 1022
`Page 2 of 3
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`
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`Declaration of Robert C. Hilton
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`IPR2017-01845 (Patent 6,775,235)
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`111. Conclusion
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`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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`Executed on this 22nd day of November, 2017.
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`726%
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`Robert C. Hilton
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`Dallas, Texas
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`Cisco Systems, Inc.
`IPR2017-01845
`Exhibit 1022
`Page 3 of 3
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