`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`
`DOCKETNO.: 2211726-00161
`Filed on behalf of Unified Patents Inc.
`By: David L. Cavanaugh, Reg. No. 36,476
`Daniel V. Williams, Reg. No. 45,221
`Jonathan E. Robe, Reg. No. 76,033
`WilmerCutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: David.Cavanaugh@wilmerhale.com
`
`Jonathan Stroud, Reg. No. 72,518
`Roshan S. Mansinghani, Reg. No. 62,429
`Unified Patents Inc.
`1875 Connecticut Ave. NW, Floor 10
`Washington, DC, 20009
`Tel: (202) 805-8931
`Email: jonathan@unifiedpatents.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTSINC.
`Petitioner
`
`V.
`
`BRADIUM TECHNOLOGIES, LLC
`Patent Owner
`
`IPR2018-00952
`Patent 9,253,239
`
`PETITIONER’S VOLUNTARY INTERROGATORY RESPONSES
`
`ActiveUS 169439723v.1
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`
`
`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 1 of 23
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`UNIFIED PATENTS EXHIBIT 1032
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`PUBLIC REDACTED VERSION
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`PUBLIC REDACTED VERSION
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`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`Petitioner, Unified Patents Inc., provides the following voluntary
`
`interrogatory responses.
`
`DEFINITIONS
`
`A.
`
`*239 PATENT meansU.S.Patent 9,253,239.
`
`B.|COMMUNICATIONSmeansthetransmission or receipt of information of
`
`any kind through any means(e.g., e-mail, text message, voicemail, audio,
`
`computer readable media, or orally).
`
`C.|MEMBERmeans any companythat participates in UNIFIED’s solution and
`
`MEMBERSmeansall such companies.
`
`IPR meansinter partes review.
`
`|THE INSTANTIPR meansthis proceeding.
`
`D.
`
`E.
`
`F.|PETITION meansthe petition, including the exhibits thereto, for THE
`
`INSTANTIPR.
`
`G.|UNIFIED means Unified Patents Inc. and includes any shareholder, officer,
`
`director, employee, agent, representative, privies, intermediaries, or other
`
`individual authorized to act on behalf of Unified Patents Inc.
`
`H.
`
`USPTO meansthe United States Patent and Trademark Office.
`
`ActiveUS 169439723v.1
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`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 2 of 23
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`UNIFIED PATENTS EXHIBIT 1032
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`PUBLIC REDACTED VERSION
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`PUBLIC REDACTED VERSION
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`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
`
`RESPONSES TO INTERROGATORIES
`
`INTERROGATORYNO.1:
`
`Identify any COMMUNICATIONS between UNIFIED and any entity other
`
`than its counsel relating to the financing, preparation, editing, prior review, or
`
`approval of the PETITION.
`
`RESPONSENO.1:
`
`UNIFIEDstates that no such communicationsexist.
`
`UNIFIEDstates that it was founded by intellectual property professionals
`
`over concerns with the increasing risk of non-practicing entities (NPEs) asserting
`
`patents of poor quality against strategic technologies and industries. The founders
`
`thus createdafirst-of-its-kind company whosesole purpose is to deter NPElitigation
`
`by protecting technology sectors. Companies in a technology sector subscribe to
`
`UNIFIED’s technology-specific deterrence, and in turn, UNIFIED performs many
`
`NPE-deterrent activities, such as analyzing the technology sector and monitoring
`
`patent activity (including patent ownership and sales, NPE demandletters and
`
`litigation, and industry companies). UNIFIED’s monitoring activities allowsit to
`
`identify patents, perform prior art research, analyze invalidity, and to sometimesfile
`
`reexaminations or IPRs against somepatents.
`
`UNIFIEDstates that it has sole and absolute discretion over its decision to
`
`contest patents through the USPTO’s post-grant proceedings. Based on its own
`
`ActiveUS 169439723v.1
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`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 3 of 23
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`UNIFIED PATENTS EXHIBIT 1032
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`PUBLIC REDACTED VERSION
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`PUBLIC REDACTED VERSION
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`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`analysis, UNIFIED determines which patents are worth pursuing in terms of
`
`searching for prior art or taking action,
`
`including filing an IPR. UNIFIED’s
`
`decisions to file an IPR are made independently without the input, assistance, or
`
`approval of its MEMBERS. Should UNIFIED decideto challenge a patentin a post-
`
`grant proceeding, UNIFIED controls every aspect of such a challenge, including
`
`controlling which patent and claims to challenge, which prior art to apply and the
`
`grounds raised in the challenge, and whento bring any challenge.
`
`MEMBERSreceive noprior notice of UNIFIED’s patent challenges. After
`
`filing a post-grant proceeding, UNIFIED retains sole and absolute discretion and
`
`control overall strategy decisions (including any decision to continue or terminate
`
`UNIFIED’s participation). UNIFIED is also solely responsible for paying for the
`
`preparation, filing, and prosecution of any post-grant proceeding, including any
`
`expenses associated with the proceeding.
`
`In THE INSTANT IPR, UNIFIEDexercisedits sole discretion and control in
`
`decidingto file this PETITION against the °239 PATENT,including payingfor all
`
`fees and expenses. UNIFIEDshall exercise sole and absolute control and discretion
`
`of the continued prosecution of THE INSTANT IPR(including any decision to
`
`terminate UNIFIED’s participation) and shall bear all subsequent costs related to
`
`THE INSTANT IPR.
`
`ActiveUS 169439723v.1
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`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 4 of 23
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`UNIFIED PATENTS EXHIBIT 1032
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`PUBLIC REDACTED VERSION
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`PUBLIC REDACTED VERSION
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`INTERROGATORYNO.2:
`
`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`
`Identify any individuals acting for or on behalf of any entity other than
`
`UNIFIED’s counsel that participated or assisted in any way with the financing,
`
`preparation, editing, prior review, approval, orfiling of the PETITION.
`
`RESPONSENO.2:
`
`UNIFIEDstates that no such individuals exist. UNIFIED further states that
`
`no individuals other than UNIFIED’s employees and its counsel had any prior
`
`knowledgeofthe filing of THE INSTANT IPR.
`
`As stated in response to Interrogatory No. 1,
`
`in THE INSTANT IPR,
`
`UNIFIEDexercisedits sole discretion and control in deciding to file the PETITION
`
`against the °239 PATENT,including paying for all fees and expenses. UNIFIED
`
`shall exercise sole and absolute control and discretion of the continued prosecution
`
`of THE INSTANT IPR (including any decision to terminate UNIFIED’s
`
`participation) and shall bear all subsequent costs related to THE INSTANT IPR.
`
`UNIFIED further states that its MEMBERSdo notgetto participate in any
`
`way in UNIFIED’s deterrent activities. UNIFIED does not receive input from its
`
`MEMBERS, and does not give them an opportunity to participate in or an
`
`opportunity to even know that UNIFIED is contemplating filing an IPR before the
`
`IPRis filed. In THE INSTANT IPR, none ofUNIFIED’s MEMBERShadanyprior
`
`ActiveUS 169439723v.1
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`knowledgeof, or involvement in, the preparation and filing of THE PETITION or
`
`THE INSTANTIPR.
`
`INTERROGATORYNO.3:
`
`Identify payments by any entity to UNIFIED in connection with (1) THE
`
`PETITION and/or (2) any other IPR and/or patent infringement proceedings in
`
`which Bradium Technologies, LLC is a party and the °239 PATENT wasasserted.
`
`RESPONSE NO.3:
`
`UNIFIEDstates that no such paymentsexist.
`
`UNIFIEDstates that its MEMBERSpaya yearly subscription fee to specific
`
`technology zones, and in return, UNIFIED performs its many NPE-deterrent
`
`activities. UNIFIED’s MEMBERSdonot pay any fees designated for IPRs, let
`
`alone for IPRs against specific patents.
`
`It is UNIFIED and UNIFIEDalonethat
`
`determines how to spend its money. UNIFIED independently selects which patents
`
`to challenge based on the perceived deterrent value to a technology zone. Based on
`
`its own analysis, UNIFIED determines which patents are worth pursuing in terms of
`
`filing a challenge or performing some other activity. UNIFIED’s decisionstofile a
`
`challenge are made independently without the input, assistance, or approvalofits
`
`MEMBERS.
`
`ActiveUS 169439723v.1
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`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 6 of 23
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`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
`UNIFIEDstates that there are no explicit or implicit agreements with its
`
`MEMBERSabout UNIFIED performinganyparticular deterrent strategy, including
`
`THE INSTANTIPR.
`
`INTERROGATORYNO.4:
`
`Identify any and all relevant NPE Zone(s), as presently and/or previously
`
`identified on the Unified Patents website (www.unifiedpatents.com), that pertain to
`
`the technology that is the subject of the instant IPR.
`
`RESPONSE NO.4:
`
`UNIFIEDstates that THE INSTANT IPRpertains to the “Content Delivery”
`
`NPEZone,as identified on UNIFIED’s website (www.unifiedpatents.com).
`
`INTERROGATORYNO.5:
`
`Identify any and all members orentities who are members of the Zone(s)
`
`identified in response to Interrogatory No. 4.
`
`RESPONSENO.5:
`
`UNIFIEDstates that the following members are members of the “Content
`
`Delivery’
`
`NPE
`
`Zone,
`
`as
`
`identified
`
`on
`
`UNIFIED’s
`
`website
`
`(www.unifiedpatents.com):
`
`UNIFIED MEMBERSlisted belowinitalics are public. The identity of other
`
`UNIFIED MEMBERSishighly confidential business information. PF
`
`ActiveUS 169439723v.1
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`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`IPR2018-00952 VoluntaryInterrogatory Responses
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`U.S. 9,253,239aa|
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`ActiveUS 169439723v.1
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`ActiveUS 169439723v.1
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`oo
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`IPR2018-00952 VoluntaryInterrogatory Responses
`U.S. 9,253,239
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`ActiveUS 169439723v.1
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`oO
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
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`ary
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`ActiveUS 169439723v.1
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`So
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
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`ActiveUS 169439723v.1
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`—
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`—
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`UNIFIED PATENTS EXHIBIT 1032
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`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`
`4—= x zx©QO>=©zx o Z 9 &
`
`Identify any entity that is both (1) presently a MEMBER and/or has been a
`
`MEMBER atanytime since 2016, and (2) (a) has been sued for patent infringement
`
`ActiveUS 169439723v.1
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`of the ’239 PATENT by Bradium Technologies, LLC or
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`IPR2018-00952 Voluntary Interrogatory Responses
`US. 9,253,239
`(b) has received
`
`Notice/Licensing letters from Bradium Technologies, LLC (or from GPC).
`
`RESPONSENO.6:
`
`UNIFIEDstates it is not aware of any current or former MEMBERwhohas
`
`been sued by Bradium Technologies, LLC. UNIFIEDfurtherstates that, in general,
`
`it is not aware of licensing activities between third parties, including by any ofits
`
`current or former MEMBERS. UNIFIED furtherstates that it is not aware of any
`
`current or former MEMBER who hasreceived a Notice/Licensing letter from
`
`Bradium Technologies, LLC. UNIFIED further states that it is not aware of any
`
`current or former MEMBERthat has been the subject of licensing or enforeement
`
`by Bradium Technologies, LLC.
`
`INTERROGATORYNO.7:
`
`Identify the date on which Unified Patents first became aware of the °239
`
`PATENT.
`
`RESPONSENO.7:
`
`UNIFIEDstates thatit first became aware of the °239 PATENTonor about
`
`June 17, 2015.
`
`INTERROGATORYNO.8:
`
`Without disclosing privileged information, identify how Unified Patentsfirst
`
`became aware of(a) the 7239 PATENT,(b) Bradium Technologies, LLC, and (c)
`
`ActiveUS 169439723v.1
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`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`any other patent owned by Bradium Technologies, LLC, including the identity of
`
`any outside parties who may haveprovidednotice or other information concerning
`
`the °239 PATENT to Unified Patents and identify and documentspertaining to parts
`
`(a), (b), or (c).
`
`RESPONSE NO.8:
`
`UNIFIEDstates thatit first became aware of Bradium Technologies, LLC and
`
`patents it owns, including the °239 PATENT,via a filing subscription service e-mail
`
`and Bradium’s public website. UNIFIED furtherstates that it has producedthefiling
`
`subscription service e-mail, dated June 17, 2015, which has been marked with the
`
`identifiers UP-000001 through UP-000010. UNIFIED further states there are no
`
`other non-privileged documents pertaining to Interrogatory No. 8. No outside party,
`
`including any MEMBER, made UNIFIED awareof the ’239 PATENT.
`
`INTERROGATORYNO.9:
`
`Without disclosing privileged information,
`
`identify any written policies
`
`and/or practices that Unified Patents uses when (1) identifying and/or evaluating
`
`potential targets for challenge before the USPTO, and (2) selecting and pursuing
`
`particular patents for challenge before the USPTO and identify any documents
`
`pertaining to such policies and/or practices.
`
`RESPONSENO.9:
`
`ActiveUS 169439723v.1
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`Unified Patents Inc. v. Bradium Technologies LLC
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`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`As stated in the Response to Interrogatory No. 1, UNIFIED has sole and
`
`absolute discretion over its decision to contest patents through the USPTO’s post-
`
`grant proceedings. Based on its own analysis, UNIFIED determines which patents
`
`are worth pursuing in terms of searching for prior art or taking action, including
`
`filing an IPR. UNIFIED’s decisionsto file an IPR are made independently without
`
`the input, assistance, or approval of its MEMBERS. Should UNIFIED decide to
`
`challenge a patent in a post-grant proceeding, UNIFIED controls every aspect of
`
`such a challenge, including controlling which patent and claims to challenge, which
`
`prior art to apply and the groundsraised in the challenge, and whento bring any
`
`challenge.
`
`To the extent that Interrogatory No. 9 relates to non-privileged material and
`
`solely to internal legal decision-making and in the interest of avoiding delay and
`
`without waiving any applicable privilege, UNIFIEDstates that there are no written
`
`policies UNIFIED uses when (1) identifying and/or evaluating potential patents for
`
`challenge before the USPTO,and (2) selecting and pursuing particular patents for
`
`challenge before the USPTO. UNIFIEDfurtherstates thatit has internal discussions
`
`between UNIFIED’s employees and outside counsel that include no third party.
`
`UNIFIED further states its practices include identifying current patents to target
`
`based on publicly available information obtained solely through UNIFIED’s own
`
`independent search of publicly available legal databases, assignment records,
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`ActiveUS 169439723v.1
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`15
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`US. 9,253,239
`secondary marketsales, and other similar available means. UNIFIEDfurtherstates
`
`its practices include legal analysis of the patent, including analysis of the potential
`
`target’s claims and UNIFIED own internal determinationofthe likelihood of success
`
`in an IPR proceeding.
`
`INTERROGATORYNO.10:
`
`Identify the time periods during which the membersorentities identified in
`
`responseto Interrogatory No. 6 have been Unified Patents MEMBERS.
`
`RESPONSENO.10:
`
`UNIFIEDstates it is not aware of any current or former MEMBER who has
`
`been sued by Bradium Technologies, LLC. UNIFIEDfurtherstates that, in general,
`
`it is not aware oflicensing by third parties, including by any of its current or former
`
`MEMBERS. UNIFIEDfurtherstates that it is not aware of any current or former
`
`MEMBERwhohas received a Notice/Licensing letter from Bradium Technologies,
`
`LLC. UNIFIEDfurtherstates thatit is not aware of any current or former MEMBER
`
`which was or will be the subject of potential licensing or enforcement by Bradium
`
`Technologies, LLC.
`
`INTERROGATORYNO.11:
`
`Identify all Unified Patents members from the past two years.
`
`RESPONSENO.11:
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`ActiveUS 169439723v.1
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`16
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`U.S. 9,253,239
`UNIFIEDobjects to Interrogatory No. 11 as redundant of Interrogatory No.
`
`5. UNIFIED states that it has provided the relevant list of membersofits “Content
`
`Delivery” NPE Zonein its Responseto Interrogatory No.5.
`
`INTERROGATORYNO.12:
`
`Identify payments made to Unified Patents by the entities identified in
`
`response to Interrogatory No.6.
`
`RESPONSENO.12:
`
`UNIFIEDstates that no such paymentsexist.
`
`INTERROGATORYNO.13:
`
`Identify any Board Members, significant shareholders, and any otherentities
`
`or individuals who own orcontrol Unified Patents.
`
`RESPONSENO.13:
`
`UNIFIED states that Kevin Jakel and Shawn Ambwani are the sole
`
`shareholders, owners, and controllers of Unified Patents; UNIFIED further states
`
`that no such otherentities or individuals exist.
`
`INTERROGATORYNO.14:
`
`Identify any law firm(s) Unified Patents has retained or paid in connection
`
`with THE INSTANTIPR.
`
`RESPONSENO.14:
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`ActiveUS 169439723v.1
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`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`UNIFIED objects to the extent that Interrogatory No. 14 seeks privileged
`
`information.
`
`To the extent
`
`that
`
`Interrogatory No.
`
`14 seeks non-privileged
`
`information, UNIFIED objects as unduly burdensomebecauseits counsel of record
`
`in THE INSTANTIPRis a matter of public record andis therefore as available to
`
`Bradium Technologies, LLC as it
`
`is to UNIFIED. No other counsel has been
`
`retained or paid in connection to this matter.
`
`INTERROGATORYNO.15:
`
`Identify (a) the total number of IPRs Unified has filed since 2016 and, ofthat
`
`total, (b) the numberoffiled IPRs related to district court litigation that had already
`
`been filed against Unified membersidentified in the response to Interrogatory No. 5
`
`above.
`
`RESPONSENO.15:
`
`UNIFIEDobjects to part (a) of Interrogatory No. 15 as unduly burdensome
`
`because the total number of IPRs UNIFIEDhas filed since 2016 is a matter of public
`
`record and is therefore as available to Bradium Technologies, LLC as it
`
`is to
`
`UNIFIED. UNIFIED objects to part (b) of Interrogatory No. 15 as unduly
`
`burdensome because the number of IPRs filed by UNIFIED which are related to
`
`district court litigation filed against any MEMBERincluded in the Response to
`
`Interrogator No. 5 is now as available to Bradium Technologies, LLC as it is to
`
`UNIFIED. UNIFIEDstates that it has provided the relevant list of MEMBERS in
`
`ActiveUS 169439723v.1
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`18
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`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 19 of 23
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`UNIFIED PATENTS EXHIBIT 1032
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`PUBLIC REDACTED VERSION
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`PUBLIC REDACTED VERSION
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`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`its Response to Interrogatory No. 5 and therefore the number of IPRsfiled by
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`UNIFIED which arerelated to district court litigation filed against any MEMBER
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`included in the Response to Interrogator No. 5 is matter of public record andis as
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`available to Bradium Technologies, LLCas it is to UNIFIED.
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`INTERROGATORYNO.16:
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`Identify Unified’s revenue as a percentage by source (e.g., membership fees
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`versus any other sources of revenue), by year, since 2016.
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`RESPONSENO. 16:
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`UNIFIED states that
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`the following table presents the percentage of
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`UNIFIED’S revenue that was derived from member subscription fees, annually,
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`since 2016. These figures are approximate and do not accountfortrivial revenue
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`sources. Accordingly, the percentages are roundedto the nearest whole number:
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`Percentage of Unified’s Revenue
`
`
`
`Year
`
`Coming from Member Subscription
`
`Fees
`
`2016||
`
`2017
`a
`|
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`2018 (1st quarter)
`||
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`INTERROGATORYNO.17:
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`ActiveUS 169439723v.1
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`19
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`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 20 of 23
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`UNIFIED PATENTS EXHIBIT 1032
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`PUBLIC REDACTED VERSION
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`PUBLIC REDACTED VERSION
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`Identify Unified’s costs/expenses as
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`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`a percentage by category (e.g.,
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`expenditures expended on IPRs as a percentageoftotal expenditures), by year, since
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`2016 and identify the line items included in amounts expended on IPRs.
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`RESPONSENO.17:
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`UNIFIED states following table presents the percentage of UNIFIED’s
`
`expenses which was expended on IPRs, annually since 2016. These figures are
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`rounded to the nearest whole number:
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`2018 (1st quarter)
`
`Percentage of Unified’s Expenses
`
`Expended on IPRs
`
`
`
`
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`ActiveUS 169439723v.1
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`20
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`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 21 of 23
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`UNIFIED PATENTS EXHIBIT 1032
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`PUBLIC REDACTED VERSION
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`PUBLIC REDACTED VERSION
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`Unified Patents Inc.
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`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
`
`/Daniel V. Williams/
`By:
`Daniel V. Williams, Reg. No. 45,221
`Wilmer Cutler Pickering Hale and Dorr
`LLP 1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: Daniel. Williams@wilmerhale.com
`
`ActiveUS 169439723v.1
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`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 22 of 23
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`UNIFIED PATENTS EXHIBIT 1032
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`PUBLIC REDACTED VERSION
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`PUBLIC REDACTED VERSION
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`IPR2018-00952 Voluntary Interrogatory Responses
`U.S. 9,253,239
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`VERIFICATION
`
`
`I, Kevin Jakel, state that I am CEO of Unified Patents Inc., and that I am
`authorized to make this verification for and on its behalf.
`I certify that I have read
`the foregoing Interrogatory responses, and that the responses are true and accurate
`to the best of my own knowledge, information, and belief. Further, I make this
`verification with the knowledge that willful false statements and the like so made
`are punishable by fine or imprisonment, or both, under Section 1001 of Title 18 of
`the United States Code and that such willful false statements may jeopardize the
`results of these proceedings.
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`I declare under penalty of perjury that the foregoingis true and correct.
`
`By:
`
`ieie,
`
`Kevin Jakél
`
`ActiveUS 169439723v.1
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`22
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`UNIFIED PATENTS EXHIBIT 1032
`Bradium Exhibit 2013
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 23 of 23
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`UNIFIED PATENTS EXHIBIT 1032
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`PUBLIC REDACTED VERSION
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`