`Patent No. 9,737,154
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`AMERICAN NATIONAL MANUFACTURING INC.,
`Petitioner,
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`v.
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`SLEEP NUMBER CORPORATION
`f/k/a SELECT COMFORT CORPORATION,
`Patent Owner.
`
`____________
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`Case No. IPR2019-00500, Patent No. 9,737,154
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`DECLARATION OF BRIAN T. BEAR IN SUPPPORT OF
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`PETITIONER’S MOTION FOR ADDITIONAL DISCOVERY
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`1
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`WA 14041830.1
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`American National Manufacturing, Inc.
`EXHIBIT 1041
`IPR2019-00500
`Page 1
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`Case No. IPR2019-00500
`Patent No. 9,737,154
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`I, Brian T. Bear, declare and state as follows:
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`1.
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`I am an attorney with the law firm of Spencer Fane LLP. I represent
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`Petitioner, American National Manufacturing Inc., in connection with these Inter
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`Partes Review proceedings. I make this declaration in support of Petitioner’s Motion
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`for Additional Discovery.
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`2.
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`Exhibit 1042 is a true and correct copy of Sleep Number Corporation’s
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`most recent 10-K SEC Annual Report that I downloaded off of EDGAR, the
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`Securities and Exchange Commission’s publically accessible data base for
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`publically traded company reports, on December 18, 2019. Links to this report are
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`publically
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`accessible
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`at
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`the
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`following
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`url:
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`https://www.sec.gov/Archives/edgar/data/827187/000156459019004499/00015645
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`90-19-004499-index.htm
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`3.
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`Exhibit 1043 is a true and correct copy of the web page entitled “About
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`Us” which is found on Sleep Number Corporation’s publically available website. I
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`last accessed this website on December 18, 2019. The web page is publically
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`accessible at the following url: http://newsroom.sleepnumber.com/about-us
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`4.
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`Exhibit 1044 is a true and correct copy of a new release entitled “Sleep
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`Number and NFL Announce Groundbreaking Partnership to Emphasize the
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`Importance of Sleep on player performance” released on January 31, 2018. I
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`downloaded the press release from Sleep Number Corporation’s publically available
`2
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`WA 14041830.1
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`American National Manufacturing, Inc.
`EXHIBIT 1041
`IPR2019-00500
`Page 2
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`
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`Case No. IPR2019-00500
`Patent No. 9,737,154
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`website on December 18, 2019. The press release is publically accessible at the
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`following url: https://sleepnumber.new-media-release.com/super_bowl_LII/
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`5.
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`Exhibit 1045 is a true and correct copy of the petition that Sleep
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`Number Corporation filed against John Baxter and Dires, LLC on or about
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`November 16, 2012. This document was publically obtained from PACER and is
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`listed as Docket Entry Number 1, of Case 0:12-CV-02899-DWF-SER.
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`FURTHER DECLARANT SAYTEH NOT
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`Date: December 19, 2019
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`
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`By /s/Brian Bear .
`Brian Bear (pro hac vice)
`Spencer Fane LLP
`1000 Walnut Street, Suite 1400
`Kansas City, Missouri 64106-2140
`Telephone: (816) 474-8100
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`3
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`WA 14041830.1
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`American National Manufacturing, Inc.
`EXHIBIT 1041
`IPR2019-00500
`Page 3
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