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`BEFORE THE PA TENT TRIAL AND APPEAL BOARD
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`ZTE (USA), INC.
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`Petitioner,
`
`V.
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`CYWEE GROUP LTD.
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`(record) Patent Owner.
`
`IPR No. IPR2019-00525
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`U.S. Patent No. 8,552,978
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`DECLARATION OF ANDREA SHOFFSTALL
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`ZTE Exhibit 1052
`Page 1 of 5
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`
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`I, Andrea Shoffstall, declare as follows:
`
`Shoffstall Declaration ('978 Patent)
`IPR No. 2019-00525
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`1.
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`I am an attorney at Brinks Gilson & Lione. I am licensed to
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`practice law in the state of Illinois.
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`2.
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`I am over 18 years of age and I make this declaration based upon
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`my own knowledge, personal experience, and belief.
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`If called upon, I can
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`competently testify to the facts stated in this declaration.
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`3.
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`I assisted with the collection and assembly of the documents
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`included as Exhibits supporting Petitioner's Petition for Inter Partes Review of
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`U.S. Patent No. 8,552,978, bearing Inter Partes Review number IPR2019-00525,
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`to be filed on January 10, 2019.
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`4.
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`Exhibit 1001, as submitted with Petitioner's Petition, is a true
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`and accurate copy of Exhibit 1001 from the IPR2018-01257, Google LLC v.
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`Cywee Group Ltd., obtained from the Patent Trial and Appeal Board End to End
`
`Portal.
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`5.
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`Exhibit 1002, as submitted with Petitioner's Petition, is a true
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`and accurate copy of Exhibit 1002 from the IPR2018-01257, Google LLC v.
`
`Cywee Group Ltd., obtained from the Patent Trial and Appeal Board End to End
`
`Portal.
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`6.
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`Exhibit 1003, as submitted with Petitioner's Petition, is a true
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`and accurate copy of Exhibit 1003 from the IPR2018-01257, Google LLC v.
`
`1
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`ZTE Exhibit 1052
`Page 2 of 5
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`
`
`Shoffstall Declaration ('978 Patent)
`IPR No. 2019-00525
`
`Cywee Group Ltd., obtained from the Patent Trial and Appeal Board End to End
`
`Portal.
`
`7.
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`Exhibit 1004, as submitted with Petitioner's Petition, is a true
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`and accurate copy of Exhibit 1004 from the IPR2018-01257, Google LLC v.
`
`Cywee Group Ltd., obtained from the Patent Trial and Appeal Board End to End
`
`Portal.
`
`8.
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`Exhibit 1005, as submitted with Petitioner's Petition, is a true
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`and accurate copy of Exhibit 1005 from the IPR2018-01257, Google LLC v.
`
`Cywee Group Ltd., obtained from the Patent Trial and Appeal Board End to End
`
`Portal.
`
`9.
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`Exhibit 1006, as submitted with Petitioner's Petition, is a true
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`and accurate copy of Exhibit 1006 from the IPR2018-01257, Google LLC v.
`
`Cywee Group Ltd., obtained from the Patent Trial and Appeal Board End to End
`
`Portal.
`
`10. Exhibit 1007, as submitted with Petitioner's Petition, is a true
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`and accurate copy of Exhibit 1007 from the IPR2018-01257, Google LLC v.
`
`Cywee Group Ltd., obtained from the Patent Trial and Appeal Board End to End
`
`Portal.
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`11. Exhibit 1008, as submitted with Petitioner's Petition, is a true
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`and accurate copy of Exhibit 1008 from the IPR2018-01257, Google LLC v.
`
`2
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`ZTE Exhibit 1052
`Page 3 of 5
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`
`
`Shoffstall Declaration ('978 Patent)
`IPR No. 2019-00525
`
`Cywee Group Ltd., obtained from the Patent Trial and Appeal Board End to End
`
`Portal.
`
`12. Exhibit 1009, as submitted with Petitioner's Petition, is a true
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`and accurate copy of Exhibit 1009 from the IPR2018-01257, Google LLC v.
`
`Cywee Group Ltd., obtained from the Patent Trial and Appeal Board End to End
`
`Portal.
`
`13. Exhibit 1010, as submitted with Petitioner's Petition, is a true
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`and accurate copy of Exhibit 1010 from the IPR2018-01257, Google LLC v.
`
`Cywee Group Ltd., obtained from the Patent Trial and Appeal Board End to End
`
`Portal.
`
`14. Exhibit 1011, as submitted with Petitioner's Petition, is a true
`
`and accurate copy of Exhibit 1011 from the IPR2018-01257, Google LLC v.
`
`Cywee Group Ltd., obtained from the Patent Trial and Appeal Board End to End
`
`Portal.
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`15. Exhibit 1050 as submitted with Petitioner's Petition, is a true and
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`accurate redlined comparison between the current petition and the petition filed
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`by Google in IPR2018-001257, Google LLC v. Cywee Group Ltd.
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`16. Exhibit 1051 as submitted with Petition's Petition is a true and
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`accurate copy of the claim construction order in Cywee Group Ltd. v. Motorola
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`Mobility LLC, l 7-cv-00780 (Jan. 4, 2019), obtained from PACER.
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`3
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`ZTE Exhibit 1052
`Page 4 of 5
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`
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`Shoffstall Declaration ('978 Patent)
`IPR No. 2019-00525
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`I hereby declare that all statements made in this declaration are of my own
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`knowledge and are true, that all statements made on information and belief are
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`believed to be true, and that these statements were made with the knowledge that
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`willful false statements and the like so made are punishable by fine or imprisonment,
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`or both, under 18 U.S.C. § 1001.
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`The contents of this declaration are true under penalty of perjury of the laws
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`of the United States.
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`Dated: January 10, 2019
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`/s/ Andrea Shoffstall
`Andrea Shoffstall
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`4
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`ZTE Exhibit 1052
`Page 5 of 5
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`