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