`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`NetApp, Inc. and Hewlett Packard Enterprise Co.
`
`Petitioners
`
`v.
`
`KOM Software Inc.
`
`Patent Owner
`
`Patent No. 7,536,524
`Case No. IPR2019-00605
`
`DECLARATION OF VALENCIA DANIEL
`
`i
`
`Page 1 of 3
`
`NETAPP-HPE EXHIBIT 1025
`
`
`
`U.S. Patent No. 7,536,524
`Declaration of Valencia Daniel
`
`I, Valencia Daniel, declare as follows:
`I have prepared this Declaration in connection with the Petition of
`1.
`
`NetApp, Inc., and Hewlett Packard Enterprise Co., for inter partes review of U.S.
`
`Patent No. 7,076,524 (“the ’524 patent”).
`
`2.
`
`I am currently a Litigation Legal Assistant at Finnegan, Henderson,
`
`Farabow, Garrett & Dunner, LLP, 271 17th Street, NW, Suite 1400, Atlanta, GA
`
`30362-6209.
`
`3.
`
`I am over eighteen years of age and am competent to make this
`
`Declaration. I make this Declaration based on my own personal knowledge.
`
`4.
`
`I was asked to create comparisons of the following documents:
`
`• Canadian Patent No. 2,270,651 and U.S. Patent No. 7,076,624;
`
`• U.S. Patent No. 7,076,624 and U.S. Patent No. 7,536,524
`
`5.
`
`To create these exhibits, after pdf versions of the specifications from
`
`Canadian Patent No. 2,270,651, U.S. Patent No. 7,076,624, and U.S. Patent No.
`
`7,536,524 were converted into Microsoft Word documents, I used Microsoft
`
`Word’s “Compare” utility to generate redline comparisons. The comparisons show
`
`the differences between the respective documents, with the redlines indicating
`
`revisions to the original document.
`
`Page 2 of 3
`
`
`
`6.
`
`The comparisons are marked as Exs. 1024 (comparison of U.S. Patent
`
`No. 7,076,624 and U.S. Patent No. 7,536,524) and 1026 (comparison of Canadian
`
`Patent No. 2,270,651 and U.S. Patent No. 7,076,624).
`
`7.
`
`I declare that all statements made herein of my knowledge are true,
`
`and 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
`
`Section 1001 of Title 18 of the United States Code.
`
`
`
`Date: January 25, 2019
`
`
`By: /Valencia Daniel/
`Valencia Daniel
`Litigation Legal Assistant
`
`
`
`
`
`2
`
`
`Page 3 of 3
`
`
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