IPR2020-00034
`U.S. Patent No. 8,023,580
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`APPLE INC.,
`
`Petitioner,
`
`v.
`
`REMBRANDT WIRELESS TECHNOLOGIES, LP,
`
`Patent Owner.
`
`____________
`
`Case IPR2020-00034
`
`U.S. Patent No. 8,023,580
`
`____________
`
`DECLARATION OF DRAGO GREGOV IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW OF UNITED STATES PATENT NO. 8,023,580
`
`Apple Exhibit 1131
`Apple Inc. v. Rembrandt Wireless
`IPR2020-00034
`Page 00001
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`
`U.S. Patent No. 8,023,580
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`APPLE INC.,
`
`Petitioner,
`
`v.
`
`REMBRANDT WIRELESS TECHNOLOGIES, LP,
`
`Patent Owner.
`
`____________
`
`Case IPR2020-00034
`
`U.S. Patent No. 8,023,580
`
`____________
`
`DECLARATION OF DRAGO GREGOV IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW OF UNITED STATES PATENT NO. 8,023,580
`
`Apple Exhibit 1131
`Apple Inc. v. Rembrandt Wireless
`IPR2020-00034
`Page 00001
`
`
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`IPR2020-00034
`U.S. Patent No. 8,023,580
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`I, Drago Gregov, make the following Declaration pursuant to 28 U.S.C.
`
`§ 1746:
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`1.
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`I am a Lead Litigation Paralegal Specialist at the law firm of Ropes &
`
`Gray LLP.
`
`2.
`
`I provide this Declaration in support of the Petition for Inter Partes
`
`Review of United States Patent No. 8,023,580 that is being requested at the United
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`States Patent and Trademark Office (“USPTO”) by Petitioner Apple Inc. Unless
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`otherwise stated, the facts stated in this Declaration are based on my personal
`
`knowledge.
`
`3.
`
`Ex. 1101 is a true and correct copy of United States Patent No.
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`8,023,580, which was obtained from the United States Patent and Trademark
`
`Office’s Public Patent Application Information Retrieval system (USPTO Public
`
`PAIR) on September 30, 2019. This document has been marked with an exhibit
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`label and page numbers on each page at the bottom right corner. However, no
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`alterations, other than these noted markings, have been made to this document.
`
`4.
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`Ex. 1102 is a true and correct copy of the entire prosecution Image File
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`Wrapper of United States Patent No. 8,023,580, which was obtained from the
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`USPTO’s Public PAIR system on September 30, 2019. This document has been
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`marked with an exhibit label and page numbers on each page at the bottom right
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`1
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`IPR2020-00034 Page 00002
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`IPR2020-00034
`U.S. Patent No. 8,023,580
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`corner. However, no alterations, other than these noted markings, have been made
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`to this document.
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`5.
`
`Ex. 1104 is a true and correct copy of United States Patent No.
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`6,075,814, which was obtained from the USPTO’s Public PAIR system on
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`September 30, 2019. This document has been marked with an exhibit label and page
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`numbers on each page at the bottom right corner. However, no alterations, other than
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`these noted markings, have been made to this document.
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`6.
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`Ex. 1105 is a true and correct copy of United States Patent No.
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`5,583,922, which was obtained from the USPTO’s Public PAIR system on
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`September 30, 2019. This document has been marked with an exhibit label and page
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`numbers on each page at the bottom right corner. However, no alterations, other than
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`these noted markings, have been made to this document.
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`7.
`
`Ex. 1106 is a true and correct copy of United States Patent No.
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`4,549,293, which was obtained from the USPTO’s Public PAIR system on
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`September 30, 2019. This document has been marked with an exhibit label and page
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`numbers on each page at the bottom right corner. However, no alterations, other than
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`these noted markings, have been made to this document.
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`8.
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`Ex. 1110 is a true and correct copy of the entire prosecution Image File
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`Wrapper of Ex Parte Reexamination No. 90/013,808 of United States Patent No.
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`8,023,580, which was obtained the USPTO’s Public PAIR system on September 30,
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`2
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`IPR2020-00034 Page 00003
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`IPR2020-00034
`U.S. Patent No. 8,023,580
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`2019. This document has been marked with an exhibit label and page numbers on
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`each page at the bottom right corner. However, no alterations, other than these noted
`
`markings, have been made to this document.
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`9.
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`Ex. 1111 is a true and correct copy of the Claim Construction
`
`Memorandum and Order, Docket No. 114, from Rembrandt Wireless Techs., LP v.
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`Samsung Elecs. Co., Ltd., No. 2:13-cv-00213-JRG, (E.D. Tex. July 10, 2014), which
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`was obtained from the United States Court’s Public Access to Court Electronic
`
`Records (PACER) system on September 30, 2019. This document has been marked
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`with an exhibit label and page numbers on each page at the bottom right corner.
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`However, no alterations, other than these noted markings, have been made to this
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`document.
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`10. Ex. 1112 is a true and correct copy of the April 17, 2017 Federal Circuit
`
`Decision, Docket No. 66, from Rembrandt v. Samsung, United States Court of
`
`Appeals for the Federal Circuit, Case No. 16-1729, which was obtained from the
`
`PACER system on September 30, 2019. This document has been marked with an
`
`exhibit label and page numbers on each page at the bottom right corner. However,
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`no alterations, other than these noted markings, have been made to this document.
`
`11. Ex. 1113 is a true and correct copy of the P.R. 4-3 Joint Claim
`
`Construction Statement, Docket No. 70, from Rembrandt Wireless Technologies, LP
`
`v. Apple Inc., No. 2:19-cv-00025-JRG (E.D. Tex. Sept. 9, 2019), which was obtained
`
`3
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`IPR2020-00034 Page 00004
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`IPR2020-00034
`U.S. Patent No. 8,023,580
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`from the PACER system on September 30, 2019. This document has been marked
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`with an exhibit label and page numbers on each page at the bottom right corner.
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`However, no alterations, other than these noted markings, have been made to this
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`document.
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`12. Ex. 1114 is a true and correct copy of United States Provisional Patent
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`Application No. 60/067,562, which was obtained from the USPTO’s Public PAIR
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`system on September 30, 2019. This document has been marked with an exhibit
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`label and page numbers on each page at the bottom right corner. However, no
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`alterations, other than these noted markings, have been made to this document.
`
`13. Ex. 1115 is a true and correct copy of the Final Written Decision, Paper
`
`47, from Samsung Elecs. Co. Ltd., et al. v. Rembrandt Wireless Techs., LP, IPR2014-
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`00518 (P.T.A.B. Sept. 17, 2015), which was obtained from PTAB E2E on
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`September 30, 2019. This document has been marked with an exhibit label and page
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`numbers on each page at the bottom right corner. However, no alterations, other than
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`these noted markings, have been made to this document.
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`14. Ex. 1116 is a true and correct copy of Rembrandt’s Response in
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`Opposition to Samsung Defendants’ Rule 50(b) Renewed Motion for Judgment as a
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`Matter of Law and/or Rule 59(a) Motion for a New Trial on Liability Issues, Docket
`
`No. 335, from Rembrandt Wireless Techs., LP v. Samsung Elecs. Co., Ltd., No. 2:13-
`
`cv-00213-JRG-RSP (E.D. Tex. Sept. 7, 2015), which was obtained from the PACER
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`4
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`IPR2020-00034 Page 00005
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`
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`IPR2020-00034
`U.S. Patent No. 8,023,580
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`system on September 30, 2019. This document has been marked with an exhibit
`
`label and page numbers on each page at the bottom right corner. However, no
`
`alterations, other than these noted markings, have been made to this document.
`
`15. Ex. 1117 is a true and correct copy of Samsung Defendants’ Reply to
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`Rule 50(b) Renewed Motion for Judgment as a Matter of Law and/or Rule 59(a)
`
`Motion for New Trial on Liability Issues, Docket No. 338, from Rembrandt Wireless
`
`Techs., LP v. Samsung Elecs. Co., Ltd., No. 2:13-cv-00213-JRG-RSP (E.D. Tex.
`
`Sept. 22, 2015), which was obtained from the PACER system on September 30,
`
`2019. This document has been marked with an exhibit label and page numbers on
`
`each page at the bottom right corner. However, no alterations, other than these noted
`
`markings, have been made to this document.
`
`16. Ex. 1119 is a true and correct copy of the Memorandum Opinion and
`
`Order, Docket No. 352, from Rembrandt Wireless Techs., LP v. Samsung Elecs. Co.,
`
`Ltd., No. 2:13-cv-00213-JRG-RSP, (E.D. Tex. Feb. 17, 2016), which was obtained
`
`from the PACER system on September 30, 2019. This document has been marked
`
`with an exhibit label and page numbers on each page at the bottom right corner.
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`However, no alterations, other than these noted markings, have been made to this
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`document.
`
`17. Ex. 1121 is a true and correct copy of the Declaration of Jon Mears and
`
`attached article titled “Communication Protocols for Embedded Systems,” by
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`5
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`IPR2020-00034 Page 00006
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`IPR2020-00034
`U.S. Patent No. 8,023,580
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`B. Upender and P. Koopman, Jr., which is Ex. 1218 from Samsung Elecs. Co. Ltd.,
`
`et al. v. Rembrandt Wireless Techs., LP, IPR2014-00518, and which was obtained
`
`from PTAB E2E on September 30, 2019, Also attached is a true and correct copy
`
`of the article titled “Communication Protocols for Embedded Systems,” by
`
`B. Upender
`
`and P. Koopman,
`
`Jr., which was
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`downloaded
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`from
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`https://users.ece.cmu.edu/-koopman/protsrvy/protsrvy.html on October 8, 2019.
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`These documents have been marked with an exhibit label and page numbers on each
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`page at the bottom right corner. However, no alterations, other than these noted
`
`markings, have been made to these documents.
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`18. Ex. 1122 is a true and correct copy of the Petition for Inter Partes
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`Review of U.S. Patent No. 8,023,580 from Samsung Elecs. Co. Ltd., et al. v.
`
`Rembrandt Wireless Techs., LP, IPR2014-00518, Pap. 1 (P.T.A.B. Mar. 20, 2014),
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`which was obtained from PTAB E2E on September 30, 2019. This document has
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`been marked with an exhibit label and page numbers on each page at the bottom
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`right corner. However, no alterations, other than these noted markings, have been
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`made to this document.
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`19. Ex. 1123 is a true and correct copy of the Decision Institution of Inter
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`Partes Review 37 C.F.R. §42.108 from Samsung Elecs. Co. Ltd., et al. v. Rembrandt
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`Wireless Techs., LP, IPR2014-00518, Pap. 16 (P.T.A.B. Sept. 23, 2014). This
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`document has been marked with an exhibit label and page numbers on each page at
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`6
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`IPR2020-00034 Page 00007
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`IPR2020-00034
`U.S. Patent No. 8,023,580
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`20. Ex. 1124 is a true and correct copy of the Declaration of David
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`Goodman from Samsung Elecs. Co. Ltd., et al. v. Rembrandt Wireless Techs., LP,
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`IPR2014-00518 (Ex. 1220). This document has been marked with an exhibit label
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`and page numbers on each page at the bottom right corner. However, no alterations,
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`other than these noted markings, have been made to this document.
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`21. Ex. 1127 is a true and correct copy of European Patent Application No.
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`95107807.0 (“Schuermann”), which was obtained from the Espacenet on October 8,
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`2019. This document has been marked with an exhibit label and page numbers on
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`each page at the bottom right corner. However, no alterations, other than these noted
`
`markings, have been made to this document.
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`22.
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`I hereby declare that all statements made herein of my own knowledge
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`are true and that all statements made on information and belief are believed to be
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`true; and further that these statements were made with the knowledge that willful
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`false statements and the like so made are punishable by fine or imprisonment, or
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`both, under 18 U.S.C. 1001. If called to testify as to the truth of the matters stated
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`herein, I could and would testify competently.
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`///
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`///
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`7
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`IPR2020-00034 Page 00008
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`IPR2020-00034
`U.S. Patent No. 8,023,580
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`23.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed this 5th day of November, 2019, in East Palo Alto, California.
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`
`
`/s/ Drago Gregov
`Drago Gregov
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`8
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`IPR2020-00034 Page 00009
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