`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`INTEL CORPORATION
`Petitioner,
`
`v.
`
`PACT XPP SCHWEIZ AG
`Patent Owner
`________________
`
`Case IPR2020-00532
`U.S. Patent No. 8,471,593
`________________
`
`DECLARATION OF ZIYONG LI
`IN SUPPORT OF PATENT OWNER’S SUR-REPLY
`
`
`
`PACT - Ex. 2020.0001
`
`
`
`I, Ziyong Li, do hereby declare as follows:
`
`1.
`
`I have been retained to represent Patent Owner, PACT XPP SCHWEIZ AG
`
`(“PACT”), in the matter of PACT XPP SCHWEIZ AG v. Intel Corporation,
`
`Case No. 19-1006 in the United States District Court for the District of
`
`Delaware (“the Delaware Action”).
`
`2.
`
`In the course of discovery in the Delaware Action, as of August 6, 2020,
`
`Petitioner (“Intel”) has produced over 100,000 documents, which account
`
`for over 2,200,000 pages; and PACT has produced over 100,000 documents,
`
`which account for over 2,700,000 pages. In total, over 5,000,000 pages have
`
`already been exchanged between the parties.
`
`3.
`
`Intel has filed twelve petitions for inter partes review against PACT’s
`
`patents which cumulatively include challenges against over 100 patent
`
`claims on more than 50 grounds.
`
`4.
`
`Depositions have been scheduled for the Delaware Action. One deposition is
`
`set for each of the following dates in 2020: August 21, September 1,
`
`September 2, September 3, September 4, September 8, September 10,
`
`September 11, September 15, September 16, September 18, September 22,
`
`September 24, September 25, September 29, September 30, and October 2.
`
`5.
`
`In Intel’s declaration, Ex. 1042, Raymundo Avila declared that he executed
`
`service of the hard-copy documents of the IPR petitions by hand-delivery at
`
`1
`
`PACT - Ex. 2020.0002
`
`
`
`Quinn Emanuel's Los Angeles office and Melody Ormano signed for the
`
`delivery. After a reasonable investigation with Quinn Emanuel staff, I
`
`understand that Melody Ormano is not an employee of Quinn Emanuel and
`
`does not work for Quinn Emanuel’s office building in Los Angeles.
`
`6.
`
`I hereby declare under penalty of perjury under the laws of the United States
`
`of America that the foregoing is true and correct, and that all statements
`
`made of my own knowledge are true and that all statements made on
`
`information and belief are believed to be true. I understand that willful false
`
`statements are punishable by fine or imprisonment or both. See 18 U.S.C.
`
`§ 1001.
`
`
`
`Date: August 6, 2020
`
`Respectfully submitted,
`
`
`
`
`
`
`
`/Ziyong Li/
`Ziyong Li
`
`
`2
`
`PACT - Ex. 2020.0003
`
`
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