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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
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`LKQ Corporation and Keystone Automotive Industries, Inc.,
`
`Petitioners,
`
`v.
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`GM Global Technology Operations LLC,
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`Patent Owner.
`_________________
`
`IPR2020-00534
`U.S. Design Patent No. D797,625 S
`
`__________________________
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`DECLARATION OF BARRY F. IRWIN, P.C. IN SUPPORT OF
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`PETITIONERS’ REPLY TO PATENT OWNER’S RESPONSE
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`Ex. 1045, LKQ v. GM
`IPR2020-00534
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`
`
`IPR2020-00534
`D797,625 S
`
`I, Barry F. Irwin, declare as follows:
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`1.
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`The facts set forth herein are based on my personal knowledge and/or
`
`the documents attached hereto (that I have personal knowledge of
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`sufficient to authenticate them), and are true and correct to the best of
`
`my personal knowledge, belief, recollection, and understanding.
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`2.
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`I am over the age of eighteen, and if asked to do so, I could
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`competently testify to the matters set forth herein.
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`3.
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`I am the founding attorney at Irwin IP LLC, 222 South Riverside
`
`Plaza, Suite 2350, Chicago, Illinois 60606, and serve as Lead Counsel
`
`for the Petitioners, LKQ Corporation’s and Keystone Automotive
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`Industries, Inc., in this proceeding. I submit this declaration in support
`
`of Petitioner’s Reply to Patent Owner’s Response.
`
`4.
`
`Submitted herewith as Exhibit 1017 is a true and correct copy of U.S.
`
`Design Patent No. D766,149.
`
`5.
`
`Submitted herewith as Exhibit 1018 is a true and correct copy of U.S.
`
`Design Patent No. D704,607.
`
`6.
`
`Submitted herewith as Exhibit 1019 is a true and correct copy of U.S.
`
`Design Patent No. D763,753.
`
`7.
`
`Submitted herewith as Exhibit 1020 is a true and correct copy of U.S.
`
`Design Patent No. D686,536.
`
`2
`
`
`
`IPR2020-00534
`D797,625 S
`
`8.
`
`Submitted herewith as Exhibit 1021 is a true and correct copy of U.S.
`
`Design Patent No D692,798.
`
`9.
`
`Submitted herewith as Exhibit 1022 is a true and correct copy of U.S.
`
`Design Patent No. 762,151.
`
`10.
`
`Submitted herewith as Exhibit 1023 is a true and correct copy of U.S.
`
`Design Patent No. D713,298.
`
`11.
`
`Submitted herewith as Exhibit 1024 is a true and correct copy of U.S.
`
`Design Patent No. D764,362.
`
`12.
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`Submitted herewith as Exhibit 1025 is a true and correct copy of U.S.
`
`Design Patent No. D785,521.
`
`13.
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`Submitted herewith as Exhibit 1026 is a true and correct copy of U.S.
`
`Design Patent No. D739,306.
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`14.
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`Submitted herewith as Exhibit 1027 is a true and correct copy of U.S.
`
`Design Patent No. D722,282.
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`15.
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`Submitted herewith as Exhibit 1028 is a true and correct copy of U.S.
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`Design Patent No. D784,857.
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`16.
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`Submitted herewith as Exhibit 1029 is a true and correct copy of U.S.
`
`Design Patent No. D613,645.
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`17.
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`Submitted herewith as Exhibit 1030 is a true and correct copy of U.S.
`
`Design Patent No. D611,387.
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`3
`
`
`
`IPR2020-00534
`D797,625 S
`
`18.
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`Submitted herewith as Exhibit 1031 is a true and correct copy of U.S.
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`Design Patent No. D704,103.
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`19.
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`Submitted herewith as Exhibit 1032 is a true and correct copy of U.S.
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`Design Patent No. D717,696.
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`20.
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`Submitted herewith as Exhibit 1033 is a true and correct copy of U.S.
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`Design Patent No. 692,798.
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`21.
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`Submitted herewith as Exhibit 1034 is a true and correct copy of U.S.
`
`Design Patent No D680,909.
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`22.
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`Submitted herewith as Exhibit 1035 is a true and correct copy of U.S.
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`Design Patent No. D615,458.
`
`23.
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`Submitted herewith as Exhibit 1036 is a true and correct copy of U.S.
`
`Design Patent No. D699,629.
`
`24.
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`Submitted herewith as Exhibit 1037 is a true and correct copy of U.S.
`
`Design Patent No. D781,180.
`
`25.
`
`Submitted herewith as Exhibit 1038 is a true and correct copy of U.S.
`
`Design Patent No. D635,488.
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`26.
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`Submitted herewith as Exhibit 1039 is a true and correct copy of U.S.
`
`Design Patent No. D773,361.
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`27.
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`Submitted herewith as Exhibit 1040 is a true and correct copy of U.S.
`
`Design Patent No. D699,649.
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`4
`
`
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`IPR2020-00534
`D797,625 S
`
`28.
`
`Submitted herewith as Exhibit 1041 is a true and accurate collage
`
`depicting images of the “crowded field” prior art patents cited as
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`“most similar” in the Declaration of T. Peters, the images comprising
`
`which were each obtained from U.S. Design Patent No. D797,625,
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`U.S. Design Patent D773,340, and the aforementioned Exhibits 1017–
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`1022.
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`29.
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`Submitted herewith as Exhibit 1042 is a true and accurate collage
`
`depicting images of the “crowded field” prior art patents cited in the
`
`Declaration of T. Peters, the images comprising which were each
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`obtained from U.S. Design Patent No. D797,625, U.S. Design Patent
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`No. D773,340, and the aforementioned Exhibits 1023–1042.
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`30.
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`Submitted herewith as Exhibit 1043 is a true and accurate copy of the
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`Declaration of Jason C. Hill in Support of Petitioners’ Reply to Patent
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`Owner’s Response.
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`31.
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`Submitted herewith as Exhibit 1044 is a true and accurate copy of the
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`transcript of the Deposition of Thomas V. Peters.
`
`5
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`
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`IPR2020-00534
`D797,625 S
`
`32.
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`I declare under penalty of perjury under the laws of the United States
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`of America that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are
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`believed to be true; and further that these statements were made with
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`the knowledge that willful false statements and the like so made are
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`punishable by fine or imprisonment, or both, under Section 1001 of
`
`Title 18 of the United States Code.
`
`Dated: January 26, 2021
`Chicago, Illinois
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`Respectfully submitted,
`
`/Barry F. Irwin/
`Barry F. Irwin, P.C.
`Reg. No. 36,557
`birwin@irwinip.com
`Irwin IP LLC
`222 S. Riverside Plaza, Ste. 2350
`Chicago, IL 60606
`Phone: 312.667.6080
`
`6
`
`
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