throbber
Case IPR2020-01506
` PATENT 10,469,614
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________
`CODE200, UAB; TESO LT, UAB; METACLUSTER LT, UAB; AND
`OXYSALES, UAB,
`
`Petitioners
`
`v.
`
`LUMINATI NETWORKS LTD.,
`
`Patent Owner
`
`_________________________
`
`Case IPR2020-01506
`Patent 10,469,614
`_________________________
`
`
`
`
`
`DECLARATION OF THOMAS M. DUNHAM
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`Luminati Exhibit 2017
`Code200 et al. v. Luminati Networks LTD.
`IPR2020-01506 Page 001
`
`

`

`
`
`IPR2020-01506
`Patent 10,469,614
`
`
`
`
`I, Thomas M. Dunham, declare as follows under penalty of perjury.
`
`1. I am lead counsel for Patent Owner.
`
`2. Concurrently filed with Patent Owner’s Preliminary Response are the following
`
`exhibits.
`
`3. Exhibit 2001 is a true and correct copy of Oxylabs’ Motion To Stay Pending
`
`Inter Partes Reviews (public-redacted) in Luminati v. Teso Lt UAB et al., E.D.
`
`Texas, Case No. 2:19-cv-00395-JRG ECF No. 131.
`
`4. Exhibit 2002 is a true and correct copy of a portion of the Joint Claim
`
`Construction and Prehearing Statement in Luminati v. Teso Lt UAB et al., E.D.
`
`Texas, Case No. 2:19-cv-00395-JRG ECF No. 105-1.
`
`5. Exhibit 2003 is a true and correct copy of Plaintiff’s Markman opening brief in
`
`Luminati v. Teso Lt UAB et al., E.D. Texas, Case No. 2:19-cv-00395-JRG ECF
`
`No. 126.
`
`6. Exhibit 2004 is a true and correct copy of the Defendants’ Markman response
`
`brief in Luminati v. Teso Lt UAB et al., E.D. Texas, Case No. 2:19-cv-00395-
`
`JRG ECF No. 138.
`
`7. Exhibit 2005 is a true and correct copy of Plaintiff’s Markman reply brief in
`
`Luminati v. Teso Lt UAB et al., E.D. Texas, Case No. 2:19-cv-00395-JRG ECF
`
`No. 145.
`
`
`
`2
`
`Luminati Exhibit 2017
`Code200 et al. v. Luminati Networks LTD.
`IPR2020-01506 Page 002
`
`

`

`
`
`IPR2020-01506
`Patent 10,469,614
`
`
`8. Exhibit 2006 is a true and correct copy of a Stipulation filed in IPR2020-01266,
`
`Paper No 14.
`
`9. Exhibit 2007 is a true and correct copy of Oxysales’ Answer (public-redacted)
`
`in Luminati v. Teso Lt UAB et al., E.D. Texas, Case No. 2:19-cv-00395-JRG,
`
`ECF. No. 95.
`
`10. Exhibit 2008 is a November 5, 2020 ECF notice from the district court moving
`
`jury selection from May 3 to May 10, 2021. Luminati v. Teso Lt UAB et al.,
`
`E.D. Texas, Case No. 2:19-cv-00395-JRG.
`
`11. Exhibit 2009 is a true and correct copy of Dr. Rhyne’s Markman Declaration
`
`in Luminati v. Teso Lt UAB et al., E.D. Texas, Case No. 2:19-cv-00395-JRG,
`
`ECF No. 126.
`
`12. Exhibit 2010 is a true and correct copy of the Sur-Reply in the Motion to
`
`Dismiss in Luminati v. Teso Lt UAB et al., E.D. Texas, Case No. 2:19-cv-
`
`00395-JRG ECF No. 47.
`
`13. Exhibit 2011 is a true and correct copy of the Order on the Motion to Dismiss
`
`in Luminati v. Teso Lt UAB et al., E.D. Texas, Case No. 2:19-cv-00395-JRG
`
`ECF No. 85.
`
`14. Exhibit 2012 is a true and correct copy of the Declaration of Thomas Rhyne.
`
`
`
`3
`
`Luminati Exhibit 2017
`Code200 et al. v. Luminati Networks LTD.
`IPR2020-01506 Page 003
`
`

`

`
`
`IPR2020-01506
`Patent 10,469,614
`
`
`15. Exhibit 2013 is a true and correct copy of an Amended Rule 7.1 disclosure
`
`statement from Luminati v. Teso Lt UAB et al., E.D. Texas, Case No. 2:19-cv-
`
`00395-JRG ECF No. 55.
`
`16. Exhibit 2014 is a true and correct copy of Code200’s Rule 7.1 Disclosure
`
`statement in Luminati v. Code200 et al., E.D. Texas, Case No. 2:19-cv-00396-
`
`JRG ECF No. 28.
`
`17. Exhibit 2015 is a true and correct copy of and Order Denying Motion to Stay
`
`pending Inter Partes Review; Luminati v. Teso Lt UAB et al., E.D. Texas, Case
`
`No. 2:19-cv-00395-JRG, ECF 157.
`
`18. Exhibit 2016 is true and correct copy of the Claim Construction Opinion and
`
`Order issued December 7, 2020; Luminati v. Teso Lt UAB et al., E.D. Texas,
`
`Case No. 2:19-cv-00395-JRG, ECF 191.
`
`
`
`I declare under the laws of the United States that the foregoing is true and correct.
`
`Executed on December 9, 2020.
`
`/s/ Thomas M. Dunham
`Thomas M. Dunham
`Reg. No. 39,965
`
`
`
`
`
`
`
`
`
`
`
`
`
`4
`
`Luminati Exhibit 2017
`Code200 et al. v. Luminati Networks LTD.
`IPR2020-01506 Page 004
`
`

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