`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CoO., LTD.;
`SAMSUNG ELECTRONICS AMERICA,INC.;
`SONY CORPORATION; AND
`SONY MOBILE COMMUNICATIONS INC.
`Petitioner
`
`V.
`
`NEODRONLTD.
`Patent Owner.
`
`DECLARATION OF DO-HYUNG KIM IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW OF U.S. PATENT NO.8,749,251
`
`Petitioners Samsung and Sony Ex-1012, 0001
`
`Petitioners Samsung and Sony Ex-1012, 0001
`
`
`
`Declaration of Do-Hyung Kim
`
`l.
`
`2.
`
`I, Do-Hyung Kim, declare as follows:
`
`I am employedin the Device Solution (DS) IP Legal Department at
`
`Samsung Electronics Co., LTD.
`
`I providethis declaration in support of Samsung
`
`Electronics Co., Ltd. and Samsung Electronics America, Inc.’s (collectively,
`
`“Samsung”) Petition for /nter Partes Review of U.S. Patent No. 8,749,251 (‘251
`
`Patent”). If called as a witness, I could and would testify competently to the
`
`information set forth in this declaration.
`
`3.
`
`I have workedin the licensing group of Device Solution Division
`
`since 2019, and had workedin the IP legal department before that. My job
`
`responsibilities are to interview engineers and review factual and legal materials,
`
`including technical documents and relevant agreements,in light of patent disputes.
`
`4.
`
`I am informedthat in U.S.I.T.C. Investigation No. 337-TA-1193,
`
`Complainant Neodron Ltd. accuses Samsung smartphonesandtablets (the
`
`“Samsung Accused Products”) of infringing certain of Neodron’s Patents,
`
`including the ’251 Patent.
`
`>.
`
`Samsungdid not collaborate with either Apple Inc. or Microsoft Corp.
`
`in developing the accusedfeatures(i.e., idle or low power modein touch ICs) of
`
`the Samsung Accused Products.
`
`6.
`
`I declare that all statements made herein of my knowledgearetrue,
`
`andthatall statements made on information andbelief are believed to be true, and
`
`Petitioners Samsung and Sony Ex-1012, 0002
`
`Petitioners Samsung and Sony Ex-1012, 0002
`
`
`
`Declaration of Do-Hyung Kim
`
`that these statements were made with the knowledgethat willful false statements
`
`and the like so madeare punishable by fine or imprisonment, or both, under
`
`Section 1001 of Title 18 of the United States Code.
`
`Date: September07, 2020
`
`
`| a
`Do Hyung Kim
`
`Petitioners Samsung and Sony Ex-1012, 0003
`
`Petitioners Samsung and Sony Ex-1012, 0003
`
`
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