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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________
`
`
`
`
`SAMSUNG ELECTRONICS CO., LTD.; AND
`SAMSUNG ELECTRONICS AMERICA, INC.,
`SONY CORPORATION; AND
`SONY MOBILE COMMUNICATIONS INC.
`Petitioners
`v.
`
`NEODRON LTD.
`Patent Owner.
`
`
`
`
`DECLARATION OF LEE HILL IN SUPPORT OF PETITIONS FOR INTER
`PARTES REVIEW OF U.S. PATENT NO. 8,749,251
`
`
`
`Petitioners Samsung and Sony Ex-1013, 0001
`
`
`
`Declaration of Lee Hill
`
`1.
`
`2.
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`I, Lee Hill, declare as follows:
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`I am employed by Sony Corporation of America in the United States.
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`I provide this declaration in support of the Petitions for Inter Partes Review of
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`U.S. Patent No. 8,749,251 (“’251 Patent”) filed by Samsung Electronics Co., Ltd.;
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`Samsung Electronics America, Inc.; Sony Corporation; and Sony Mobile
`
`Communications Inc. I refer to Sony Corporation and Sony Mobile
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`Communications Inc. collectively as “Sony.” If called as a witness, I could and
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`would testify competently to the information set forth in this declaration.
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`3.
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`I have worked in the Intellectual Property Division of Sony
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`Corporation of America since 2019 and had worked in the Legal Department of
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`Sony Mobile Communications before that. My job responsibilities include
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`overseeing patent disputes and in conjunction therewith the collection and review
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`of factual and legal materials, including technical documents and relevant
`
`agreements, in light of such patent disputes.
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`4.
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`I am informed that in U.S.I.T.C. Investigation No. 337-TA-1193,
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`Complainant Neodron Ltd. accuses certain Sony smartphones (the “Sony Accused
`
`Products”) of infringing certain of Neodron’s Patents, including the ’251 Patent.
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`5.
`
`Sony did not collaborate with either Apple Inc. or Microsoft Corp. in
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`developing the accused features (i.e., touch recognition features) of the Sony
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`Accused Products.
`
`1
`
`
`
`Petitioners Samsung and Sony Ex-1013, 0002
`
`
`
`Declaration of Lee Hill
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`6.
`
`I declare that all statements made herein of my knowledgearetrue,
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`and that all statements made on information andbelief are believed to be true, and
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`that these statements were made with the knowledgethat willful false statements
`
`and the like so made are punishable by fine or imprisonment, or both, under
`
`Section 1001 of Title 18 of the United States Code.
`
`Date: September 23, 2020
`
`Lee Hill
`
`Petitioners Samsung and Sony Ex-1013, 0003
`
`Petitioners Samsung and Sony Ex-1013, 0003
`
`
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