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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD.;
`SAMSUNG ELECTRONICS AMERICA, INC;
`SONY CORPORATION; AND
`SONY MOBILE COMMUNICATIONS INC.
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`Petitioner
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`V.
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`NEODRON LTD.
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`Patent Owner.
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`DECLARATION OF DO-HYUNG KIM IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW OF U.S. PATENT NO. 8,749,251
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`Petitioners Samsung and Sony Ex-1012, 0001
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`Petitioners Samsung and Sony Ex-1012, 0001
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`
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`Declaration of Do-Hyung Kim
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`1.
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`2.
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`I, Do-Hyung Kim, declare as follows:
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`I am employed in the Device Solution (DS) IP Legal Department at
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`Samsung Electronics Co., LTD.
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`I provide this declaration in support of Samsung
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`Electronics Co., Ltd. and Samsung Electronics America, Inc.’s (collectively,
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`“Samsung”) Petition for Inter Partes Review of US. Patent No. 8,749,251 (“’251
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`Patent”). If called as a witness, I could and would testify competently to the
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`information set forth in this declaration.
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`3.
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`I have worked in the licensing group of Device Solution Division
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`since 2019, and had worked in the IP legal department before that. My job
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`responsibilities are to interview engineers and review factual and legal materials,
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`including technical documents and relevant agreements, in light of 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-l 193,
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`Complainant Neodron Ltd. accuses Samsung smartphones and tablets (the
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`“Samsung Accused Products”) of infringing certain of Neodron’s Patents,
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`including the ’251 Patent.
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`5.
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`Samsung did not collaborate with either Apple Inc. or Microsoft Corp.
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`in developing the accused features (i.e., idle or low power mode in touch ICs) of
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`the Samsung Accused Products.
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`6.
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`I declare that all statements made herein of my knowledge are true,
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`and that all statements made on information and belief are believed to be true, and
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`Petitioners Samsung and Sony Ex-1012, 0002
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`Petitioners Samsung and Sony Ex-1012, 0002
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`
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`Declaration of Do—Hyung Kim
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`that these statements were made with the knowledge that willful false statements
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`and the like so made are punishable by fine or imprisonment, or both, under
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`Section 1001 of Title 18 of the United States Code.
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`
`Date: September 07, 2020 #h
`Do Hyung Kim
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`Petitioners Samsung and Sony EX-1012, 0003
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`Petitioners Samsung and Sony Ex-1012, 0003
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`