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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`SAMSUNG ELECTRONICS CO. LTD., SAMSUNG ELECTRONICS
`AMERICA, INC., AND APPLE, INC.,
`Petitioner,
`
`v.
`
`NEONODE SMARTPHONE LLC,
`Patent Owner.
`____________
`
`Case IPR2021-00144
`Patent 8,095,879
`____________
`
`EXHIBIT 2042
`DECLARATION OF PARHAM HENDIFAR
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`
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`I, Parham Hendifar, declare the following:
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`1.
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`I am an attorney at the law firm of Lowenstein & Weatherwax LLP,
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`and am a member in good standing of, among other bars, the State Bar of
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`California, and a registered practitioner in good standing before the Office, with
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`the registration number of 71,470.
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`2.
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`I provide this Declaration in connection with IPR2021-00144, in
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`which I am counsel of record for Patent Owner Neonode Smartphone LLC.
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`3. Unless otherwise stated, the facts contained in this Declaration are
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`based on my personal knowledge.
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`4. Exhibit 2008 is a true and accurate copy of a video, titled “Neonode
`
`N2 instructions film,” available at the following link as visited on or about March
`
`24, 2022: https://www.youtube.com/watch?v=Hq3S8Crxf2s.
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`5. Exhibit 2012 is a true and accurate copy of an article titled “NeoNode
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`N1 Can a unique interface put this compelling smart phone on the map?” by
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`Conrad H. Blickenstorfer available at the following link as visited on or about
`
`March 22, 2022: http://pencomputing.com/WinCE/neonode-n1-review.html.
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`6. Exhibit 2013 is a true and accurate copy of an article titled “NeoNode
`
`N2 A new version of the phone that pioneered touchscreens” by Conrad H.
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`Blickenstorfer available at the following link as visited on or about March 22,
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`2022: http://www.pencomputing.com/WinCE/neonode-n2-review.html.
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`
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`1
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`
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`7. Exhibit 2014 is a true and accurate copy of an article titled “The
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`Neonode N2” by Bill Hennessy available at the following link as visited on or
`
`about March 24, 2022: https://www.trendhunter.com/trends/neonode-n2-phone.
`
`8. Exhibit 2015 is a true and accurate copy of the webpage titled “About
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`Trend Hunter” available at the following link as visited on or about March 22,
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`2022: https://www.trendhunter.com/about-trend-hunter.
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`9. Exhibit 2016 is a true and accurate copy of an article titled “Neonode
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`N1m first impressions” available at the following link as visited on or about
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`March 24, 2022: https://tnkgrl.com/2007/04/16/neonode-n1m-first-impressions/.
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`10. Exhibit 2017 is a true and accurate copy of the webpage titled “tnkgrl
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`Media” available at the following link as visited on or about March 22, 2022:
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`https://tnkgrl.com/tnkgrl-media/.
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`11. Exhibit 2019 is a true and accurate copy of an article titled “If
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`Android is a ‘stolen product,’ then so was the iPhone” by Timothy B. Lee
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`available at the following link as visited on or about March 24, 2022:
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`https://arstechnica.com/tech-policy/2012/02/if-android-is-a-stolen-product-then-
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`so-was-the-iphone/.
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`12. Exhibit 2021 is a true and accurate copy of an article titled “Hunting
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`the iPhone killer; Swedish Neonode generates buzz for device” available at the
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`following link as visited on or about March 24, 2022:
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`2
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`https://www.rcrwireless.com/20070407/archived-articles/hunting-the-iphone-
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`killer.
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`13. Exhibit 2029 is a true and accurate copy of a video titled “Neonode
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`N1m review” available at the following link as visited on or about March 24,
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`2022: https://www.youtube.com/watch?v=Tj-KS2kfIr0.
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`14. Exhibit 2030 is a true and accurate copy of a thread titled “Neonode
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`N2 instructions film” available at the following link and printed on March 23,
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`2022: https://www.youtube.com/watch?v=Hq3S8Crxf2s.
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`15. Exhibit 2031 is a true and accurate copy of a thread titled “Neonode
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`N2 Overview” available at the following link and printed on March 23, 2022:
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`https://www.youtube.com/watch?v=vQNUQm3-qJA.
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`16. Exhibit 2032 is a true and accurate copy of a thread titled “Neonode
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`N2 unbox and review video” available at the following link and printed on March
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`24, 2022: https://www.youtube.com/watch?v=Ux_9tbioS_8.
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`17. Exhibit 2033 is a true and accurate copy of the webpage titled
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`“iPhone” available at the following link and printed on March 23, 2022, 7:20 PM:
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`https://en.wikipedia.org/wiki/IPhone.
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`18. Exhibit 2034 is a true and accurate copy of the webpage titled
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`“Samsung Galaxy” available at the following link and printed on March 23, 2022,
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`7:19 PM: https://en.wikipedia.org/wiki/Samsung_Galaxy.
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`
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`3
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`19. Exhibit 2036 is a true and accurate copy of a video titled “Neonode
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`the only original” available at the following link as visited on or about March 24,
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`2022: https://www.youtube.com/watch?v=D9N3H1rSxHk.
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`20. Exhibit 2039 is a true and accurate copy of a webpage titled “US
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`Inflation Calculator,” available at the following link as visited on or about March
`
`24, 2022: https://www.usinflationcalculator.com/.
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`21. Exhibit 2040 is a true and accurate copy of a webpage titled “Euro
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`Dollar Exchange Rate (EUR USD) - Historical Chart,” available at the following
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`link as visited on or about March 24, 2022:
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`https://www.macrotrends.net/2548/euro-dollar-exchange-rate-historical-chart.
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`22. Exhibit 2041 is a true and accurate copy of a January 27, 2021 article
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`titled “Smartphone Shipments Declined in the Fourth Quarter But 2021 Was Still
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`a Growth Year with a 5.7% Increase in Shipments, According to IDC,” available
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`at the following link as visited on or about March 24, 2022:
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`https://www.idc.com/getdoc.jsp?containerId=prUS48830822.
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`23. I certify that all statements made herein of my knowledge are
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`true and that all statements made on information and belief are believed to be
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`true, and that these statements were made with knowledge that willful false
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`statements and the like are made punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
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`4
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`March 25, 2022
` Date
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`/s/ Parham Hendifar
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`5
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