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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`GOOGLE LLC,
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`Petitioner
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`v.
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`NEONODE SMARTPHONE LLC,
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`Patent Owner
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`____________
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`Case IPR2021-01041
`U.S. Patent No. 8,095,879
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`DECLARATION OF ULF MÅRTENSSON
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`Google v. Neonode
`IPR2021-01041 (US 8,095,879)
`Neonode Ex. 2007 - Page 1
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`I, Ulf Mårtensson, declare as follows:
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`Declaration of Ulf Mårtensson
`IPR2021-01041
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`I am over 18 years of age and, if I am called upon to do so, I would be
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`1.
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`2.
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`competent to do testify as to the matters set forth herein.
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`3.
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`I have been employed by Neonode, Inc. as its Director of
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`Manufacturing, from September 2006 through December 2008, and as its
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`Executive Vice President, Operations, from September 2012 and ongoing.
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`Currently, among my job functions is to serve as the company’s custodian of
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`records.
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`4.
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`Attached hereto are true and correct copies of the following
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`documents:
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`EXHIBIT 2010: Excel Spreadsheet documenting Neonode sales.
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`EXHIBIT 2014: Research & Development and License Agreement between
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`Neonode and Samsung Electronics Co., Ltd., effective July 13, 2005.
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`5.
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`I am familiar with Exhibits 2010 and 2014. Exhibits 2010 and 2014
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`are records that were produced by Neonode officers and employees who at the time
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`had personal knowledge of the matters stated in them. They were intended to be
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`relied upon by Neonode and third parties, and thus were intended by Neonode to
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`be accurate and reliable. They were kept by Neonode in the course of regularly
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`conducted business activity in soliciting investment in the company, and in
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`1
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`EX2007
`
`Google v. Neonode
`IPR2021-01041 (US 8,095,879)
`Neonode Ex. 2007 - Page 2
`
`
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`marketing, promotion, and sales of Neonode’s products. Exhibits A and B were
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`Declaration of Ulf Mårtensson
`IPR2021-01041
`
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`made in the regular course of those activities.
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`6.
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`I have reviewed Exhibit 2010. Neonode began commercial sales of
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`the N1 mobile handset in early 2004, it released the N2 in 2007, and sales of the
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`N1 and N2 ended after Neonode’s mobile handset manufacturing entity filed for
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`bankruptcy in 2008. The Excel spreadsheet documents sales of 26,991 units of the
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`Neonode N2 phone. In addition, Neonode sold 8,000 units to a network operator in
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`India, for a total of 34,991 units of the N2 phone. Furthermore, Neonode sold
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`approximately 5,000 units of the N1 phone. So in all, Neonode’s records presently
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`available document approximately sales of approximately 40,000 N1 and N2
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`phones.
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`7.
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`I declare under penalty of perjury under the laws of the United States
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`of America that all statements made herein of my knowledge are true, and that all
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`statements made on information and belief are believed to be true, and that these
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`statements were made with the knowledge that willful false statements and the like
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`so made are punishable by fine or imprisonment, or both, under Section 1001 of
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`Title 18 of the United States Code.
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`Dated: October 18, 2021
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`________________________________
` Ulf Mårtensson
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`2
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`EX2007
`
`Google v. Neonode
`IPR2021-01041 (US 8,095,879)
`Neonode Ex. 2007 - Page 3
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