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UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________
`NETNUT LTD.,
`
`Petitioner
`
`v.
`
`BRIGHT DATA LTD.,
`
`Patent Owner
`
`_________________________
`
`Case IPR2021-01492
`Patent No. 10,257,319
`_________________________
`
`DECLARATION OF MR. THOMAS M. DUNHAM
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`NetNut Ltd. v. Bright Data Ltd.
`IPR2021-01492, EX. 2017
`1 of 3
`
`

`

`I, Thomas M. Dunham, declare as follows under penalty of perjury:
`
`IPR2021-01492 of Patent No. 10,257,319
`
`
`
`1. I am lead counsel for Patent Owner.
`
`2. Concurrently filed with Patent Owner’s Sur-Reply, dated January 28, 2022,
`
`are the following exhibits.
`
`3. Exhibit 2011 is a true and correct copy of the Order (Dkt. 100) dated Feb. 12,
`
`2018 in the case of Uniloc USA, Inc. v. Ringcentral, Inc., No. 2-17-cv-354
`
`(E.D. Tex.).
`
`4. Exhibit 2012 is a true and correct copy of the Motion (Dkt. 97) dated Feb. 8,
`
`2018 in the case of Uniloc USA, Inc. v. Ringcentral, Inc., No. 2-17-cv-354
`
`(E.D. Tex.).
`
`5. Exhibit 2013 is a true and correct copy of the Order (Dkt. 99) dated Feb. 9,
`
`2018 in the case of Uniloc USA, Inc. v. Ringcentral, Inc., No. 2-17-cv-354
`
`(E.D. Tex.).
`
`6. Exhibit 2014 is a true and correct copy of the Joint Motion (Dkt. 79) dated
`
`Dec. 22, 2021 in the case of Bright Data Ltd. v. NetNut Ltd., No. 2:21-cv-225
`
`(E.D. Tex.).
`
`7. Exhibit 2015 is a true and correct copy of the Motion (Dkt. 80) dated Dec. 23,
`
`2021 in the case of Bright Data Ltd. v. NetNut Ltd., No. 2:21-cv-225 (E.D.
`
`Tex.).
`
`2
`
`NetNut Ltd. v. Bright Data Ltd.
`IPR2021-01492, EX. 2017
`2 of 3
`
`

`

`
`8. Exhibit 2016 is a true and correct copy of a Letter dated Dec. 30, 2021 from
`
`IPR2021-01492 of Patent No. 10,257,319
`
`Bright Data Ltd. to NetNut Ltd. regarding the scheduling of depositions in the
`
`case of Bright Data Ltd. v. NetNut Ltd., No. 2:21-cv-225 (E.D. Tex.).
`
`I declare under the laws of the United States that the foregoing is true and correct.
`Executed on January 28, 2022.
`
`/s/ Thomas M. Dunham
`Thomas M. Dunham
`Reg. No. 39,965
`
`3
`
`NetNut Ltd. v. Bright Data Ltd.
`IPR2021-01492, EX. 2017
`3 of 3
`
`

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