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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. 2010
`Page 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 Preliminary Response are the
`
`following exhibits.
`
`3. Exhibit 2001 is a true and correct copy of the Jury Verdict (Dkt. 516) in the
`
`case of Bright Data Ltd. f/k/a Luminati Networks Ltd. v. Teso LT, UAB a/k/a
`
`UAB Teso LT, et al., Case No. 2:19-cv-00395-JRG (E.D. Tex. Nov. 5, 2021).
`
`4. Exhibit 2002 is a true and correct copy of Plaintiff Bright Data Ltd.’s
`
`Disclosure of Proposed Claim Terms for Construction, dated December 8,
`
`2021, in the case of Bright Data Ltd. v. NetNut Ltd., Case No. 2:21-cv-00225-
`
`JRG (E.D. Tex.).
`
`5. Exhibit 2003 is a true and correct copy of the Docket Control Order (Dkt. 56)
`
`in the case of Bright Data Ltd. v. NetNut Ltd., Case No. 2:21-cv-00225-JRG
`
`(E.D. Tex. Oct. 22, 2021).
`
`6. Exhibit 2004 is a true and correct copy of the Order on Pretrial Motions and
`
`Motions in Limine (Dkt. 476) in the case of Bright Data Ltd. f/k/a Luminati
`
`Networks Ltd. v. Teso LT, UAB a/k/a UAB Teso LT, et al., Case No. 2:19-cv-
`
`00395-JRG (E.D. Tex. Sept. 9, 2021).
`
`
`
`2
`
`NetNut Ltd. v. Bright Data Ltd.
`IPR2021-01492, EX. 2010
`Page 2 of 3
`
`

`

`IPR2021-01492 of Patent No. 10,257,319
`
`7. Exhibit 2005 is a true and correct copy of the Applicant Remarks, dated
`
`October 18, 2018, regarding Application No. 15/957,945 which issued as
`
`Patent No. 10,257,319 (previously submitted in IPR2020-01266 as EX. 2008).
`
`8. Exhibit 2006 is a true and correct copy of the Declaration of Dr. V. Thomas
`
`Rhyne Declaration (previously submitted in IPR2020-01266 as EX. 2012).
`
`9. Exhibit 2007 is a true and correct copy of Plaintiff’s Sur-reply in opposition
`
`to Defendants’ Motion to Dismiss (Dkt. 47) in the case of Bright Data Ltd.
`
`f/k/a Luminati Networks Ltd. v. Teso LT, UAB a/k/a UAB Teso LT, et al., Case
`
`No. 2:19-cv-00395-JRG (E.D. Tex. May 5, 2020).
`
`10. Exhibit 2008 is a true and correct copy of the Order (Dkt. 55) in the case of
`
`Boxcast Inc., v. Resi Media LLC, et al., Case No. 2:21-cv-00217-JRG (E.D.
`
`Tex. Dec. 1, 2021).
`
`11. Exhibit 2009 is a true and correct copy of the Order (Dkt. 87) in the case of
`
`Oyster Optics, LLC v. Infinera Corp., et al., Case No. 2:19-cv-00257-JRG
`
`(E.D. Tex. July 17, 2020).
`
`I declare under the laws of the United States that the foregoing is true and correct.
`
`Executed on December 27, 2021.
`
`/s/ Thomas M. Dunham
`Thomas M. Dunham
`Reg. No. 39,965
`
`3
`
`NetNut Ltd. v. Bright Data Ltd.
`IPR2021-01492, EX. 2010
`Page 3 of 3
`
`

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