`IPR2022-00031
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` Declaration of Jennifer Hayes
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`Do Paper No.
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE, INC.
`Petitioner
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`v.
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`MEMORYWEB, LLC
`Patent Owner
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`Patent No. 10,621,228
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`Inter Partes Review No. IPR2022-00031
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`DECLARATION OF JENNIFER HAYES
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`MemoryWeb Ex. 2113
`Apple v. MemoryWeb - IPR 2022-00031
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`
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`Patent Nos. 10,621,228
`IPR2022-00031
`
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`I, Jennifer Hayes, hereby declare as follows:
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` Declaration of Jennifer Hayes
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`1.
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`I am an attorney at Nixon Peabody LLP, attorneys for MemoryWeb,
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`LLC (“Patent Owner”) in the above-captioned inter partes review.
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`2.
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`Exhibit 2058, which was previously submitted pursuant to the Board’s
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`August 11, 2023 Order (Paper 50), is a true and correct copy of “3 Questions for
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`Unified Patents CEO Post-Oil States (Part II)” available from the following URL:
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`https://abovethelaw.com/2018/05/3-questions-for-unified-patents-ceo-post-oil-
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`states-part-ii.
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`3.
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`Exhibit 2062, which was previously submitted pursuant to the Board’s
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`August 11, 2023 Order (Paper 50), is a true and correct copy of “Benefits for Large
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`Company
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`Members”
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`available
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`from
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`the
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`following
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`URL:
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`https://web.archive.org/web/20130907064849/http://www.unifiedpatents.com:80/b
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`enefits/large_companies.html.
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`4.
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`Exhibit 2063, which was previously submitted pursuant to the Board’s
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`August 11, 2023 Order (Paper 50), is a true and correct copy of “United Patents’
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`Collaborative Deterrence Approach” available from the following URL:
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`https://web.archive.org/web/20130413073000/http://www.unifiedpatents.com:80/s
`
`olution/unified_patents.html.
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`
`
`1
`
`MemoryWeb Ex. 2113
`Apple v. MemoryWeb - IPR 2022-00031
`
`
`
`Patent Nos. 10,621,228
`IPR2022-00031
`
`
`
`
` Declaration of Jennifer Hayes
`
`5.
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`Exhibit 2064, which was previously submitted pursuant to the Board’s
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`August 11, 2023 Order (Paper 50), is a true and correct copy of “NPE Zones”
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`available from the following URL: at www.unifiedpatents.com/npe/.
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`6.
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`Exhibit 2065, which was previously submitted pursuant to the Board’s
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`August 11, 2023 Order (Paper 50), is a true and correct copy of “Success at
`
`Challenging Bad
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`Patents”
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`available
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`from
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`the
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`following URL:
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`https://www.unifiedpatents.com/success.
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`7.
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`Exhibit 2066, which was previously submitted pursuant to the Board’s
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`August 11, 2023 Order (Paper 50), is a true and correct copy of “FAQ” available
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`from the following URL: https://www.unifiedpatents.com/faq.
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`8.
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`Exhibit 2067, which was previously submitted pursuant to the Board’s
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`August 11, 2023 Order (Paper 50), is a true and correct copy of “NPE Zones”
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`available from the following URL: at www.unifiedpatents.com/npe/.
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`9.
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`Submitted with Patent Owner’s Motion to Terminate as Exhibit 2087 is
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`a true and correct copy of https://portal.unifiedpatents.com/ptab/analytics/case-
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`level/top-parties.
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`10. Submitted with Patent Owner’s Motion to Terminate as Exhibit 2093 is
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`a true and correct copy of MemoryWeb’s Subscription Plans available from the
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`following URL: https://www.memoryweb.me/pricing.
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`
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`2
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`MemoryWeb Ex. 2113
`Apple v. MemoryWeb - IPR 2022-00031
`
`
`
`Patent Nos. 10,621,228
`IPR2022-00031
`
`
`
`
` Declaration of Jennifer Hayes
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`11. Submitted with Patent Owner’s Motion to Terminate as Exhibit 2095 is
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`a true and correct copy of search results from Docket Navigator listing Unified
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`Patents LLC’s Patent Trial and Appeal Board filings from March 1, 2021 to the
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`present.
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`12. Submitted with Patent Owner’s Motion to Terminate as Exhibit 2098 is
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`a true and correct copy of “Unified Patents Real Party-in-Interest (RPI) Decisions”
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`available from the following URL: https://www.unifiedpatents.com/rpi.
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`13. Submitted with Patent Owner’s Motion to Terminate as Exhibit 2099 is
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`a true and correct comparison between Ex. 1005 (A3UM) and Exhibit 2107. Exhibit
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`2113 was generated using Litera Workshare Compare software.
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`14. Submitted with Patent Owner’s Motion to Terminate as Exhibit 2112 is
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`a true and correct copy of the September 24, 2021 letter from Apple’s counsel, Bita
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`Rahebi, addressed to MemoryWeb’s counsel, Daniel Schwartz.
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`I declare under penalty of perjury under the laws of the United States that the
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`foregoing is true and correct to the best of my knowledge.
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`Dated: September 15, 2023
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`By: /s/ Jennifer Hayes
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`Jennifer Hayes
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`3
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`MemoryWeb Ex. 2113
`Apple v. MemoryWeb - IPR 2022-00031
`
`