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IPR2022-00222
`Patent No. 10,621,228
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`
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD.
`
`Petitioner
`
`
`v.
`
`MEMORYWEB, LLC
`
`Patent Owner
`
`Patent No. 10,621,228
`
`Inter Partes Review No. IPR2022-00222
`
`DECLARATION OF JENNIFER HAYES
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`MemoryWeb Ex. 2037
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`

`

`IPR2022-00222
`Patent No. 10,621,228
`I, Jennifer Hayes, hereby declare as follows:
`
`
`
`1.
`
`I am an attorney at Nixon Peabody LLP, attorneys for MemoryWeb,
`
`LLC (“Patent Owner”) in the above-captioned inter partes review.
`
`2.
`
`Submitted with Patent Owner’s Brief Addressing Additional Discovery
`
`in Support of its Motion to Terminate and Authorization for Third Party Subpoenas
`
`to Unified Patents as Ex. 2028 is a true and correct copy of Petitioner’s Motion to
`
`Seal and For Entry of Protective Order (Paper 10) from Unified Patents, LLC v.
`
`MemoryWeb, LLC, IPR2021-01413.
`
`3.
`
`Submitted with Patent Owner’s Brief Addressing Additional Discovery
`
`in Support of its Motion to Terminate and Authorization for Third Party Subpoenas
`
`to Unified Patents as Ex. 2029 is a true and correct copy of Petitioner’s Updated
`
`Mandatory Notices (Paper 57) from Unified Patents, LLC v. MemoryWeb, LLC,
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`IPR2021-01413.
`
`4.
`
`Submitted with Patent Owner’s Brief Addressing Additional Discovery
`
`in Support of its Motion to Terminate and Authorization for Third Party Subpoenas
`
`to Unified Patents as Ex. 2030 is a true and correct copy of the Final Written
`
`Decision (Public Version) (Paper 67) from Unified Patents, LLC v. MemoryWeb,
`
`LLC, IPR2021-01413.
`
`5.
`
`Submitted with Patent Owner’s Brief Addressing Additional Discovery
`
`in Support of its Motion to Terminate and Authorization for Third Party Subpoenas
`
`
`
`1
`
`MemoryWeb Ex. 2037
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`

`

`IPR2022-00222
`Patent No. 10,621,228
`to Unified Patents as Ex. 2031 is a true and correct copy of the Decision Granting
`
`
`
`Director Review (Public Version) (Paper 76) from Unified Patents, LLC v.
`
`MemoryWeb, LLC, IPR2021-01413.
`
`6.
`
`Submitted with Patent Owner’s Brief Addressing Additional Discovery
`
`in Support of its Motion to Terminate and Authorization for Third Party Subpoenas
`
`to Unified Patents as Ex. 2032 is a true and correct copy of the March 13-15, 2023
`
`email chain between counsel for Patent Owner to counsel for Petitioner regarding
`
`Patent Owner’s Motion to Terminate.
`
`7.
`
`Submitted with Patent Owner’s Brief Addressing Additional Discovery
`
`in Support of its Motion to Terminate and Authorization for Third Party Subpoenas
`
`to Unified Patents as Ex. 2036 is a true and correct copy of the June 5-9, 2023 email
`
`chain between counsel for Patent Owner and counsel for Petitioner.
`
`8.
`
`Submitted with Patent Owner’s Brief Addressing Additional Discovery
`
`in Support of its Motion to Terminate and Authorization for Third Party Subpoenas
`
`to Unified Patents as Ex. 2038 is a true and correct copy of the Order Identifying
`
`Real Party in Interest (Public Version) (Paper 79) from Unified Patents, LLC v.
`
`MemoryWeb, LLC, IPR2021-01413.
`
`
`
`
`
`
`
`
`
`2
`
`MemoryWeb Ex. 2037
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`

`

`IPR2022-00222
`Patent No. 10,621,228
`I declare under penalty of perjury under the laws of the United States that the
`
`
`
`foregoing is true and correct to the best of my knowledge.
`
`By: /s/ Jennifer Hayes
`
`Jennifer Hayes
`
`
`
`
`
`
`
`Dated: June 30, 2023
`
`
`
`
`
`
`
`3
`
`MemoryWeb Ex. 2037
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`

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