`IPR2022-00222
`
`
`
`
` Declaration of Jennifer Hayes
`
`Paper No.
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`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD. et al,
`Petitioner
`v.
`MEMORYWEB, LLC
`Patent Owner
`Patent No. 10,621,228
`
`
`Inter Partes Review No. IPR2022-00222
`
`
`
`DECLARATION OF JENNIFER HAYES
`
`
`
`MemoryWeb Ex. 2113
`Samsung v. MemoryWeb - IPR 2022-00222
`
`
`
`Patent Nos. 10,621,228
`IPR2022-00222
`
`
`I, Jennifer Hayes, hereby declare as follows:
`
`
`
` Declaration of Jennifer Hayes
`
`1.
`
`I am an attorney at Nixon Peabody LLP, attorneys for MemoryWeb,
`
`LLC (“Patent Owner”) in the above-captioned inter partes review.
`
`2.
`
`Exhibit 2052, which was previously submitted pursuant to the Board’s
`
`August 11, 2023 Order (Paper 44), is a true and correct copy of “3 Questions for
`
`Unified Patents CEO Post-Oil States (Part II)” available from the following URL:
`
`https://abovethelaw.com/2018/05/3-questions-for-unified-patents-ceo-post-oil-
`
`states-part-ii.
`
`3.
`
`Exhibit 2056, which was previously submitted pursuant to the Board’s
`
`August 11, 2023 Order (Paper 44), is a true and correct copy of “Benefits for Large
`
`Company
`
`Members”
`
`available
`
`from
`
`the
`
`following
`
`URL:
`
`https://web.archive.org/web/20130907064849/http://www.unifiedpatents.com:80/b
`
`enefits/large_companies.html.
`
`4.
`
`Exhibit 2057, which was previously submitted pursuant to the Board’s
`
`August 11, 2023 Order (Paper 44), is a true and correct copy of “United Patents’
`
`Collaborative Deterrence Approach” available from the following URL:
`
`https://web.archive.org/web/20130413073000/http://www.unifiedpatents.com:80/s
`
`olution/unified_patents.html.
`
`
`
`1
`
`MemoryWeb Ex. 2113
`Samsung v. MemoryWeb - IPR 2022-00222
`
`
`
`Patent Nos. 10,621,228
`IPR2022-00222
`
`
`
`
` Declaration of Jennifer Hayes
`
`5.
`
`Exhibit 2058, which was previously submitted pursuant to the Board’s
`
`August 11, 2023 Order (Paper 44), is a true and correct copy of “NPE Zones”
`
`available from the following URL: at www.unifiedpatents.com/npe/.
`
`6.
`
`Exhibit 2059, which was previously submitted pursuant to the Board’s
`
`August 11, 2023 Order (Paper 44), is a true and correct copy of “Success at
`
`Challenging Bad
`
`Patents”
`
`available
`
`from
`
`the
`
`following URL:
`
`https://www.unifiedpatents.com/success.
`
`7.
`
`Exhibit 2060, which was previously submitted pursuant to the Board’s
`
`August 11, 2023 Order (Paper 44), is a true and correct copy of “FAQ” available
`
`from the following URL: https://www.unifiedpatents.com/faq.
`
`8.
`
`Exhibit 2061, which was previously submitted pursuant to the Board’s
`
`August 11, 2023 Order (Paper 44), is a true and correct copy of “NPE Zones”
`
`available from the following URL: at www.unifiedpatents.com/npe/.
`
`9.
`
`Submitted with Patent Owner’s Motion to Terminate as Exhibit 2081 is
`
`a true and correct copy of https://portal.unifiedpatents.com/ptab/analytics/case-
`
`level/top-parties.
`
`10. Submitted with Patent Owner’s Motion to Terminate as Exhibit 2087 is
`
`a true and correct copy of MemoryWeb’s Subscription Plans available from the
`
`following URL: https://www.memoryweb.me/pricing.
`
`
`
`2
`
`MemoryWeb Ex. 2113
`Samsung v. MemoryWeb - IPR 2022-00222
`
`
`
`Patent Nos. 10,621,228
`IPR2022-00222
`
`
`
`
` Declaration of Jennifer Hayes
`
`11. Submitted with Patent Owner’s Motion to Terminate as Exhibit 2089 is
`
`a true and correct copy of search results from Docket Navigator listing Unified
`
`Patents LLC’s Patent Trial and Appeal Board filings from March 1, 2021 to the
`
`present.
`
`12. Submitted with Patent Owner’s Motion to Terminate as Exhibit 2092 is
`
`a true and correct copy of “Unified Patents Real Party-in-Interest (RPI) Decisions”
`
`available from the following URL: https://www.unifiedpatents.com/rpi.
`
`13. Submitted with Patent Owner’s Motion to Terminate as Exhibit 2112 is
`
`a true and correct copy of the September 24, 2021 letter from Apple’s counsel, Bita
`
`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
`
`foregoing is true and correct to the best of my knowledge.
`
`
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`
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`Dated: September 29, 2023
`
`
`
`
`
`
`
`By: /s/ Jennifer Hayes
`
`Jennifer Hayes
`
`
`
`3
`
`MemoryWeb Ex. 2113
`Samsung v. MemoryWeb - IPR 2022-00222
`
`
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