`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLEINC.,
`
`Petitioner,
`
`Vv.
`
`MASIMO CORPORATION,
`
`Patent Owner.
`
`Case IPR2022-01299
`U.S. Patent 7,761,127
`
`DECLARATION OF MICAH YOUNG
`
`
`
`
`REDACTED
`
`MASIMO 2181
`Apple v. Masimo
`IPR2022-01299
`
`
`
`IPR2022-01299 & IPR2022-01300
`Apple Inc. v. Masimo Corp.
`
`1.
`
`I, Micah Young, am making this declaration at the request of Patent
`
`Owner Masimo Corporation (“Masimo”) in the matters of the Inter Partes Review
`
`Nos. IPR2022-01299 and IPR2022-01300 of U.S. Patent No. 7,761,127 (“the °127
`
`patent”).
`
`I understand that this declaration is being submitted in each of these
`
`proceedings as Exhibit 2081.
`
`2.
`
`I am Masimo’s Chief Financial Officer and Executive Vice President.
`
`I started working at Masimo in October 2017.
`
`3.
`
`I have a Bachelor of Science degree in accounting from Indiana
`
`Wesleyan University, and I earned my CPA shortly thereafter, although I am
`
`currently inactive.
`
`4.
`
`As Masimo’s CFO and Executive VP, I am responsible forall.aspects
`
`of finance, including accounting, financial planning and analysis, tax, and investor
`
`relations.
`
`I report directly to Masimo’s Chief Executive Officer, Joe Kiani..
`
`5.
`
`Masimo maintains a financial data warehouse that we often refer to in
`
`documents as FinDW. Thedatabase includes a lot of Masimo’s Enterprise Resource
`
`Planning (“ERP”) information, coming from systems like Expandable or Oracle.
`
`The database also includes information such as revenue, cost of goods sold, sales
`
`orders, and purchase order information.
`
`
`
`
`REDACTED
`
`MASIMO 2181
`Apple v. Masimo
`IPR2022-01299
`
`
`
`IPR2022-01299 & IPR2022-01300
`Apple Inc. v. Masimo Corp.
`
`6.
`
`In connection with Masimo’s complaint against Apple in the
`
`International Trade Commission,
`
`I directed members of Masimo’s financial
`
`planning and analysis team to generate various financial
`
`reports containing
`
`information relevant
`
`to the Masimo products,
`
`including Masimo’s rainbow®
`
`sensors,
`
`that
`
`I understand are covered by the patents asserted in the ITC
`
`Investigation.
`
`I understand that certain models of the rainbow® sensors are the
`
`Masimo domestic industry products in the ITC Investigation and relevant to these
`
`IPRs.
`
`7.
`
`Weextracted data from the financial data warehouse to generate the
`
`financial reports used in the ITC Investigation.
`
`8.
`
`Exhibit 2082 is one of the financial reports we created for the ITC
`
`Investigation. Exhibit 2082 is a rainbow® Financial Report Spreadsheet showing
`
`various data related to Masimo’s sales of the models of rainbow® sensors asserted
`
`as domestic industry products in the ITC Investigation. The data shownin Exhibit
`
`2082 is from Fiscal Year 2008 to the second quarter of 2021.
`
`
`
`10.
`
`I declare that all statements made herein on my own knowledgeare true
`
`and that all statements made on information and belief are believed to be true, and
`
`REDACTED
`
`MASIMO 2181
`Apple v. Masimo
`IPR2022-01299
`
`
`
`IPR2022-01299 & IPR2022-01300
`Apple Inc. v. Masimo Corp.
`
`further, that these statements were made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`underSection 1001 of Title 18 of the United States Code.
`
`Dated:
`
`/I Spee
`
`56555008
`
`ee
`
`gt
`
`fer
`Micah Young
`
`
`
`
`REDACTED
`
`MASIMO 2181
`Apple v. Masimo
`IPR2022-01299
`
`
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