UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________
`
`FORESIGHT DIAGNOSTICS INC.,
`Petitioner,
`
`v.
`
`PERSONALIS, INC.,
`Patent Owner.
`
`Case Nos. IPR2023-00224 and IPR2023-00317
`U.S. Patent Nos. 11,384,394 and 11,408,033
`
`DECLARATION OF DOUG ZEMAN
`
`Personalis EX2034
`
`
`__________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________
`
`FORESIGHT DIAGNOSTICS INC.,
`Petitioner,
`
`v.
`
`PERSONALIS, INC.,
`Patent Owner.
`
`Case Nos. IPR2023-00224 and IPR2023-00317
`U.S. Patent Nos. 11,384,394 and 11,408,033
`
`DECLARATION OF DOUG ZEMAN
`
`Personalis EX2034
`
`
`
`
`
`TABLE OF CONTENTS(cid:3)
`
`I. BACKGROUND AND QUALIFICATIONS ........................................................ 1(cid:3)
`II. RETENTION AND MAINTENANCE OF ELECTRONIC FILES AT
`PERSONALIS ................................................................................................. 1(cid:3)
`III. CERTIFICATION ............................................................................................. 24(cid:3)
`
`
`Table of Contents, Page 1
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`Personalis EX2034
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`Foresight Diagnostics v. Personalis
`IPR2023-00224 and IPR2023-00317
`1.
`I, Doug Zeman, make this Declaration in connection with inter partes
`
`review proceedings at the U.S. Patent & Trademark Office concerning U.S. Patent
`
`No. 11,384,394 (“the ’394 patent”) and U.S. Patent No. 11,408,033 (“the ’033
`
`patent”).
`
`I. BACKGROUND AND QUALIFICATIONS
`2.
`I am Associate Director of Scientific Computing and Information
`
`Technology at Personalis, Inc. I have held this position from January 2021 to
`
`present. I was previously Senior Manager of Scientific Computing and Information
`
`Technology at Personalis from November 2016 through December 2020.
`
`3.
`
`I have two decades of Information Technology operations and support
`
`experience, including infrastructure development and technical project management.
`
`4.
`
`I am familiar with the manner in which Personalis makes, retains, and
`
`maintains electronic files in the regular course of business. I am qualified to provide
`
`a written declaration regarding the records of regularly conducted business activity
`
`which are the subject of this document.
`
`II. RETENTION AND MAINTENANCE OF ELECTRONIC FILES AT
`PERSONALIS
`5.
`It is a regularly conducted business activity of Personalis to retain and
`
`maintain electronic files made by its employees. Google Enterprise Suite is the
`
`corporate communications platform that Personalis currently uses and has used, to
`
`the best of my knowledge, since the founding of company. Since approximately
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`Foresight Diagnostics v. Personalis
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`2016 Personalis added the Google Vault add-on feature to its Google Enterprise Suit,
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`and the Vault saves all documents and communications in the Personalis Google
`
`Enterprise Suite indefinitely for the duration each employee’s employment at
`
`Personalis. It is Personalis’ policy that, when an employee leaves the company (and
`
`there is no applicable litigation hold) then that employee’s account is exported for
`
`long term storage, and then the employee’s Google gmail and Vault accounts are
`
`deleted. If a litigation hold is in place for a departing employee, then it is Personalis’
`
`policy retain and maintain that employee’s gmail and Vault accounts for the duration
`
`of the litigation hold. In addition, it is Personalis’ policy to image the hard drive of
`
`the departing employee’s computer, if available, for long term storage.
`
`6.
`
`All of the emails in John West’s account as of 2016 and thereafter were
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`saved and stored in Google Vault. A litigation hold has been placed on his Vault
`
`account, so it has not been deleted. The Google Vault account for John West
`
`includes every email present in his account at the time of Google Vault activation,
`
`dating back to his Google account creation in 2011, and every email since Google
`
`Vault activation. Accordingly, Personalis has retained and maintained John West’s
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`emails dating back to 2011.
`
`7.
`
`John West has retired from Personalis. Because he has retired, the hard
`
`drive from his computer was imaged as part of Personalis’ standard procedure on
`
`June 27, 2023. Accordingly, Personalis has retained and maintained John West’s
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`Personalis EX2034
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`Foresight Diagnostics v. Personalis
`IPR2023-00224 and IPR2023-00317
`emails dating back to 2011 through the additional process of imaging the hard drive
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`of his computer.
`
`8.
`
`The document marked as Exhibit 2036 is a copy of the April 2, 2012
`
`email from John West to Christian Haudenschild regarding “Personalis Laboratory
`
`plans.” The email was retained and maintained within the course of regularly
`
`conducted business activity of Personalis, and Personalis relies on the accuracy of
`
`such emails being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`9.
`
`The document marked as Exhibit 2037 is a copy of the May 3, 2012
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`email from John West to Mark Pratt regarding “Comparing methods to determine
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`SNP error rate” with attachment. The email was retained and maintained within the
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`course of regularly conducted business activity of Personalis, and Personalis relies
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`on the accuracy of such emails being made, retained, and maintained in the course
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`of its regularly conducted business.
`
`10. The document marked as Exhibit 2038 is a copy of the May 3, 2012
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`Google calendar reminder for a “Dev Group Weekly Mtg.” The document was
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`retained and maintained within the course of regularly conducted business activity
`
`of Personalis, and Personalis relies on the accuracy of such documents being made,
`
`retained, and maintained in the course of its regularly conducted business.
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`Foresight Diagnostics v. Personalis
`IPR2023-00224 and IPR2023-00317
`11. The document marked as Exhibit 2039 is a copy of the May 4, 2012
`
`Google calendar reminder for a “Pipeline timeline walk through.” The document
`
`was retained and maintained within the course of regularly conducted business
`
`activity of Personalis, and Personalis relies on the accuracy of such documents being
`
`made, retained, and maintained in the course of its regularly conducted business.
`
`12. The document marked as Exhibit 2040 is a copy of the May 4, 2012
`
`Google calendar reminder for a “Personalis Weekly Team Meeting.” The document
`
`was retained and maintained within the course of regularly conducted business
`
`activity of Personalis, and Personalis relies on the accuracy of such documents being
`
`made, retained, and maintained in the course of its regularly conducted business.
`
`13. The document marked as Exhibit 2041 is a copy of the May 8, 2012
`
`email from John West to Carol Tillis regarding “J West Board slides with one slide
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`revised” with attachment. The email was retained and maintained within the course
`
`of regularly conducted business activity of Personalis, and Personalis relies on the
`
`accuracy of such emails being made, retained, and maintained in the course of its
`
`regularly conducted business.
`
`14. The document marked as Exhibit 2042 is a copy of the May 8, 2012
`
`email from Richard Chen to John West regarding “Final Board Slides” with
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`attachment. The email was retained and maintained within the course of regularly
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`conducted business activity of Personalis, and Personalis relies on the accuracy of
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`Foresight Diagnostics v. Personalis
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`such emails being made, retained, and maintained in the course of its regularly
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`conducted business.
`
`15. The document marked as Exhibit 2044 is a copy of the April 24, 2012
`
`email from Hugo Lam to John West regarding “Personalis Servers (with new
`
`storages).” The email was retained and maintained within the course of regularly
`
`conducted business activity of Personalis, and Personalis relies on the accuracy of
`
`such emails being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`16. The document marked as Exhibit 2046 is a copy of the January 6, 2012
`
`email from John West to Mark Pratt regarding “Draft Framework for Personalis
`
`accuracy-related product development” with attachment. The email was retained
`
`and maintained within the course of regularly conducted business activity of
`
`Personalis, and Personalis relies on the accuracy of such emails being made,
`
`retained, and maintained in the course of its regularly conducted business.
`
`17. The document marked as Exhibit 2047 is a copy of the May 11, 2012
`
`Google calendar reminder for a “Personalis Weekly Team Meeting.” The document
`
`was retained and maintained within the course of regularly conducted business
`
`activity of Personalis, and Personalis relies on the accuracy of such documents being
`
`made, retained, and maintained in the course of its regularly conducted business.
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`Foresight Diagnostics v. Personalis
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`18. The document marked as Exhibit 2048 is a copy of the May 5, 2012
`
`Google calendar reminder for “Accuracy review / brainstorm” meeting. The
`
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`19. The document marked as Exhibit 2049 is a copy of the May 25, 2012
`
`Google calendar reminder for a “Personalis Weekly Team Meeting.” The document
`
`was retained and maintained within the course of regularly conducted business
`
`activity of Personalis, and Personalis relies on the accuracy of such documents being
`
`made, retained, and maintained in the course of its regularly conducted business.
`
`20. The document marked as Exhibit 2050 is a copy of the May 25, 2012
`
`email from Carlos Bustamente to Mark Pratt regarding “Founder meeting schedule
`
`change for this PM.” The email was retained and maintained within the course of
`
`regularly conducted business activity of Personalis, and Personalis relies on the
`
`accuracy of such emails being made, retained, and maintained in the course of its
`
`regularly conducted business.
`
`21. The document marked as Exhibit 2051 is a copy of the May 14, 2012
`
`email from Richard Chen to Founders, et al. regarding “Founder Working Group
`
`Proposal” with attachment. The email was retained and maintained within the
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`Personalis EX2034
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`Foresight Diagnostics v. Personalis
`IPR2023-00224 and IPR2023-00317
`course of regularly conducted business activity of Personalis, and Personalis relies
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`on the accuracy of such emails being made, retained, and maintained in the course
`
`of its regularly conducted business.
`
`22. The document marked as Exhibit 2052 is a copy of the May 15, 2012
`
`Email from Mark Pratt to John West regarding “accuracy strategy notes” with
`
`attachment. The email was retained and maintained within the course of regularly
`
`conducted business activity of Personalis, and Personalis relies on the accuracy of
`
`such emails being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`23. The document marked as Exhibit 2053 is a copy of the May 15, 2012
`
`Email from Scott Kirk to Richard Chen, et al., regarding “Sprint 0 sprint backlog.”
`
`The email was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such emails
`
`being made, retained, and maintained in the course of its regularly conducted
`
`business.
`
`24. The document marked as Exhibit 2054 is a copy of the May 22, 2012
`
`Email from John West to Richard Chen, et al., regarding “Spreadsheet for 2pm
`
`discussion of Accuracy Differentiation” with attachment. The email was retained
`
`and maintained within the course of regularly conducted business activity of
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`Personalis EX2034
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`Foresight Diagnostics v. Personalis
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`Personalis, and Personalis relies on the accuracy of such emails being made,
`
`retained, and maintained in the course of its regularly conducted business.
`
`25.
`
`The document marked as Exhibit 2055 is a copy of the May 22, 2012
`
`Email from John West to Mark Pratt regarding “My slides for meeting with Mike
`
`Snyder yesterday” with attachments. The email was retained and maintained within
`
`the course of regularly conducted business activity of Personalis, and Personalis
`
`relies on the accuracy of such emails being made, retained, and maintained in the
`
`course of its regularly conducted business.
`
`26.
`
`The document marked as Exhibit 2056 is a copy of the May 29, 2012
`
`Email from John West to Scott Kirk regarding “Accuracy documents to convert into
`
`project plan format” with attachments. The email was retained and maintained
`
`within the course of regularly conducted business activity of Personalis, and
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`Personalis relies on the accuracy of such emails being made, retained, and
`
`maintained in the course of its regularly conducted business.
`
`27.
`
`The document marked as Exhibit 2057 is a copy of the June 1, 2012
`
`Google Calendar reminder regarding “Personalis Weekly Team Meeting.” The
`
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
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`Foresight Diagnostics v. Personalis
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`28. The document marked as Exhibit 2058 is a copy of the June 15, 2012
`
`Google Calendar reminder regarding “Personalis Weekly Team Meeting.” The
`
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`29. The document marked as Exhibit 2059 is a copy of the June 22, 2012
`
`Google Calendar reminder regarding “Personalis Weekly Team Meeting.” The
`
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`30. The document marked as Exhibit 2060 June is a copy of the 29, 2012
`
`Google Calendar reminder regarding “Personalis Weekly Team Meeting.” The
`
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`31. The document marked as Exhibit 2061 is a copy of the June 7, 2012
`
`Email from John West to Richard Chen regarding “Accuracy next steps, spreadsheet
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`Personalis EX2034
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`Foresight Diagnostics v. Personalis
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`to organize the discussion” with attachment. The email was retained and maintained
`
`within the course of regularly conducted business activity of Personalis, and
`
`Personalis relies on the accuracy of such emails being made, retained, and
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`maintained in the course of its regularly conducted business.
`
`32. The document marked as Exhibit 2062 is a copy of the June 11, 2012
`
`Email from Richard Chen to John West, et al. regarding “updated board slides” with
`
`attachment. The email was retained and maintained within the course of regularly
`
`conducted business activity of Personalis, and Personalis relies on the accuracy of
`
`such emails being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`33. The document marked as Exhibit 2063 is a copy of the June 11, 2012
`
`Email from John West to Richard Chen, et al. regarding “Draft Board slides for your
`
`comments” with attachment. The email was retained and maintained within the
`
`course of regularly conducted business activity of Personalis, and Personalis relies
`
`on the accuracy of such emails being made, retained, and maintained in the course
`
`of its regularly conducted business.
`
`34. The document marked as Exhibit 2065 is a copy of the June 17, 2012
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`Email from John West to Scott Kirk regarding “Sprint 2 overview.” The email was
`
`retained and maintained within the course of regularly conducted business activity
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`Personalis EX2034
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`Foresight Diagnostics v. Personalis
`IPR2023-00224 and IPR2023-00317
`of Personalis, and Personalis relies on the accuracy of such emails being made,
`
`retained, and maintained in the course of its regularly conducted business.
`
`35. The document marked as Exhibit 2066 is a copy of the July 6, 2012
`
`Google Calendar reminder regarding “Personalis Weekly Team Meeting.” The
`
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`36. The document marked as Exhibit 2067 is a copy of the July 13, 2012
`
`Google Calendar reminder regarding “Personalis Weekly Team Meeting.” The
`
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`37. The document marked as Exhibit 2068 is a copy of the July 20, 2012
`
`Google Calendar reminder regarding “Personalis Weekly Team Meeting.” The
`
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
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`Personalis EX2034
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`Foresight Diagnostics v. Personalis
`IPR2023-00224 and IPR2023-00317
`38. The document marked as Exhibit 2069 is a copy of the July 27, 2012
`
`Google Calendar reminder regarding “Personalis Weekly Team Meeting.” The
`
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`39. The document marked as Exhibit 2070 is a copy of the July 17, 2012
`
`Email from Richard Chen to John West, et, al. regarding “Final Board Slides” with
`
`attachment. The email was retained and maintained within the course of regularly
`
`conducted business activity of Personalis, and Personalis relies on the accuracy of
`
`such emails being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`40. The document marked as Exhibit 2071 is a copy of the July 18, 2012
`
`Email from John West to Carol Tillis, et, al. regarding “JW Board slides for printing”
`
`with attachment. The email was retained and maintained within the course of
`
`regularly conducted business activity of Personalis, and Personalis relies on the
`
`accuracy of such emails being made, retained, and maintained in the course of its
`
`regularly conducted business.
`
`41. The document marked as Exhibit 2072 is a copy of the July 18, 2012
`
`Google calendar reminder regarding “2012 Personalis BOD Meeting.” The
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`Personalis EX2034
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`Foresight Diagnostics v. Personalis
`IPR2023-00224 and IPR2023-00317
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`42. The document marked as Exhibit 2074 is a copy of the July 24, 2012
`
`email from Mark Prat to Shujun Luo regarding “Quick Notes on Lab Sequencing
`
`From Discussion with JW.” The email was retained and maintained within the
`
`course of regularly conducted business activity of Personalis, and Personalis relies
`
`on the accuracy of such emails being made, retained, and maintained in the course
`
`of its regularly conducted business.
`
`43. The document marked as Exhibit 2075 is a copy of the August 6, 2012
`
`Email from Mark Pratt to John West regarding “Lab Projects” with attachment. The
`
`email was retained and maintained within the course of regularly conducted business
`
`activity of Personalis, and Personalis relies on the accuracy of such emails being
`
`made, retained, and maintained in the course of its regularly conducted business.
`
`44. The document marked as Exhibit 2076 is a copy of the August 6, 2012
`
`Email from John West to Mark Pratt regarding “Lab Projects.” The email was
`
`retained and maintained within the course of regularly conducted business activity
`
`of Personalis, and Personalis relies on the accuracy of such emails being made,
`
`retained, and maintained in the course of its regularly conducted business.
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`Foresight Diagnostics v. Personalis
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`45. The document marked as Exhibit 2077 is a copy of the August 10, 2012
`
`Email from Richard Chen to John West regarding “Sprint 4 pre planning =JW
`
`Questions & Input.” The email was retained and maintained within the course of
`
`regularly conducted business activity of Personalis, and Personalis relies on the
`
`accuracy of such emails being made, retained, and maintained in the course of its
`
`regularly conducted business.
`
`46. The document marked as Exhibit 2078 is a copy of the August 28, 2012
`
`Email from Nan Leng to Hugo Lam regarding “MiSeq 2x250 run completed over
`
`the weekend.” The email was retained and maintained within the course of regularly
`
`conducted business activity of Personalis, and Personalis relies on the accuracy of
`
`such emails being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`47. The document marked as Exhibit 2079 is a copy of the August 3, 2012
`
`Google calendar reminder regarding “Personalis Weekly Team Meeting.” The
`
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`48. The document marked as Exhibit 2080 is a copy of the August 10, 2012
`
`Google calendar reminder regarding “Personalis Weekly Team Meeting.” The
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`Foresight Diagnostics v. Personalis
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`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`49. The document marked as Exhibit 2081 is a copy of the August 17, 2012
`
`Google calendar reminder regarding “Personalis Weekly Team Meeting.” The
`
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`50. The document marked as Exhibit 2082 is a copy of the August 20, 2012
`
`Email from John West to Russ Altman regarding “USE THIS ONE: my edits/slides
`
`v2” with attachment. The email was retained and maintained within the course of
`
`regularly conducted business activity of Personalis, and Personalis relies on the
`
`accuracy of such emails being made, retained, and maintained in the course of its
`
`regularly conducted business.
`
`51. The document marked as Exhibit 2083 is a copy of the September 4,
`
`2012 Email from Richard Chen to John West, et al. regarding “Final Board Slides”
`
`with attachment. The email was retained and maintained within the course of
`
`regularly conducted business activity of Personalis, and Personalis relies on the
`
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`Personalis EX2034
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`Foresight Diagnostics v. Personalis
`IPR2023-00224 and IPR2023-00317
`accuracy of such emails being made, retained, and maintained in the course of its
`
`regularly conducted business.
`
`52. The document marked as Exhibit 2084 is a copy of the September 4,
`
`2012 Email from John West to Carol Tillis regarding “Personalis Board meeting
`
`preview.” The email was retained and maintained within the course of regularly
`
`conducted business activity of Personalis, and Personalis relies on the accuracy of
`
`such emails being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`53. The document marked as Exhibit 2085 is a copy of the September 5,
`
`2012 Google calendar reminder regarding “2012 Personalis BOD Meeting.” The
`
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`54. The document marked as Exhibit 2086 is a copy of the September 5,
`
`2012 Email from John West to Carol Tillis and Eliane Sousa, et al. regarding “John
`
`West’s Board Slides” with attachment. The email was retained and maintained
`
`within the course of regularly conducted business activity of Personalis, and
`
`Personalis relies on the accuracy of such emails being made, retained, and
`
`maintained in the course of its regularly conducted business.
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`Personalis EX2034
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`Foresight Diagnostics v. Personalis
`IPR2023-00224 and IPR2023-00317
`55. The document marked as Exhibit 2088 is a copy of the September 7,
`
`2012 Google calendar reminder regarding “Personalis Monthly Team Meeting.”
`
`The document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`56. The document marked as Exhibit 2090 is a copy of the October 5, 2012
`
`Google Calendar reminder regarding “Personalis Monthly Team Meeting.” The
`
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`57. The document marked as Exhibit 2091 is a copy of the October 9, 2012
`
`Google Calendar reminder regarding “accuracy requirements walk through.” The
`
`document was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such
`
`documents being made, retained, and maintained in the course of its regularly
`
`conducted business.
`
`58. The document marked as Exhibit 2092 is a copy of the October 10,
`
`2012 Google Calendar reminder regarding “Accuracy Bi-weekly.” The document
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`-17-
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`Personalis EX2034
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`
`
`Foresight Diagnostics v. Personalis
`IPR2023-00224 and IPR2023-00317
`was retained and maintained within the course of regularly conducted business
`
`activity of Personalis, and Personalis relies on the accuracy of such documents being
`
`made, retained, and maintained in the course of its regularly conducted business.
`
`59. The document marked as Exhibit 2093 is a copy of the October 24,
`
`2012 Google Calendar reminder regarding “Accuracy Bi-weekly.” The document
`
`was retained and maintained within the course of regularly conducted business
`
`activity of Personalis, and Personalis relies on the accuracy of such documents being
`
`made, retained, and maintained in the course of its regularly conducted business.
`
`60. The document marked as Exhibit 2094 is a copy of the October 4, 2012
`
`Email from Scott Kirk to John West regarding “Notes from the runs discussion.”
`
`The email was retained and maintained within the course of regularly conducted
`
`business activity of Personalis, and Personalis relies on the accuracy of such emails
`
`being made, retained, and maintained in the course of its regularly conducted
`
`business.
`
`61. The document marked as Exhibit 2095 is a copy of the October 10,
`
`2012 Email from Scott Kirk to John West, et al., regarding “PGS v1 Requirements
`
`draft (rev 1.10)” with attachment. The email was retained and maintained within the
`
`course of regularly conducted business activity of Personalis, and Personalis relies
`
`on the accuracy of such emails being made, retained, and maintained in the course
`
`of its regularly conducted business.
`
`-18-
`
`Personalis EX2034
`
`
`
`Foresight Diagnostics v. Personalis
`IPR2023-00224 and IPR2023-00317
`62. The document marked as Exhibit 2096 is a copy of the October 9, 2012
`
`Email from John West to Richard Chen, et al., regarding “Slide for accuracy
`
`requirements walkthrough meeting 3-5pm today” with attachment. The email was
`
`retained and maintained within the course of regularly conducted business activity
`
`of Personalis, and Personalis relies on the accuracy of such emails being made,
`
`retained, and maintained in the course of its regularly conducted business.
`
`63. The document marked as Exhibit 2097 is a copy of the October 12,
`
`2012 Email from John West to Christian Haudenschild, et al., regarding
`
`“Prioritization of Ops Sequencing projects” with attachment. The email was
`
`retained and maintained within the course of regularly conducted business activity
`
`of Personalis, and Personalis relies on the accuracy of such emails being made,
`
`retained, and maintained in the course of its regularly conducted business.
`
`64. The document marked as Exhibit 2098 is a copy of the October 19,
`
`2012 Email from John West to Richard Chen, et al., regarding “Applying for a patent
`
`on our idea of panels reflecting to exome / WGS.” The email was retained and
`
`maintained within the course of regularly conducted business activity of Personalis,
`
`and Personalis relies on the accuracy of such emails being made, retained, and
`
`maintained in the course of its regularly conducted business.
`
`65. The document marked as Exhibit 2099 is a copy of the November 1,
`
`2012 Email from John West to Carol Tillis regarding “Board slides from John West,
`
`-19-
`
`Personalis EX2034
`
`
`
`Foresight Diagnostics v. Personalis
`IPR2023-00224 and IPR2023-00317
`ready to print” with attachment. The email was retained and maintained within the
`
`course of regularly conducted business activity of Personalis, and Personalis relies
`
`on the accuracy of such emails being made, retained, and maintained in the course
`
`of its regularly conducted business.
`
`66. The document marked as Exhibit 2100 is a copy of the October 31,
`
`2012 Email from Richard Chen to John West, et al., regarding “final board slides,
`
`ready to print” with attachment. The email was retained and maintained within the
`
`course of regularly conducted business activity of Personalis, and Personalis relies
`
`on the accuracy of such emails being made, retained, and maintained in the course
`
`of its regularly conducted business.
`
`67. The document marked as Exhibit 2101 is a copy of the November 1,
`
`2012 Google Calendar reminder regarding “Personalis BOD Meeting – Breakfast
`
`will be served between 8:15am and 9am.” The document was retained and
`
`maintained within the course of regularly conducted business activity of Personalis,
`
`and Personalis relies on the accuracy of such documents being made, retained, and
`
`maintained in the course of its regularly conducted business.
`
`68. The document marked as Exhibit 2102 is a copy of the November 1,
`
`2012 Email from Shujun Luo to John West regarding “Re: Can you please email me
`
`a copy of your slides from this afternoon?” with attachment. The email was retained
`
`and maintained within the course of regularly conducted business activity of
`
`-20-
`
`Personalis EX2034
`
`
`
`Foresight Diagnostics v. Personalis
`IPR2023-00224 and IPR2023-00317
`Personalis, and Personalis relies on the accuracy of such emails being made,
`
`retained, and maintained in the course of its regularly conducted business.
`
`69. The document marked as Exhibit 2103 is a copy of the November 21,
`
`2012 Google Calendar reminder regarding “Accuracy Bi-weekly.” The document
`
`was retained and maintained within the course of regularly conducted business
`
`activity of Personalis, and Personalis relies on the accuracy of such documents being
`
`made, retained, and maintained in the course of its regularly conducted business.
`
`70. The document marked as Exhibit 2104 is a copy of the December 7,
`
`2012 Google Calendar reminder regarding “Accuracy Bi-weekl
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