IPR2023-00624
`U.S. Patent No. 8,224,282
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`EMERSON ELECTRIC CO.
`
`Petitioner,
`
`v.
`
`OLLNOVA TECHNOLOGIES LTD.
`
`Patent Owner.
`
`____________
`
`Case IPR2023-00624
`
`U.S. Patent No. 8,224,282
`
`____________
`
`DECLARATION OF JONATHAN BRADFORD
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF UNITED STATES PATENT NO. 8,224,282
`
`Emerson Exhibit 1047
`Emerson Electric v. Ollnova
`IPR2023-00624
`Page 00001
`
`
`U.S. Patent No. 8,224,282
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`EMERSON ELECTRIC CO.
`
`Petitioner,
`
`v.
`
`OLLNOVA TECHNOLOGIES LTD.
`
`Patent Owner.
`
`____________
`
`Case IPR2023-00624
`
`U.S. Patent No. 8,224,282
`
`____________
`
`DECLARATION OF JONATHAN BRADFORD
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF UNITED STATES PATENT NO. 8,224,282
`
`Emerson Exhibit 1047
`Emerson Electric v. Ollnova
`IPR2023-00624
`Page 00001
`
`
`
`IPR2023-00624
`U.S. Patent No. 8,224,282
`
`1.
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`I, Jonathan Bradford, make the following Declaration pursuant to 28
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`U.S.C. § 1746: I am a Senior IP Paralegal at the law firm of Ropes & Gray LLP.
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`2.
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`I provide this Declaration in connection with the above-identified
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`Inter Partes Review proceeding that is before the United States Patent and
`
`Trademark Office (“USPTO”). Unless otherwise stated, the facts stated in this
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`Declaration are based on my personal knowledge.
`
`3.
`
`Ex. 1001 is a true and correct copy of U.S. Patent No. 8,224,282,
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`which was obtained from the USPTO’s Public Patent Application Information
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`Retrieval (“Public PAIR”) system. This document has been marked with an
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`exhibit label and page numbers on each page at the bottom right corner. However,
`
`no alterations, other than these noted markings, have been made to this document.
`
`4.
`
`Ex. 1003 is a true and correct copy of File History of U.S. Patent No.
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`8,224,282, which was obtained from the USPTO’s Public Patent Application
`
`Information Retrieval (“Public PAIR”) system. This document has been marked
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`with an exhibit label and page numbers on each page at the bottom right corner.
`
`However, no alterations, other than these noted markings, have been made to this
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`document.
`
`5.
`
`Ex. 1005 is a true and correct copy of U.S. Patent Application
`
`Publication No. 2004/0100394 to Hitt, which was obtained from the USPTO’s
`
`Public Patent Application Information Retrieval (“Public PAIR”) system. This
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`1
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`IPR2023-00624 Page 00002
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`IPR2023-00624
`U.S. Patent No. 8,224,282
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`6.
`
`Ex. 1009 is a true and correct copy of Ollnova Technologies Ltd. v.
`
`Emerson Electric Co., 4:22-cv-01387 (E.D. Mo.) Defendants’ Opening Claim
`
`Construction Brief (October 27, 2022), which was obtained at my direction. This
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`7.
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`Ex. 1010 is a true and correct copy of Ollnova Technologies Ltd. v.
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`Emerson Electric Co., 4:22-cv-01387 (E.D. Mo.) Plaintiff Ollnova Technologies
`
`Ltd.’s Responsive Claim Construction Brief (November 17, 2022), which was
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`obtained at my direction. This document has been marked with an exhibit label
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`and page numbers on each page at the bottom right corner. However, no
`
`alterations, other than these noted markings, have been made to this document.
`
`8.
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`Ex. 1011 is a true and correct copy of Ollnova Technologies Ltd. v.
`
`Emerson Electric Co., 4:22-cv-01387 (E.D. Mo.) Defendants’ Reply Claim
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`Construction Brief (December 1, 2022), which was obtained at my direction. This
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`document has been marked with an exhibit label and page numbers on each page at
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`2
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`IPR2023-00624 Page 00003
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`IPR2023-00624
`U.S. Patent No. 8,224,282
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`9.
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`Ex. 1012 is a true and correct copy of Ollnova Technologies Ltd. v.
`
`Emerson Electric Co., 4:22-cv-01387 (E.D. Mo.) Plaintiff Ollnova Technologies
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`Ltd.’s Sur-Reply Claim Construction Brief (December 15, 2022), which was
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`obtained at my direction. This document has been marked with an exhibit label
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`and page numbers on each page at the bottom right corner. However, no
`
`alterations, other than these noted markings, have been made to this document.
`
`10. Ex. 1013 is a true and correct copy of Ollnova Technologies Ltd. v.
`
`Emerson Electric Co., 4:22-cv-01387 (E.D. Mo.) Joint Claim Construction
`
`Statement (December 20, 2022), which was obtained at my direction. This
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
`
`11. Ex. 1014 is a true and correct copy of Ollnova Technologies Ltd. v.
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`Carrier Global Corp., 9:22-cv-80388 (S.D. Fla.) Plaintiff Ollnova Technologies
`
`Ltd.’s Opening Claim Construction Brief (November 4, 2022), which was obtained
`
`at my direction. This document has been marked with an exhibit label and page
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`numbers on each page at the bottom right corner. However, no alterations, other
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`than these noted markings, have been made to this document.
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`3
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`IPR2023-00624 Page 00004
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`IPR2023-00624
`U.S. Patent No. 8,224,282
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`12. Ex. 1015 is a true and correct copy of Ollnova Technologies Ltd. v.
`
`Carrier Global Corp., 9:22-cv-80388 (S.D. Fla.) Carrier Global Corp.’s
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`Responsive Claim Construction and Indefiniteness Brief (November 18, 2022),
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`which was obtained at my direction. This document has been marked with an
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`exhibit label and page numbers on each page at the bottom right corner. However,
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`no alterations, other than these noted markings, have been made to this document.
`
`13. Ex. 1016 is a true and correct copy of Ollnova Technologies Ltd. v.
`
`Carrier Global Corp., 9:22-cv-80388 (S.D. Fla.) Plaintiff Ollnova Technologies
`
`Ltd.’s Reply Claim Construction Brief (November 30, 2022), which was obtained
`
`at my direction. This document has been marked with an exhibit label and page
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`numbers on each page at the bottom right corner. However, no alterations, other
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`than these noted markings, have been made to this document.
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`14. Ex. 1017 is a true and correct copy of Ollnova Technologies Ltd. v.
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`Carrier Global Corp., 9:22-cv-80388 (S.D. Fla.) Joint Claim Construction Chart
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`(December 5, 2022), which was obtained at my direction. This document has been
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`marked with an exhibit label and page numbers on each page at the bottom right
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`corner. However, no alterations, other than these noted markings, have been made
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`to this document.
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`15. Ex. 1023 is a true and correct copy of Ollnova Technologies Ltd. v.
`
`ecobee Technologies, ULC, 2:22-cv-00072 (E.D. Tex.) P.R. 4-3 Joint Claim
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`4
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`IPR2023-00624 Page 00005
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`IPR2023-00624
`U.S. Patent No. 8,224,282
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`Construction and Prehearing Statement (January 10, 2023), which was obtained at
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`my direction. This document has been marked with an exhibit label and page
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`numbers on each page at the bottom right corner. However, no alterations, other
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`than these noted markings, have been made to this document.
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`16. Ex. 1025 is a true and correct copy of Ollnova Technologies Ltd. v.
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`Emerson Electric Co., 4:22-cv-01387 (E.D. Mo.) Plaintiff’s Preliminary Disclosure
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`of Asserted Claims and Infringement Contentions (July 7, 2022), which was
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`obtained at my direction. This document has been marked with an exhibit label
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`and page numbers on each page at the bottom right corner. However, no
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`alterations, other than these noted markings, have been made to this document.
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`17. Ex. 1027 is a true and correct copy of U.S. Patent Application
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`Publication No. 2007/0242688 to McFarland, which was obtained from the
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`USPTO’s Public Patent Application Information Retrieval (“Public PAIR”)
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`system. This document has been marked with an exhibit label and page numbers
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`on each page at the bottom right corner. However, no alterations, other than these
`
`noted markings, have been made to this document.
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`18. Ex. 1028 is a true and correct copy of U.S. Patent Application
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`Publication No. 2006/0186214 to Simon, which was obtained from the USPTO’s
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`Public Patent Application Information Retrieval (“Public PAIR”) system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`5
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`IPR2023-00624 Page 00006
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`IPR2023-00624
`U.S. Patent No. 8,224,282
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`19. Ex. 1029 is a true and correct copy of U.S. Patent Application
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`Publication No. 2006/0071089 to Kates, which was obtained from the USPTO’s
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`Public Patent Application Information Retrieval (“Public PAIR”) system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`20. Ex. 1030 is a true and correct copy of U.S. Patent No. 8,276,829 to
`
`Stoner, which was obtained from the USPTO’s Public Patent Application
`
`Information Retrieval (“Public PAIR”) system. This document has been marked
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`with an exhibit label and page numbers on each page at the bottom right corner.
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`However, no alterations, other than these noted markings, have been made to this
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`document.
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`21. Ex. 1032 is a true and correct copy of U.S. Patent No. 7,455,236 to
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`Kates, which was obtained from the USPTO’s Public Patent Application
`
`Information Retrieval (“Public PAIR”) system. This document has been marked
`
`with an exhibit label and page numbers on each page at the bottom right corner.
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`However, no alterations, other than these noted markings, have been made to this
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`document.
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`6
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`IPR2023-00624 Page 00007
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`IPR2023-00624
`U.S. Patent No. 8,224,282
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`22. Ex. 1033 is a true and correct copy of WIPO International Application
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`Publication WO 1999/017477 to Kriz, which was obtained at my direction. This
`
`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`23. Ex. 1035 is a true and correct copy of Lex Machina: Overview for
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`E.D. Mo. (Jan. 29, 2023) (retrieved from https://law.lexmachina.com/court/moed),
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`which was obtained at my direction. This document has been marked with an
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`exhibit label and page numbers on each page at the bottom right corner. However,
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`no alterations, other than these noted markings, have been made to this document.
`
`24. Ex. 1036 is a true and correct copy of U.S. Patent Application
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`Publication No. 2005/0268629 to Ahmed, which was obtained from the USPTO’s
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`Public Patent Application Information Retrieval (“Public PAIR”) system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`25. Ex. 1037 is a true and correct copy of U.S. Patent Application
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`Publication No. 2006/0071773 to Ahmed, which was obtained from the USPTO’s
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`Public Patent Application Information Retrieval (“Public PAIR”) system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`7
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`IPR2023-00624 Page 00008
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`IPR2023-00624
`U.S. Patent No. 8,224,282
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
`
`26. Ex. 1038 is a true and correct copy of WIPO International Application
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`Publication WO 2007/036922 to Cummins, which was obtained from the WIPO’s
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`Patentscope search system. This document has been marked with an exhibit label
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`and page numbers on each page at the bottom right corner. However, no
`
`alterations, other than these noted markings, have been made to this document.
`
`27. Ex. 1039 is a true and correct copy of U.S. Patent Application
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`Publication No. 2007/0026107 to Wang, which was obtained from the USPTO’s
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`Public Patent Application Information Retrieval (“Public PAIR”) system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`28. Ex. 1040 is a true and correct copy of U.S. Patent No. 6,392,536 to
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`Tice, which was obtained from the USPTO’s Public Patent Application
`
`Information Retrieval (“Public PAIR”) system. This document has been marked
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`with an exhibit label and page numbers on each page at the bottom right corner.
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`However, no alterations, other than these noted markings, have been made to this
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`document.
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`8
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`IPR2023-00624 Page 00009
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`IPR2023-00624
`U.S. Patent No. 8,224,282
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`29. Ex. 1043 is a true and correct copy of Ollnova Technologies Ltd. v.
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`Emerson Electric Co., 6:22-cv-00358-ADA (W.D. Tex.) Declaration of Erik De La
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`Iglesia in Support of Plaintiff Ollnova Technologies Ltd.’s Responsive Claim
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`Construction Brief, which was obtained at my direction. This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
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`corner. However, no alterations, other than these noted markings, have been made
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`to this document.
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`30. Ex. 1044 is a true and correct copy of Ollnova Technologies Ltd. v.
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`ecobee Technologies, ULC, 2:22-cv-00072 (E.D. Tex.) Ollnova Technologies
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`Ltd.’s Opening Claim Construction Brief (January 31, 2023), which was obtained
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`at my direction. This document has been marked with an exhibit label and page
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`numbers on each page at the bottom right corner. However, no alterations, other
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`than these noted markings, have been made to this document.
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`31. Ex. 1045 is a true and correct copy of U.S. Provisional Patent
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`Application No. 61/037,739, which was obtained from the USPTO’s Public Patent
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`Application Information Retrieval (“Public PAIR”) system. This document has
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`been marked with an exhibit label and page numbers on each page at the bottom
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`right corner. However, no alterations, other than these noted markings, have been
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`made to this document.
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`9
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`IPR2023-00624 Page 00010
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`IPR2023-00624
`U.S. Patent No. 8,224,282
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`32. Certain pages have been resized to 8.5 x 11 inches. No content was
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`removed by this resizing.
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`33.
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`I hereby declare that all statements made herein of my own
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`knowledge are true and that all statements made on information and belief are
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`believed to be true; and further that these statements were made with the
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`knowledge that willful false statements and the like so made are punishable by fine
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`or imprisonment, or both, under 18 U.S.C. § 1001. If called to testify as to the
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`truth of the matters stated herein, I could and would testify competently.
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`34.
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`I declare under penalty of perjury that the foregoing is true and
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`correct.
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`Executed this 6th day of March, 2023, in Boston, Massachusetts.
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`
`
`
`/Jonathan Bradford/
`Jonathan Bradford
`ROPES & GRAY LLP
`
`10
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`IPR2023-00624 Page 00011
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