IPR2023-01273
`U.S. Patent No. 9,136,924
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`LG ELECTRONICS INC.
`
`Petitioner,
`
`v.
`
`PANTECH CORPORATION,
`
`Patent Owner.
`
`____________
`
`Case IPR2023-01273
`
`U.S. Patent No. 9,136,924
`
`____________
`
`DECLARATION OF JONATHAN BRADFORD
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF UNITED STATES PATENT NO. 9,136,924
`
`LG Elecs. Ex. 1029
`LG Elecs. v. Pantech Corp.
`IPR2023-01273 Page 1
`
`
`U.S. Patent No. 9,136,924
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`LG ELECTRONICS INC.
`
`Petitioner,
`
`v.
`
`PANTECH CORPORATION,
`
`Patent Owner.
`
`____________
`
`Case IPR2023-01273
`
`U.S. Patent No. 9,136,924
`
`____________
`
`DECLARATION OF JONATHAN BRADFORD
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF UNITED STATES PATENT NO. 9,136,924
`
`LG Elecs. Ex. 1029
`LG Elecs. v. Pantech Corp.
`IPR2023-01273 Page 1
`
`
`
`IPR2023-01273
`U.S. Patent No. 9,136,924
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`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
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`Trademark Office (“USPTO”). Unless otherwise stated, the facts stated in this
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`Declaration are based on my personal knowledge.
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`3.
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`Ex. 1001 is a true and correct copy of U.S. Patent No. 9,136,924
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`(“’924”), which was obtained from the USPTO’s Patent Center 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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`4.
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`Ex. 1002 is a true and correct copy of File History of U.S. Patent No.
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`9,136,924 (“’924FH”), which was obtained from the USPTO’s Patent Center
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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
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`noted markings, have been made to this document.
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`5.
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`Ex. 1005 is a true and correct copy of U.S. Patent App. Pub.
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`2011/0274188 (“Sayana”), which was obtained from the USPTO’s Patent Center
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`system. This document has been marked with an exhibit label and page numbers
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`1
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`IPR2023-01273 Page 2
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`IPR2023-01273
`U.S. Patent No. 9,136,924
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`on each page at the bottom right corner. However, no alterations, other than these
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`noted markings, have been made to this document.
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`6.
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`Ex. 1006 is a true and correct copy of U.S. Provisional App. No.
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`61/331,818 (“Sayana-Prov”), which was obtained from the USPTO’s Patent Center
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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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`7.
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`Ex. 1007 is a true and correct copy of International Patent App. Pub.
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`WO2010/050689 (“Lee-689”), 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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`8.
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`Ex. 1010 is a true and correct copy of U.S. Patent App. Pub.
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`2013/0064129 (“Koivisto”), which was obtained from the USPTO’s Patent Center
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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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`9.
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`Ex. 1012 is a true and correct copy of U.S. Patent App. Pub.
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`2011/0249713 (“Hammarwall”), which was obtained from the USPTO’s Patent
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`Center system. This document has been marked with an exhibit label and page
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`2
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`IPR2023-01273 Page 3
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`IPR2023-01273
`U.S. Patent No. 9,136,924
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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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`10. Ex. 1013 is a true and correct copy of U.S. Patent App. Pub.
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`2011/0305263 (“Jongren”), which was obtained from the USPTO’s Patent Center
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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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`11. Ex. 1014 is a true and correct copy of U.S. Patent App. Pub.
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`2011/0034192 (“Lim”), which was obtained from the USPTO’s Patent Center
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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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`12. Ex. 1015 is a true and correct copy of Third Amended Docket Control
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`Order, Pantech Corporation et al. v. LG Electronics Inc. et al., No. 5:22-cv-00113-
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`RWS-JBB Dkt 98 (E.D. Tex.), 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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`13. Ex. 1016 is a true and correct copy of Docket Navigator “Time to
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`Trial” report for Judge Robert W. Schroeder, which was obtained at my direction.
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`3
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`IPR2023-01273 Page 4
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`IPR2023-01273
`U.S. Patent No. 9,136,924
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`This document has been marked with an exhibit label and page numbers on each
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`page at the bottom right corner. However, no alterations, other than these noted
`
`markings, have been made to this document.Ex. 1017 is a true and correct copy of
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`Cooklev-Declaration
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`14. Ex. 1018 is a true and correct copy of Joint Claim Construction and
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`Prehearing Statement, Pantech Corp. et al. v. LG Electronics Inc. et al., Case 5:22-
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`cv-00113-RWS-JBB (E.D. Texas), Dkt. No. 118, which was obtained at my
`
`direction. 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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`15. Ex. 1020 is a true and correct copy of International Patent App. Pub.
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`WO2009/025619 (“Göransson-619”), 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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`16. Ex. 1021 is a true and correct copy of U.S. Patent No. 9,078,236
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`(“Chun”), which was obtained from the USPTO’s Patent Center 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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`4
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`IPR2023-01273 Page 5
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`IPR2023-01273
`U.S. Patent No. 9,136,924
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`17. Ex. 1022 is a true and correct copy of U.S. Patent No. 9,247,420
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`(“Jung”), which was obtained from the USPTO’s Patent Center 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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`18. Ex. 1023 is a true and correct copy of U.S. Patent No. 9,083,411
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`(“Li”), which was obtained from the USPTO’s Patent Center 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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`19. Ex. 1024 is a true and correct copy of U.S. Patent No. 7,369,511
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`(“Utsunomiya”), which was obtained from the USPTO’s Patent Center system.
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`This document has been marked with an exhibit label and page numbers on each
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`page at the bottom right corner. However, no alterations, other than these noted
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`markings, have been made to this document.
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`20. Ex. 1025 is a true and correct copy of U.S. Patent No. 8,649,456
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`(“Xia”), which was obtained from the USPTO’s Patent Center 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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`5
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`IPR2023-01273 Page 6
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`IPR2023-01273
`U.S. Patent No. 9,136,924
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`21. Ex. 1026 is a true and correct copy of an excerpt of Sesia, Stefania et
`
`al. LTE - The UMTS Long Term Evolution: From Theory to Practice. United
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`Kingdom, Wiley, 2011, which was obtained at my direction. 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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`22. Ex. 1027 is a true and correct copy of Lin Hui and Wang Wen Bo.
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`“Coordinated Beamforming technology in TD-LTE-Advanced system.” 2010
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`International Conference on Communications and Mobile Computing. Vol. 2.
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`IEEE, 2010, which was obtained at my direction. 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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`23. Ex. 1028 is a true and correct copy of USCourts.gov “U.S. District
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`Court – Judicial Caseload Profile” for Eastern District of Texas, 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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`24. 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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`6
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`IPR2023-01273 Page 7
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`IPR2023-01273
`U.S. Patent No. 9,136,924
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`25.
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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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`26.
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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 11th day of August, 2023, in Boston, Massachusetts.
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`
`
`
`/Jonathan Bradford/
`Jonathan Bradford
`ROPES & GRAY LLP
`
`7
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`IPR2023-01273 Page 8
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