UNITED STATES PATENT AND 1RADEMARK OFFICE
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`BEFORE THE PA TENT TRIAL AND APPEAL BOARD
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`NIKE, INC.,
`Petitioner,
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`SHERRYWEA R LLC,
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`Patent Owner.
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`IPR2024-01123; IPR2024-01125; IPR2024-01126; IPR2024-01122; IPR2024-
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`01124; IPR2024-01128; IPR2024-01127; IPR2024-01129
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`U.S. Patent Nos. 9,295,288; 9,808,036; 10,219,550; 9,289,016; 9,723,878;
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`10,244,800; 10,219,551; 10,869,510
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`AFFIDAVIT OF SHARON GOFF IN OPPOSITION TO INSTITUTION OF
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`INTER PAR TES REVIEW OF U.S. PATENT
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`NOS. 9,295,288; 9,808,036; 10,219,550; 9,289,016; 9,723,878; 10,244,800;
`10,219,551
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`Nike, Inc. v. SherryWear, LLC et al. IPR2024-01123 SherryWear, LLC Exhibit 2001 Page 1
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`I, Sharon Goff, hereby declare as follows:
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`1. I am the owner of ShenyWear, LLC (SherryWear), which is the Patent
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`Owner of the above-listed patents, and in the above-listed cases which are currently
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`pending before the Patent Trials and Appeals Board (PTAB).
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`2. I invented the Pocket Bra because of an unmet need I saw in women's
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`clothing. Modern fashions have produced many articles of clothing for women such as
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`pants and leggings that have no pockets. I found that I and many other women I met
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`were stowing items such as phones, money, and ID cards in their bras for lack of another
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`convenient way to keep their hands free. This was uncomfortable and led to lost items.
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`3. The Pocket Bra solved this problem by adding pockets in a few places that
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`allowed women to store their item safely and comfortably while still being fashionable.
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`some spmis4. I designed and sold a few varieties of Pocket Bras, including
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`bras designed for athletic or leisure activity.
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`5. My company, SherryWear, spent considerable time and money developing
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`patents for the Pocket Bra, including the patents being challenged in this case. I filed the
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`first patent on April 26, 2011. By early 2015, Sherry Wear had a total of four patent
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`applications, two of which had issued as patents, that covered my pocket bras.
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`6. When I began marketing the Pocket Bra, I frequently spoke with women
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`who had similar experiences to my own: a lack of useful places to stow items in their
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`everyday
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`clothing. Many of these women told me that the Pocket Bra had been or would
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`be useful for resolving this issue.
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`7. For example, one mother contacted me to purchase one of the Pocket Bras
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`so that her diabetic daughter could use it to store an insulin pump. I also received requests
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`from other women asking me to produce the Pocket Bra in a wider range of sizes. These
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`are both cases I mentioned in an interview with the Berkshire Eagle on May 12, 2014,
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`which is provided with this affidavit as Exhibit SW-2002.
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`8. I manufactured and sold several hundred Pocket Bras between 2014 and
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`Nike, Inc. v. SherryWear, LLC et al. IPR2024-01123 SherryWear, LLC Exhibit 2001 Page 2
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`9. I also licensed my patents to five companies other than NIKE, starting in
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`2022, including (a) a license to Urban Savage, LLC for their Stash Bra; (b) a license
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`with Tracksmith Corporation for their Allston Bra; (c) a license to Rabbit, LLC for the
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`Strappy Pocket Bra, the UtiliBra-vo, the Crop Hop Supp01t & Pocket Tech, the Crop
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`Hop Support & Pocket, the Bunny Hopp Supp01t & Pocket, and the Crusher Crop; and
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`( d)a license to Senita Athletics, LLC for the Sarah Sp01is Bra, the Perfect Pocket Spo1ts
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`Bra, the Hustle Sports Bra, the Flight Bra, and the Sculpt Support Bra.
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`10.Each of the four companies listed above has continued to sell at least one
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`of the models I described above. The Stash Bra, the Allston Bra, the Strappy Pocket Bra,
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`the UtiliBra-vo, the Cruser Crop, the Sara Sports Bra, the Flyout Bra, and the Tangent
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`Bra are among the models still available for sale from the companies described above.
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`SherryWear also entered a license agreement with Smooth Landing, Inc., the terms of
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`which are confidential.
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`11.On June I 8, 2015, I submitted SherryWear's then-issued and pending
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`patents, and photographs of a SherryWear pocket bra, to NIKE via "NIKE Idea
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`Submission," an online idea submission platform operated by NIKE; the submission
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`contained examples ofmy spo1ts bra products. A copy of the June 18, 2015, NIKE Idea
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`Submission is provided with this affidavit as Exhibit SW-2035
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`12.I did not receive a response from Nike.
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`at NIKE viaseveral high-ranking employees 13.In January 2017, I contacted
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`Linkedln messenger including Evan Reynolds, then-Head of Marketplace Strategic
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`Investments; Rick Boyd, then-Patent Footwear specialist; Nathan Plowman, then-Senior
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`Director at NIKE; and Hillary Krane, then-General Counsel for NIKE. A copy of the
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`correspondence is provided with this affidavit as Exhibit SW-2036 and Exhibit SW-
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`2037.
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`14.Hillary Krane forwarded my messages to Paul Saraceni, then the VIP of
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`Global IP Transactions & Licensing at NIKE, on February 7, 2017.
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`Page 3 of 5
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`Nike, Inc. v. SherryWear, LLC et al. IPR2024-01123 SherryWear, LLC Exhibit 2001 Page 3
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`Nike, Inc. v. SherryWear, LLC et al. IPR2024-01123 SherryWear, LLC Exhibit 2001 Page 4
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`Sharon Goff
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`��y P(Jb
`( STEPHANIE
`A FARRIS
`*��* Commission
`II HH 463448
`�>. I<'<>
`"" Expires
`December
`16, 2027
`�0Ff1.'"
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`Page 5 of 5
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`Nike, Inc. v. SherryWear, LLC et al. IPR2024-01123 SherryWear, LLC Exhibit 2001 Page 5
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